Management Representative - Specific Training Required?

[noboost4you]

Does ISO 9001:2008 require Management Representative's to have any kind of formal training on ISO Standards? I read through the standard and couldn't find anything; however, that didn't stop our auditor from writing a minor nonconformity about it.

Statement of Finding: The Human Resources Process is not completely effective.

Objective Evidence: Criteria for competency (education, training skills and experience) was not sufficiently defined for the Management Representative.

Requirement: ISO 9001:2008, 6.2.2a

Our MR is also our Vice President. When we implemented ISO back in 2007, we revised his job description to state:

• ensuring that processes needed for the quality management system are established, implemented, and maintained
• ensuring the promotion of awareness of customer requirements throughout the company
• reporting to the management team on the performance of the quality management system and any need for improvement
• maintaining the quality management system by following and implementing processes and procedures set forth by the quality manual as written per ISO 9001:2008 standards and requirements

We also have grandfather clauses/statements signed and dated by each employee stating they are qualified to perform their respective duties and have been trained in the quality policy and supporting quality system documentation relevant to their job function.

Apparently none of this was sufficient for our auditor. I don't think he has any leg to stand on and I plan on appealing this nonconformity with our registrar.

This was the ONLY nonconformity written during our re-registration audit! That in itself, is a major accomplishment.

Any thoughts?

 

[noboost4you]

In my opinion, I think this was a retaliation for something I requested of him earlier in the audit. In the beginning of the audit, I requested his credentials for our file; ASQ, RAB, IATF cards, etc. Something I do for every auditor to ensure they are who they say they are as well as see if they're competent for their job. This didn't sit well with him and I think this is why he did what he did with this nonconformity.

 

[AndyN]

Does ISO 9001:2008 require Management Representative's to have any kind of formal training on ISO Standards? I read through the standard and couldn't find anything; however, that didn't stop our auditor from writing a minor nonconformity about it.

Statement of Finding: The Human Resources Process is not completely effective.

Objective Evidence: Criteria for competency (education, training skills and experience) was not sufficiently defined for the Management Representative.

Requirement: ISO 9001:2008, 6.2.2a

Our MR is also our Vice President. When we implemented ISO back in 2007, we revised his job description to state:

• ensuring that processes needed for the quality management system are established, implemented, and maintained
• ensuring the promotion of awareness of customer requirements throughout the company
• reporting to the management team on the performance of the quality management system and any need for improvement
• maintaining the quality management system by following and implementing processes and procedures set forth by the quality manual as written per ISO 9001:2008 standards and requirements

We also have grandfather clauses/statements signed and dated by each employee stating they are qualified to perform their respective duties and have been trained in the quality policy and supporting quality system documentation relevant to their job function.

Apparently none of this was sufficient for our auditor. I don't think he has any leg to stand on and I plan on appealing this nonconformity with our registrar.

This was the ONLY nonconformity written during our re-registration audit! That in itself, is a major accomplishment.

Any thoughts?

Apart from a poorly written non-conformity, I would suggest that the focus should be on competencies of the MR, not training, per se. I don't see where in this case you didn't demonstrate this, but the job description laid out seems to replicate the standard - which is a catch 22 situation - and you've apparently not defined what that means in a practical sense - i.e competencies - that I can see here.

So, the auditor is off with their nc and I think there's room to improve what you've got. How would you like to improve it?

 

[noboost4you]

Apart from a poorly written non-conformity, I would suggest that the focus should be on competencies of the MR, not training, per se. I don't see where in this case you didn't demonstrate this, but the job description laid out seems to replicate the standard - which is a catch 22 situation - and you've apparently not defined what that means in a practical sense - i.e competencies - that I can see here.

So, the auditor is off with their nc and I think there's room to improve what you've got. How would you like to improve it?

Our VP/MR also had lead auditor training back in the 90s which we brought up, but didn't show the auditor any evidence (he didn't want to see it).

Wouldn't the competencies of the MR be shown during the audit considering he is responsible for the organization and implementation of the audit? He (our MR) answers any questions related to the QMS posed by the auditor. If he wasn't competent, how would any of this work?

How would I like to improve it?...How can I/we improve it? How else can you show competency aside from seeing how they perform their job responsibilities. We have paperwork stating he's competent. The only other way to show it is by watching it.

 

[SteelMaiden]

First of all, doesn't your registrar send a CV for each auditor they send to you. Mine does. They ask us to review it to make sure there is no conflict of interest, that we are satisfied with the credentials, etc.

Next. As Andy said, proof of training is not to be confused with competency, but that is kind of the next step up from recording training.

I kind of like to look at it as recording how the knowledge was gained. Classroom, on-line class, on-the-job (current job, or past job). There is nothing that says a management rep has to attend any formal bricks and mortar school. That being said, most of us have some sort of training, either classes, or on-the-job. You should be able to document how that training was earned. Past experience, imho, is a very viable option. You just have to remember to back that up with periodic competency review documentation.

 

[noboost4you]

First of all, doesn't your registrar send a CV for each auditor they send to you. Mine does. They ask us to review it to make sure there is no conflict of interest, that we are satisfied with the credentials, etc.

Next. As Andy said, proof of training is not to be confused with competency, but that is kind of the next step up from recording training.

I kind of like to look at it as recording how the knowledge was gained. Classroom, on-line class, on-the-job (current job, or past job). There is nothing that says a management rep has to attend any formal bricks and mortar school. That being said, most of us have some sort of training, either classes, or on-the-job. You should be able to document how that training was earned. Past experience, imho, is a very viable option. You just have to remember to back that up with periodic competency review documentation.

Our registrar doesn't send us any training credentials per se; they just inform us who could audit us based on our SIC code. Secondly, we also participate in the US Dept. of Homeland Security Customs and Border Protection C-TPAT initiative. It is required of us to question and gather identification of anyone who may enter the building and/or perform services which may affect our operations. Again, something that was explained, but he had no clue.

Everything we do is on-the-job training. There are only a few positions that have 60 day training periods with a written test at the end to show their competent for the job. Aside from that, prior to implementation, our employees were grandfathered into the system. Any employee who is to change jobs/positions are required to complete a verification of effective training form to be filled out by their new supervisor/manager, someone from top management, and themselves. We have a handful of these forms; however, we do not have any for the MR as his role hasn't changed since implementation.

 

[AndyN]

I'm not suggesting that your auditor did you any favours here, however, I'd suggest that 'grandfathering' isn't sufficient to meet the competency requirements.

I also agree that there's nothing in the nc that backs up any facts to suggest that your MR can't handle to position, however, that said, you should still define what he/she is required to demonstrate. This would have helped you to avoid the nc in the first place, IMHO!

 

[noboost4you]

I'm not suggesting that your auditor did you any favours here, however, I'd suggest that 'grandfathering' isn't sufficient to meet the competency requirements.

I also agree that there's nothing in the nc that backs up any facts to suggest that your MR can't handle to position, however, that said, you should still define what he/she is required to demonstrate. This would have helped you to avoid the nc in the first place, IMHO!

This is why I attribute the NC to a retaliation on questioning his credentials. He reviewed the job descriptions and grandfathering statements for a dozen other individuals throughout the company; not a single question was asked about them.

The standard requires the organization to "determine the necessary competence for personnel performing work affecting conformity to product requirements; where applicable, provide training or take other actions to achieve the necessary competence,"

Like I mentioned before, we have on-the-job training. I have no quality background, but in 2007 looked into and brought ISO registration to our company within a year. I learned the standard by reading and from asking questions on this forum. The company gave me whatever tools I needed to perform the task and the end result was registration. Would the fact we're registered make me competent in this regard? I went to school for Industrial Engineering.

Throughout the quality manual, it states how the Vice President/MR is involved; such as: 4.2.3, 4.2.4, 5.5, 5.5.2, 5.6, 6.2 (He's also responsible for the HR Department!), 8.2.1, 8.2.2, 8.2.3, 8.3, 8.4, 8.5.1, 8.5.2, and 8.5.3

If that doesn't state what the Vice President/MR is required to demonstrate, I don't know what does.

 

[AndyN]

I don't disagree with you at all on the 'retaliation' comment. Certainly, I think you should ask for them to review it, especially in light of the fact that no evidence has been cited - objectively - that your MR couldn't demonstrate competency.

In trying to separate out the situation of a poor audit finding compared to your actual system, and maybe it's just a choice of words - being involved in all kinds of things, still doesn't make someone competent. It sounds to me as if you're more likely to be competent in the MR role, since you led the charge, so to speak. So, can I ask, why it is you're not the MR? Maybe that's a clue to why the auditor made some kind of deal with it. Do you spend your time with the auditor during such visits, over the current incumbent etc?

 

[noboost4you]

And bottom line, if the employee isn't competent for their job, they wouldn't be employed with us. But this is taking us away from the original question at hand with the NC.