OK I overstated my point, which was primarily that the OP cited ONLY an NC for the MR not being a member of management. The reasoning he disclosed here was not and has not been disclosed to the auditor, yet. There was no mention of an NC for items pointing to the lack of effectiveness of the QMS. Indeed, there were no items cited which pointed to the MR's status as a nonmanager being the cause of such ineffectiveness. I was taken aback by the introduction of "effectiveness" being raised in the thread.
We are aware the Standard states
5.5.2 Management representative
Top management shall appoint a member of the organization's management who, irrespective of other responsibilities, shall have responsibility and authority that includes
a) ensuring that processes needed for the quality management system are established, implemented and maintained,
b) reporting to top management on the performance of the quality management system and any need for improvement, and
c) ensuring the promotion of awareness of customer requirements throughout the organization.
OK, most of us agree the OP's organization was a little arrogant in not at least paying lip service to the Standard about an MR being a part of management. I think some folks are creating an idealized version of what "ensuring that processes . . ." means. Almost every manager of my acquaintance over the last 40 years has had constraints of budgets and the goals and agendas of other managers limiting his power and authority. Thus, merely being a "manager" does not confer the type of authority many here seem to assume, whereas, in Randy's words, an Executive Secretary may have more real authority and have that authority recognized by the "troops" more readily than some distant VP "
who, irrespective of other responsibilities, shall have responsibility and authority that includes . . ." which in most cases means he delegates it to someone who has a clue what Quality is all about. Frankly, I'd rather have an on-the-ground person continually tuned in on the QMS who ALSO has a pipeline back to the guys with ink in their pens who can actually make it happen than some guy who is laden with other duties and has no real clue about quality, but who is the MR because he is already a "manager." In the service branches, lots of officers in battle situations take action based on advice and counsel from the noncoms on the ground. The troops recognize the authority of that noncom, but it would be a stretch to label him/her a "manager" in the hierarchy of rank within a service branch (more like a foreman.)
While we are on the track of taking me out behind the woodshed, let's re-examine one of Steve's (Howtse) citations:
Originally Posted by ISO 19011
The audit objectives define what is to be accomplished by the audit and may include the following:
a) determination of the extent of conformity of the auditee's management system, or parts of it, with audit criteria;
b) evaluation of the capability of the management system to ensure compliance with statutory, regulatory and contractual requirements;
c) evaluation of the effectiveness of the management system in meeting its specified objectives;
d) identification of areas for potential improvement of the management system.
OK. In (a) the OP's organization agrees it did not meet audit criteria of MR being a manager. The question is what does the organization do to correct this? Most of us commenting here agree it is nonproductive to try to appeal the NC, better to correct it.
In (b), we see no evidence that OP's statutory, regulatory, or contractual requirements compel the MR to be a manager.
In (c), where is the evidence that the MR's failure to be a manager has affected the effectiveness of the QMS in meeting its specified objectives? (which I presume are as generic as most other organizations - "meet customer and regulatory requirements.") This is why I questioned raising the specter of "effectiveness" - how can any auditor tell whether a system is ineffective because the MR is not a manager defined in the organization's hierarchy?
(d) is a nonstarter here, but again I ask, "what improvement to the system would be accomplished by the MR being a manager? (documented, not anecdotal or "guessed at.")
