Should a Registrar write a NC on something that was found during the Internal Audit

[AndyN]

Re: Should the Registrar write a NC on something that was found during the Internal A

Yes, I would have made a positive comment about having found the problem internally. Nonetheless, as it was presented to me in the RABQSA course: if a nonconformance is noted in an audit and it has not yet been corrected, it should be recorded.

Based on that I would do the same in an internal audit, mainly to show the audit did notice the issue and it can be followed up on to assured it is resolved.

This is assuming there was a pattern of the nonconformance occurring. If it was a one-or-two time event, I might just make an observation on an internal audit, but the 3rd party audit (for TS) doesn't allow for observations. According to the training course I went to, if there's a noted nonconformance to requirements, the only choice is to write a major or minor.

This has to do with the CB's being warned, by the accreditation bodies, about 'soft grading' of NC's, not so much ISO/TS 16949. If it reads like a minor, it should be graded as such and so on for majors.......

 

[Coury Ferguson]

Re: Should the Registrar write a NC on something that was found during the Internal A

My intent was not to start fireworks here. Just asking for opinions, simple as that.

Is there something that defines about the Soft-grading available for download/purchase? Which standards, guidance documents, or such are available?

 

[Randy]

Re: Should the Registrar write a NC on something that was found during the Internal A

Nope....cheap shot and low hanging fruit

The existance of the NC and its entry into the CA process is evidence of stuff working within the system and the ability of the system to correct itself....it's working, not broke!

I'd definitely mention the NC's and associated CA's in my report and of course track what goes on as part of my surveillance activities.

 

[Brizilla]

Re: Should the Registrar write a NC on something that was found during the Internal A

I voted yes.
It's not a 3d party auditors job to judge good intentions. Just because it is within the abitrary time limit of a Corrective Action doesn't mean it's within conformance. If it's not conforming you write it.
The majority of organizations want to do well and follow the guidlines and results of their internal audits. But, some don't. How is the auditor to know which is which? Perhaps the CAR was written to stall off the auditor so it could be dealt at their leisure. By writing an NC it basically makes sure that the company makes some attempt to correct the problem. (Not that I'm a cynic mind you.)

Let's take this one step further: How would you explain this to Management, when their thought pattern would be something like this..."Why do internal audits if the same thing will be identified during the assessment" which would cause some concern on why have the internal audit process, even though the standard requires it. It would undermine the purpose of the Internal Audit process, in my opinion.

I think it might be better to suppose the thought process of being "Why do internal audits if the same thing was missed throughout the year and was just barely identified before the assessment?" I'd have been embarrassed to find a non-conformance a couple of weeks before my CB assessment, and would have busted butt to make sure it was fixed before the day they walked in the door.

There is no such thing as a "Double Jeopardy" scenario here. If you are involved in your QMS your internal audit is there to find your flaws and give your organization an opportunity to improve itself, it's not there to defend you from your CB. On the other hand your CB is auditing you to make sure that you are adhering to the tenents of the QMS they are certifying you to.

"So, now you will have to open a CAR for something that already has a CAR open (from the internal audit)...

Why is this a big deal? You either duplicate the open one (a few extra minutes) or note on the open CAR that this was also found by your registrar on your assessment audit. The auditors don't particularly care how many CAR's you open, only that they are fixed.

I always look forward to my assessment audits, although the last recert and the next assessment I've only gotten Opportunities for Improvement. I look forward to their challenging of the QMS I am responsible for maintaining. Every chink in our armor they find is just another opportunity to make it bulletproof from my perspective.

 

[AndyN]

Re: Should the Registrar write a NC on something that was found during the Internal A

Is there something that defines about the Soft-grading available for download/purchase? Which standards, guidance documents, or such are available?

I believe that Sidney had posted the ANAB advisory back a while.

 

[Coury Ferguson]

Re: Should the Registrar write a NC on something that was found during the Internal A

I believe that Sidney had posted the ANAB advisory back a while.

Maybe Sidney can chime in here and provide that link.


:truce: Ladies and Gentlemen,

I am asking for opinions, and do not want this thread derailed. Please, keep your comments or disagreements focused on the Question and not have personal shots at anyone. Just a caution.

 

[Jen Kirley]

Re: Should the Registrar write a NC on something that was found during the Internal A

I made my responses based on the auditing course I attended, which was for TS and not AS9100. TS is the only recent information source I can provide. I wasn't sure it would be a straight across fit when I made my comment, which is why I mentioned the TS nature of my source.

I agree it's low hanging fruit. However, the nonconformance wasn't written on the audit process not noticing a problem. The write up involved a problem noted to exist (hasn't yet been resolved).

How would you explain this to Management, when their thought pattern would be something like this..."Why do internal audits if the same thing will be identified during the assessment" which would cause some concern on why have the internal audit process, even though the standard requires it. It would undermine the purpose of the Internal Audit process, in my opinion.

Was this nonconformance against the internal audit process or the corrective action process? I didn't catch:

1) How long it had been going on before being noted in internal audit
2) If it had been noted in an audit before but not attended
3) If it had been noted before, a previous attempt to resolve had been made and it failed

I would be sorely tempted to do just what Randy said, but again the purpose of a write up is to set up a means to make sure the issue is officially noted and followed up on later.

The reason for a registrar to bring up the issue is: why wasn't a requirement for root cause ensured to be met as a normal part of the corrective action process? That is, why hadn't the process made sure root cause definitions were adequate? The issue isn't that it was noticed in an internal audit, the issue, if I understand it right, was that the process had been less than satisfactory and it ended up as an audit write up.

I agree it looks circular. I just want to sum up that it appears the registrar did that to record an existing nonconformance for follow up, not spank the audit function.

 

[Coury Ferguson]

Re: Should the Registrar write a NC on something that was found during the Internal A

Was this nonconformance against the internal audit process or the corrective action process? I didn't catch:

1) How long it had been going on before being noted in internal audit
2) If it had been noted in an audit before but not attended
3) If it had been noted before, a previous attempt to resolve had been made and it failed

1. There was no previous followed system in place, to identify this earlier, than when this Internal Audit was performed.

2. The internal audit was performed two weeks before, and it was documented as a nonconformance. The procedures allows 10 working days to respond, and if needed, a 30 days extension maximum.

3. This was the first time that is was noted.

I hope this answers your questions, Jennifer.

 

[Sidney Vianna]

Re: Should the Registrar write a NC on something that was found during the Internal A

Maybe Sidney can chime in here and provide that link.

The ANAB Accreditation Rule is available via this link: 16. Identifying and Documenting Nonconformities During Management Systems Audits.

On the Aerospace Sector, the IAQG has been telling us for a long time now about "soft grading", amongst other unwelcome practices. It was the subject of my latest Quality Digest article. The AS9104 and 9101 definition of minor and major non-conformities are clear and CB auditors are expected to comply with them.

Concerning the issue at hand, we had a similar discussion at the Internal Audits save you from Non-Conformances on external audits? thread and my personal opinion was summarized in this post.

 

[Coury Ferguson]

Re: Should the Registrar write a NC on something that was found during the Internal A

The ANAB Accreditation Rule is available via this link: 16. Identifying and Documenting Nonconformities During Management Systems Audits.

On the Aerospace Sector, the IAQG has been telling us for a long time now about "soft grading", amongst other unwelcome practices. It was the subject of my latest Quality Digest article. The AS9104 and 9101 definition of minor and major non-conformities are clear and CB auditors are expected to comply with them.

Concerning the issue at hand, we had a similar discussion at the Internal Audits save you from Non-Conformances on external audits? thread and my personal opinion was summarized in this post.

Thanks Sidney for the link. One thing...after reviewing this document it reflects soft-grading in regards to ISO9001:2000, but what about AS9100?