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Registrars and Consulting - How far can a registrar go in consulting for a company?

Q

qualityboi

#1
How far can a registrar go in consulting for a company?

If I ask ISOTS interpretation questions to a registrar is that considered consulting?

Is it still considered consulting even if no money is passed?

Would it be a problem if the same person that was answering the interpretation questions may come on site to do a registration audit?

These are all hypotheticals by the way, to alleviate concern.
 
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Jen Kirley

Quality and Auditing Expert
Staff member
Admin
#2
Re: Registrars and Consulting

Asking for interpretations is not asking for a consultation, in my view, if you ask it right.

"I want to know if I properly understand what's expected of me with the element XYZ. (state your interpretation) Did I get that right?" Even so, some registrars may hesitate to open up - and understandably so IMO.

What they can't do is claim that this-or-that method is required to satisfy a standard. Example: we have even stood toe-to-toe with registrars when arguing the FMEA requirement to conform to the FMEA Manual because the FMEA Manual clearly states it is a guideline. Result? We need an FMEA, but it does not need to be word-for-word formatted the way the FMEA Manual depicts.
 

howste

Thaumaturge
Super Moderator
#3
Re: Registrars and Consulting

How far can a registrar go in consulting for a company?

If I ask ISOTS interpretation questions to a registrar is that considered consulting?
Getting interpretations should be expected from the registrar. If they make recommendations on how to meet a requirement, then it would be consulting. If you ask them for some examples they've seen that met requirements, they can answer as long as they don't make recommendations.
Is it still considered consulting even if no money is passed?
Yes. Any advice on how to do something is consulting even if they aren't being paid for it.
Would it be a problem if the same person that was answering the interpretation questions may come on site to do a registration audit?
No. Part of their responsibility is to know the requirements and to ensure your system conforms to it. How could they possibly do that if they didn't give interpretations, even during the audit?

Also, for TS 16949, any onsite training provided by a person would be considered consulting.
TS Rules 3rd ed. said:
The provision of training, documentation development, or assistance with implementation of any management system and related training such as core tools, six sigma and lean manufacturing to a specific client is considered consulting.
Note: Training open to the public, not specific to a client, and held at a public forum is not considered consulting.
Here are a couple more relevant pieces in the Rules:
TS Rules 3rd ed. said:
Consulting
Is the provision of training, documentation development, or assistance with implementation of management systems to a specific client.
TS Rules 3rd ed. said:
The certification decision function shall confirm, prior to making a certification decision, that:...
b) any opportunities for improvement issued are supported by documented objective evidence of conformity (see section 10.0) rather than nonconformities misclassified as opportunities for improvement or written in terms that can be viewed as consulting or recommendations to address a nonconformity.
Note: The IATF considers the misuse or inappropriate application of opportunities for improvement to be a major nonconformity against the certification body.
 
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