Our ISO registered company with approximately 180 employees extrudes, fabricates and anodizes aluminum extrusions. All parts we produce are done in house with no outside jobs being done. We have been with the same registrar going back to the 90's and QS9000. The base manufacturing processes in place have not change. This year is ISO re-registration time and the registrar has decided that Nace code 25.6 should apply (never mentioned before) there by not allowing us to use the low risk reduction. I don't know if this is to justify their wanting 7 man days instead of the typical 5 but seems to me if this should apply it would have been done decades ago. Would appreciate some outside input.
NACE Code 25.6 no reduction in CB audit days?
- Thread starter qcman
- Start date
Daniel Fisher
Registered
Hey qcman - it's possible that this was overlooked at the onset and never caught. Any respectable CB would not use such a tactic to generate additional revenue, certainly not the bigger names. Auditor time is precious, and typically CBs would rather have that auditor available for new clients, to grow the business.
I used to supply metal finishing chemicals, and looking up 25.6, it seems pretty dead-on for anodizing, "treatment and coating of metals". Were you previously using only one code for fabrication/extrusion?
I used to supply metal finishing chemicals, and looking up 25.6, it seems pretty dead-on for anodizing, "treatment and coating of metals". Were you previously using only one code for fabrication/extrusion?
Yes 25.5. Here is the reply I received. I guess it could have been over looked but it would seem this well known CB would have picked up on this decades ago. Just seems fishy.
- Previously we were working with one NACE code 25.5 Forging, pressing, stamping and roll-forming of metal; powder metallurgy, it is Low risk complexity, it means that we applied 10% of reduction. Currently, our technical team added another NACE code 25.6 Treatment and coating of metals; machining to cover all ----- Scope. It means that we cannot used the low risk reduction any longer.
If I were you, I would demand to see this policy from the Accreditation Body used under your certification scheme (ANAB, RvA, UKAS, etc. ) The methodology for estimating the number of audit days is described in the IAF MD5 Document and I don’t see there what would justify a change in risk level simply by recognizing what they knew all along about your production processes.
I would also consider entertaining quotes from other CB’s. It is amazing how “understanding” some CB’s get not to lose an account.
Daniel Fisher
Registered
It feels as though adding the new NACE code is correct, but justifications for reductions is separate, and a bit CB-specific. I agree with some of the other's advice, seeking out a competitive bid or two will tell you all you need to know. Who knows? Maybe you find your registrar has been cutting you a deal all these years
Actually it won't. As has been suggested there are CBs who will do what they will to win business. Quotes are NOT the way to determine an alternative CB to select. This is clearly a service issue. QCMan, if you do consider another couple of CBs to contact, the price - look out for extra fees - will be very similar. I'd recommend working with the Sale rep and talk to the Operations management - who are after all your "supplier", and ask them how they'd handle such an event. Their response - in writing - should inform your choice.
If anyone isn't aware, the IAF publish MD-5 (IAF.nu) and on pages 21 thru 24 it shows how audit days can be calculated. I believe if not design responsible 20% reduction in days is possible, then you use the risk table - a few processes, simple tasks etc and reduce it further and then, page 24 shows the limits for each risk category. They may have been warned for low-balling their audit days, by the AB at the last audit and instead of admitting it to you, have dreamed up the NACE/NAICS code thing, but that's just an excuse, IMHO.
Randy
Super Moderator
NACE code? Horse bagels
. Your CB might be stretching IAF MD-5 8.i.d and using the NACE code as part of the justification, so that I can't say.
Every audit I do, and like others here it's a bunch, I have to provide a duration justification and the only document I'm allowed to reference is IAF MD-5 (unless it's integrated, multisite or specific OHS then we gotta add in MD-11, MD-1, MD-22). ....Oh yeah those IAF documents are totally free for anyone to download. MD-5 being the primary, contains tables and charts describing employee counts, risk, how to determine risk and other goodies........In fact I'll reference MD-5 during the audit, explain how it works and even provide the appropriate pages if they ask........It ain't no national secret! But reference a NACE, NFPA, or anything else? Absolutely no way. I can, if I can supply supporting justification increase duration (no set limit) or decrease duration (up to 30% reduction), but the justification has to be solid, verifiable and based on accepted conditions.
Other than finding some major change has occurred (like in Scope), a serious incident has occurred, employee increase, I haven't had to justify an increase duration that often over the last 20 years.
This is a touchy area that can go 15 different directions like billiard balls (not counting the Cue Ball).
. Your CB might be stretching IAF MD-5 8.i.d and using the NACE code as part of the justification, so that I can't say. Every audit I do, and like others here it's a bunch, I have to provide a duration justification and the only document I'm allowed to reference is IAF MD-5 (unless it's integrated, multisite or specific OHS then we gotta add in MD-11, MD-1, MD-22). ....Oh yeah those IAF documents are totally free for anyone to download. MD-5 being the primary, contains tables and charts describing employee counts, risk, how to determine risk and other goodies........In fact I'll reference MD-5 during the audit, explain how it works and even provide the appropriate pages if they ask........It ain't no national secret! But reference a NACE, NFPA, or anything else? Absolutely no way. I can, if I can supply supporting justification increase duration (no set limit) or decrease duration (up to 30% reduction), but the justification has to be solid, verifiable and based on accepted conditions.
Other than finding some major change has occurred (like in Scope), a serious incident has occurred, employee increase, I haven't had to justify an increase duration that often over the last 20 years.
This is a touchy area that can go 15 different directions like billiard balls (not counting the Cue Ball).
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