Registrar Audit Scope and Limits

[Liger]

I am getting ready to have an animated discussion with our company's EHS manager regarding our 3rd party registrar auditor's latitude in his auditing. In our last audit, a finding was written for failure to implement and maintain proper EMS training. This has now morphed into a much larger overall training restructure. We have an EMS audit coming in February, and our EHS manager is telling the engineering staff all EMS and QMS training has to be completed to pass the upcoming audit. I am pushing the position that the auditor cannot write a finding against any shortcomings in ISO9001 QMS training, only EMS 14001 training. I am looking for information to support my position, of course.

 

[AndyN]

Re: Regstrar audit scope and limits

To begin with, could we see (sanitized, of course) exactly (verbatim) what was reported as the NC?

 

[Liger]

Re: Regstrar Audit Scope and Limits

Certainly. Here is the requirement by the standard and the non-conformance as written:

Requirement: The organization shall identify training needs associated with its environmental aspects and its environmental management system. It shall provide training or take other action to meet these needs, and shall retain associated records.

Nonconformance: (My employer) has not consistently managed to identify environmental training needs and record keeping.

As a former quality manager who has developed and maintained both EMS and QMS programs, the registrar auditor cannot write a finding against ISO9001 training, as it is outside of the EMS scope. That would be akin to allowing him to pick up a micrometer used for production only, nothing environmental, and write a finding for it being out of calibration.

 

[Reg Morrison]

Re: Regstrar Audit Scope and Limits

Liger, you are correct that 3rd party auditors have to stick to and adhere to the declared audit scope and criteria. So, and typically, during the opening meeting, hopefully the auditor will address such aspects and during the final part of the meeting s/he should invite questions. It would be the perfect time for you to make sure you know the rules and will challenge the auditor if s/he gets out of bounds.

There could be instances where Q&E issues juxtapose; for example, if a customer requires green products and design engineers attend a design for the environment course. But, most of the time, Q and E issues are very specific.

 

[somashekar]

Re: Regstrar Audit Scope and Limits

I am getting ready to have an animated discussion with our company's EHS manager regarding our 3rd party registrar auditor's latitude in his auditing. In our last audit, a finding was written for failure to implement and maintain proper EMS training. This has now morphed into a much larger overall training restructure. We have an EMS audit coming in February, and our EHS manager is telling the engineering staff all EMS and QMS training has to be completed to pass the upcoming audit. I am pushing the position that the auditor cannot write a finding against any shortcomings in ISO9001 QMS training, only EMS 14001 training. I am looking for information to support my position, of course.

Training as a process is common in your QMS and EMS. I hope I am OK and you agree with me.
And so we come to training records. The EMS auditor will be interested in review of the EMS training records. Again as a process, training can be a continual activity, and there is no need to force upon self to complete training.
In fact there is no meaning of " all EMS and QMS training has to be completed to pass the upcoming audit."
If your training process has identified certain EMS training, and the same are necessary for your effective EMS performance and they have not been provided, you are exposing yourself. If you have not identified any specific EMS training requirement, and the audit brings up lack of EMS knowledge and awareness, then your training process is exposed.
So where is your catch ... ???

 

[AndyN]

Re: Regstrar Audit Scope and Limits

Certainly. Here is the requirement by the standard and the non-conformance as written:

Requirement: The organization shall identify training needs associated with its environmental aspects and its environmental management system. It shall provide training or take other action to meet these needs, and shall retain associated records.

Nonconformance: (My employer) has not consistently managed to identify environmental training needs and record keeping.

Setting aside the mission creep here, his NC statement sucks! This is NOT an accurate NC statement, it's a conclusion, based upon zero evidence! How anyone could determine that something hasn't been "consistently managed" without providing some details - and call themselves a "professional Lead Auditor" is beyond me! Frankly, this is a (bad) opinion, at best.

Reject the nc back to the CB and suggest their auditor doesn't come back!

 

[Liger]

Re: Regstrar Audit Scope and Limits

Somashekar, the issue at hand is our EHS manager stating that a huge volume of ISO9001 training needs to be done to satisfy the ISO14001 auditor and my position is that is incorrect.

Thanks to all for your input.

 

[Randy]

I wouldn't let that crappy NC into an audit report and I'd jerk a knot into an auditor on a team of mine that went out of scope like that.

Now here's a real deal....There is absolutely no requirement for any kind of training at all...Read the requirement "provide training or take other action".....Hey, if you can show that you can meet the requirement for competency without training go for it

You may have a self inflicted wound by saying that "each, every or all" will or shall receive blah, blah training....If that's so, re-evaluate who and/or what is required training and eliminate all the non-essential eyewash dribble.


Oh yeah, if the auditor did go outside scope file an appeal and complaint with the Registrar (thank goodness it ain't me)

 

[pldey42]

In the finding, as stated, I see no evidence of the registrar auditor going outside the scope of the EMS.

If the EHS manager chooses to bring the QMS into a broader CAPA , one that covers QMS as well as EMS training, that's a matter for the organization. It's not evidence that the registrar auditor is expanding the scope of the audit.

It could be that the EHS manager sees the problems with EMS training as part of a more general training problem and wants to get it fixed - perhaps not so much for certification purposes, but to improve the performance of the system and the people in it.

It's not inconceivable that skills required for an effective EMS rely upon elements of the QMS. For example, if operatives follow procedures accurately, perhaps there's less probability of environmental pollution? Perhaps equipment required in the EMS is maintained alongside QMS equipment?

Finally, was the audit finding as quoted a complete quote, or were parts redacted, e.g. examples that identify specific instances of inconsistency?

I have often found that when people take and defend a position, their ability to hear and understand each other can suffer. Is anxiety about certification distracting from making the EMS and QMS effective?

Just 2c
Pat

 

[somashekar]

Re: Regstrar Audit Scope and Limits

Somashekar, the issue at hand is our EHS manager stating that a huge volume of ISO9001 training needs to be done to satisfy the ISO14001 auditor and my position is that is incorrect.

Thanks to all for your input.

Liger.
Your EMS manager's need is overblown. This is a situation to assess specific EMS requirements that may perhaps be embedded into a QMS training objective. When you integrate systems, you begin to see the system holistically, and your sensitivity to the integration will be that much more purposeful.
Instead of calling it incorrect, why not filter with purpose, to meet the EMS objective.