Manual Rejected - Unable to find "shall" to support rejection - Responsibility Matrix

[RoxaneB]

Funny thing, last week during our AS9100 recert audit, one of the auditors spoke of creating a "matrix" by including/listing responsibilities on a process flow chart we have in our QM. He brought it up as kind of an "undocumented OFI".

Responsibility "matrix" must be something they are currently stressing at auditor school.

Yeah, I was thinking something very similar. I think they want the matrix so that they don't need to actually read the manual.

Was there any discussion as to how the auditor can accept the manaual but their employer (the registrar) did not? And why it took a month from the audit to provide the feedback? Seems to me a bigger issue is with the registrar, their auditor, and the registrar's timeliness.

4.4.1 of ISO 14001 states that roles responsibilites, and authorities shall be defined, documented, and communicated. It does not say how or in what document. I see no requirement that a manual must have a responsibility matrix. If, as you stated, your lower level documents clearly define responsibilities, then there is no problem for you. The problem is for your auditor and registrar to prove there is a shall and to explain why it is okay for the auditor to accept the manual but the registrar to deny it.

Ah, Dirk, you're asking exactly what I asked our EMS Rep when he informed me of the rejection. The timeliness has ceased to be a concern of mine, though, as this does appear to be their standard pace. My eyebrow is raised over how a competent auditor can accept it but the registrar does not. And as the auditor is our auditor for ISO 9001, I'm worried what this means towards that registration.

Brian, you for your kind words. You've aptly described my own professional development. I once thought the world revolved around Quality Management Systems....but after being exposed to EMS and H&S and most recently Financial, I see so many overlaps that it just makes good business sense to streamline our processes and reduce redundancies. I have no issue with separate standards/guidelines, but I see no logical reason for my company to keep them separate.

Go get them Roxy...

I'm all set to go....release the hounds!

Al and Sidney.... for making me laugh! Granted, Al, "crap" wasn't exactly the word I used.

bmccabe, please explain what you mean by your statement that it's out of the depth for practictioners? I will admit that I had exit the Cove to cool off after reading your first post. I hardly expect a monument to be erected in my honour...the occasional sacrificial ritual, however, will be appreciated.

If you do not understand the concept of a Business Management System and the integration of requirements and processes, you could have simply asked for clarification. Your first post would have been much more appreciated and positive.

An integrated BMS hardly "tells" the boss what to do. Any Management System be it Quality, Environment, H&S, Financial, or Business should merely state what is already done. It's what the company already is doing. The only thing it "tells" the reader is where to find more information like specifics and details on tasks and responsibilities. Consider the manual like a library index system...it won't tell you all about Ancient Babylon, for example, but it will point you in the right direction to get more information.

And integrating all of these requirements allows us to identify the commonalties and make better use of our resources...efficiency and effectivess....improvement. After all, my company doesn't want to merely be a survivor...we want to be an industry leader.

 

[Randy]

Responsibility matrix? I'll cry double on this one.

I do 9, 14, 18, know about ISRS and I might as well toss in AS9100 as well as ANSI Z-10 and not one of them has a "shall" related to a matrix.

You guys do use Sid's company don't you? Please don't say it was one of my co-worker's:mg: who came up with this bogus pile of dookey.

This is a new one, maybe I'm teaching the wrong stuff Whadya think Sid?

 

[Sidney Vianna]

This is a new one, maybe I'm teaching the wrong stuff Whadya think Sid?

I think you are still seeing red from a previous thread and that is impairing your good judgement even more. Like several previous times, you are doing one thing that auditors should not do: ASSUMING. And like Wes said very appropriately in a thread many moons ago, just because you do something many times, over a long time, it does not mean that you are doing it right...Be careful, you might be surprised when you jump to conclusions.

 

[Al Rosen]

Al, "crap" wasn't exactly the word I used.

It wasn't what I thought, but it beat just seeing ****s.

 

[Randy]

I think you are still seeing red from a previous thread and that is impairing your good judgement even more. Like several previous times, you are doing one thing that auditors should not do: ASSUMING. And like Wes said very appropriately in a thread many moons ago, just because you do something many times, over a long time, it does not mean that you are doing it right...Be careful, you might be surprised when you jump to conclusions.

I was refering to the "matrix". I don't recall ever seeing it being "required". Am I in error?

As for the previous thread....water under the bridge...

 

[Sidney Vianna]

I was refering to the "matrix". I don't recall ever seeing it being "required". Am I in error?

As for the previous thread....water under the bridge...

No, you are correct. There is no such matrix required anywhere.

 

[Wes Bucey]

I have long since given up trying to divine the future from omens such as

1. one reviewer accepting a system and a second rejecting it WITHOUT citing a "shall"
2. Sidney and Randy agreeing on a course of action
3. entrails of sacrificed auditors

(Wait a minute - I DO want to examine the entrails of a sacrificed 3rd party auditor - especially draped along 30 feet of barbed wire with crows picking at them.)

Bottom line:
Sounds to me like a tailor-made opportunity for discussion at a summit conference with top registrar brass and you and your "suits." I consider myself "fairly knowledgeable" and I can't even imagine the registrar being able to justify this position, based on the facts you posit in this thread. Once the registrar backs down (as I believe it must), ask for a SUBSTANTIAL discount on the fee to make up for the aggravation they have caused you. (Spend the discount on a party for your team! Include cocktails made with CACHAÇA!)

 

[Greg B]

Hi All,

Yes it is me (lol)

I was once asked for a 'Responibility Matrix' but I think it was back in the 1987 variant. This guy/gal better get with the times!!! I agree with Claes, if they want to see something.. we show it to them it is not always written down nowadays.

Better get back to the grindstone as my Logistics duties have me loading another ship tomorrow...be gone for another week or so (it looks like it will be over Christmas)

 

[Dr. L. Ramakrishnan]

Hi

1. It is possible that the Registrar had been audited (surveillance) by the Accreditation Agency that might have brought this point. It is possible that the Accreditation Agency had raised a non-conformance on the registrar on this count (i.e. inadequacy of the manual that had not been brought out by the auditor of the registrar during the Stage I audit of your organization) and their rejection of your manual may be the "corrective" action taken by the registrar. If this is the case, it is better to work with the registrar and sort this out.
2. Kindly check if "environmental" responsibilities (e.g. dealing with EPA) and authorities (e.g. taking decision on specific environmental issues) have been included in your second level document on responsibilities and authorities and a reference is made to this document in your first level document (manual). If this is the case, you have a strong case for appeal against the registrar's decision to the Registrar's "Apellate Body", if they have one.
3. If the link between the document showing the "environmental" responsibilities and authorities and the manual is not explicit, it is better to make that explicit in the manual. Please also ensure that this document (or elements of it, as appropriate) is communicated to all those identified as "responsible" and "authorized". Once this is done, the registrar should be able to respond to your corrective action positively.

I do not know if the above is useful; I could imagine a few situations that could result in the "result" like what you had stated and I thought I should share with you.

All the best.

With kind regards,

Ramakrishnan

 

[Paul Simpson]

I think I know who ....

Yeah, I was thinking something very similar. I think they want the matrix so that they don't need to actually read the manual.

Agreed. There are registrars out there who don't trust their auditors and have a full review of each auditor report. The reviewers sit in a darkened room in headquarters and "invent" requirements that extend beyond the standard.

Ah, Dirk, you're asking exactly what I asked our EMS Rep when he informed me of the rejection. The timeliness has ceased to be a concern of mine, though, as this does appear to be their standard pace. My eyebrow is raised over how a competent auditor can accept it but the registrar does not. And as the auditor is our auditor for ISO 9001, I'm worried what this means towards that registration.

Again an indicator of who this registrar is. There are some report review processes that go out beyond the visit cycle! So, as an auditor or a client, you can be asked questions by the reviewer about the visit before last! The crux of the matter is the "additional requirements that the auditor on the ground is unaware of but that come up in the review. I have some customers who are still waiting for certificates 12 months after a positive recommendation!

I am now dealing with an auditor from the same registrar (if my guess is correct) who has come in to a company I have helped with their EMS systems and he has created a raft of new requirements for their aspects, legislation and audit and has "encouraged" them to change their system so it is more readable to him. I am now between a rock and a hard place - I either tackle him head on, knowing how stubborn the reviewers are and expose their processes, and end up devaluing assessment and certification - or I go along with his "requirements" and add bureaucracy to their system with no added value.

Seems like an ideal target for a "Name and Shame" - anyone thought about doing that?

An integrated BMS hardly "tells" the boss what to do. Any Management System be it Quality, Environment, H&S, Financial, or Business should merely state what is already done. It's what the company already is doing. The only thing it "tells" the reader is where to find more information like specifics and details on tasks and responsibilities. Consider the manual like a library index system...it won't tell you all about Ancient Babylon, for example, but it will point you in the right direction to get more information.

And integrating all of these requirements allows us to identify the commonalties and make better use of our resources...efficiency and effectivess....improvement. After all, my company doesn't want to merely be a survivor...we want to be an industry leader.

Agreed totally. We should end up being a mixture of technical author and systems analyst. The system as it is documented should be a reflection of what the organization does, not what each standard requires. The clever bit on our part is ensuring that the elements of each standard are addressed and being able to point this out to anyone who we wish to show the system to. Third party auditor, customer, .....Now there is a good use for a matrix.