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I have been lately plagued with a client who insists on dealing with a specific CB with whom I have witnessed multiple auditing issues whether in relation to auditing behavior, process or competence in accurately interpreting the standard.
Please respond to some of the fillowing queries, as i am interested in getting various perspectives on the hot debates I had with the CB auditors on some of the key issues related to interpretation of various clauses:
1. With regards to the extent of involvement of the organization in managing or controlling safety risks and ensuring legal compliance in the workplace, what exactly is required? The CB for instance expects the organization to perform risk assessment of all permanent and temporary contractor activities and assess legal compliance for their activities regardless of what the contract document states on such requirements. On my part I clarified that the key words are " to take into consideration contractor activities" and more importantly "within the workplace" which is defined as activities which "are under the control of the organization". Now, if there is no contractual requirement between the organization and contractor to perform such risk assessment or legal compliance would their activities still be considered under the organization's control?
2. The CB insist that food safety should be considered fully under the ohsas system to the extent of checking the calibration of food temperature gages in chillers, is that right? Is it withing the scope of the standard?
3. The CB insist that all employees should be aware of the scales used for rating likelihood and severity and be able to fluently explain it to their auditors regardless of the said employee's education, skill or experience. Efforts to convince the auditors that the standard requires employee participation and doesn't necessitate that all employees must be included and are aware of the intricacies of the risk assessment process as long as they are aware of the risks in their workplace and are aware of the controls in place and a group of employees awho are involved in the work being assessed are able to accurately explain the process, what do you think?
4. The CB auditors will insist that reference to relevant legal documents should be included in the risk register thus -in my opinion- misinterpreting the standard's requirement of considering legal requirements related to the risk assessment process not with regards to linking the activities being assessed to its corresponding legal requirements,what do you think?
5. The auditors insist that noise level monitoring must be done in the office despite the legal requierement being implementing a noise conservation program and monitoring noise levels at twa of more than 85dba per day, what do you think?
6. The auditors will interfere with the organization's choice of controls to reduce risk and raise ncr that they are unsuitable despite having no legal requirement which mandates such controls, what do you think?
7. In the country where this is happening, there are federal laws and state laws which relate to the federal laws and are more detailed, however the auditors insisted that all federal and state laws must be included in the compliance assessment is this right?
8. The CB auditors during the certification audit of the organization and without any notice to contractors commence auditing the contractors activities, demanding their competence reckrds and risk assessment records and calibration records despite having shown them that there is no contractual requirement for auditing contractors, furthermore, after an auditor finished asking a truck driver about safety risks and controls and assessing the driver's awareness in a very patronizing manner insisted that the driver operates the crane in the truck where the truck is parked despite the driver's request to move the truck to a clear area for safety which lead to an accident and the auditor noted it as proof of incompetence, what do you think?
There are many other debatable topics and behaviors but for now i would like your comments on the topics i mentioned, please.
Please respond to some of the fillowing queries, as i am interested in getting various perspectives on the hot debates I had with the CB auditors on some of the key issues related to interpretation of various clauses:
1. With regards to the extent of involvement of the organization in managing or controlling safety risks and ensuring legal compliance in the workplace, what exactly is required? The CB for instance expects the organization to perform risk assessment of all permanent and temporary contractor activities and assess legal compliance for their activities regardless of what the contract document states on such requirements. On my part I clarified that the key words are " to take into consideration contractor activities" and more importantly "within the workplace" which is defined as activities which "are under the control of the organization". Now, if there is no contractual requirement between the organization and contractor to perform such risk assessment or legal compliance would their activities still be considered under the organization's control?
2. The CB insist that food safety should be considered fully under the ohsas system to the extent of checking the calibration of food temperature gages in chillers, is that right? Is it withing the scope of the standard?
3. The CB insist that all employees should be aware of the scales used for rating likelihood and severity and be able to fluently explain it to their auditors regardless of the said employee's education, skill or experience. Efforts to convince the auditors that the standard requires employee participation and doesn't necessitate that all employees must be included and are aware of the intricacies of the risk assessment process as long as they are aware of the risks in their workplace and are aware of the controls in place and a group of employees awho are involved in the work being assessed are able to accurately explain the process, what do you think?
4. The CB auditors will insist that reference to relevant legal documents should be included in the risk register thus -in my opinion- misinterpreting the standard's requirement of considering legal requirements related to the risk assessment process not with regards to linking the activities being assessed to its corresponding legal requirements,what do you think?
5. The auditors insist that noise level monitoring must be done in the office despite the legal requierement being implementing a noise conservation program and monitoring noise levels at twa of more than 85dba per day, what do you think?
6. The auditors will interfere with the organization's choice of controls to reduce risk and raise ncr that they are unsuitable despite having no legal requirement which mandates such controls, what do you think?
7. In the country where this is happening, there are federal laws and state laws which relate to the federal laws and are more detailed, however the auditors insisted that all federal and state laws must be included in the compliance assessment is this right?
8. The CB auditors during the certification audit of the organization and without any notice to contractors commence auditing the contractors activities, demanding their competence reckrds and risk assessment records and calibration records despite having shown them that there is no contractual requirement for auditing contractors, furthermore, after an auditor finished asking a truck driver about safety risks and controls and assessing the driver's awareness in a very patronizing manner insisted that the driver operates the crane in the truck where the truck is parked despite the driver's request to move the truck to a clear area for safety which lead to an accident and the auditor noted it as proof of incompetence, what do you think?
There are many other debatable topics and behaviors but for now i would like your comments on the topics i mentioned, please.
