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

Should the Registrar write a NC for something identified during an Internal Audit?

  • Yes

    Votes: 6 24.0%
  • No

    Votes: 19 76.0%

  • Total voters
    25
B

Bob Bonville

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

Coury, If I were the Management Rep. I would be having some private words with the auditor, and possibly bumping the issue up to the Registrar. My whole career as an auditor I always asked myself a question before I documented a finding. That question was, "What will documenting this issue buy us?". As was previously stated by one of the contributors, this is really nothing more than piling on or double jepordy as one person called it.

One could write a book on the interpersonal/professional relationships between auditors and auditees. This type of an action to me is very damaging and won't buy the registrar anything. Whoever wrote up this finding may be of the school that feels they have to write something or they haven't done their job. That kind of attitude is hog wash.
 

Coury Ferguson

Moderator here to help
Trusted Information Resource
Re: Should the Registrar write a NC on something that was found during the Internal A

Coury, If I were the Management Rep. I would be having some private words with the auditor, and possibly bumping the issue up to the Registrar. My whole career as an auditor I always asked myself a question before I documented a finding. That question was, "What will documenting this issue buy us?". As was previously stated by one of the contributors, this is really nothing more than piling on or double jepordy as one person called it.

One could write a book on the interpersonal/professional relationships between auditors and auditees. This type of an action to me is very damaging and won't buy the registrar anything. Whoever wrote up this finding may be of the school that feels they have to write something or they haven't done their job. That kind of attitude is hog wash.

Bob,

Thanks for your insight here, and I am aware of the Appeals Process. I am not going to comment on the Auditor.
 

Jen Kirley

Quality and Auditing Expert
Leader
Admin
Re: Should the Registrar write a NC on something that was found during the Internal A

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.
Thanks Coury, now I have one last question based on the writeup's wording:
The Internal Audit process identified that Root Cause was not being addressed on the Internal Corrective Actions Requests.
Does this mean that:

a) A root cause analysis had not been asked for, or
b) A defined root cause was not being given in the CARs' response acceptance subprocess, or
c) There was no review being taken to approve the root cause and its response plan, or
d) The CARs' root causes were insufficient but were accepted anyway?
 

Sidney Vianna

Post Responsibly
Leader
Admin
The rules of the game have "changed"

This type of an action to me is very damaging and won't buy the registrar anything. Whoever wrote up this finding may be of the school that feels they have to write something or they haven't done their job. That kind of attitude is hog wash.
Once again, I would like to remind the people contributing to this thread about the "context" , expectations and background surrounding all AS/EN 9100 audits performed under the ICOP Scheme.

The IAQG has been very vocal and "attempting" to communicate clearly to the CB's that it won't tolerate soft grading any longer. Soft grading, in the context of Aerospace audits include those situations where a minor nonconformity has been identified, but not reported, or reported as an "opportunity for improvement", observation or any other categorization which does not require root cause investigation and correction AND corrective action.

From AS9104
3.9 Nonconformity:
The absence of, or the failure to implement and maintain, one or more quality management system requirements, or a situation that would, on the basis of available objective evidence, raise significant doubt as to the quality of what the organization is supplying.

Major: The absence of, or total breakdown of a quality management system element specified in the AQMS standard or any non-conformities where the effect is judged to be detrimental to the integrity of the product, processes or service.

Minor: A single system failure or lapse in conformance with a procedure relating to the AQMS standard.

NOTE: A number of minor non-conformities against one requirement can represent a total breakdown of the system and this can be considered as a major nonconformity. Any finding (e.g., comments, observations) that equates to the above definition shall be documented as a nonconformity, categorized as major or minor, and dealt with in accordance with 8.3.

So....the IAQG is telling us: If a CB auditor finds a single measuring device with an overdue calibration date being used, out of 120 checked devices (in other words, all remaining 119 devices were within the calibration period), the CB auditor is expected to record the non-conformity.

Numerous discussions have been held around the subject. Issues such what corrective action would be possible in the above offered scenario? Still, the decision makers won't budge. It fits the definition of a minor NC, and should be written up, as such.​

I think the scenario that Coury reported is just an example of how confrontational and adversarial AS/EN audits can become, from here on. It is critical, in my opinion, that registrants at least understand (not necessarily agree with) that the expectations have changed for the CB auditors in this field. One of the requirements being added to the AS/EN 9104/1 document stipulates that, if an auditor is caught soft grading NC's, the CB may be suspended. Which creates a risk for the CB and their clients.​

The number of NC's being reported, during AS/EN audits are expected to increase dramatically. I foresee a large number of appeals and complaints following 9100/9110/9120 audits, as an undesired byproduct. Just like the subject of this thread. Registrants must be aware of this, as well, and the likelihood of the CB's backing their auditors up.​
 

Randy

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

I see a distinct difference between "softsoaping, ANAB #16" and what the OP provided especially in the spirit of the whole process.

As presented, the organization is using its own process of system performance evaluation and monitoring (internal audit) identified a shortcoming (NC) and has entered it into its CA process,,,,this in itself is evidence of conformance and effectiveness....it's working at this point. Now if perchance the CA process requirements are violated or not met in an effective way we could possibly have (2) NC's instead of (1), the original (whatever that is) and an additional one for an ineffective CA process and most likely I'd issue both.

The spirit and letter of the law in this case is that the "system" work and in this case up to this point I have been given evidence that it does, and if it's working that's not a non-conforming situation.

The system ain't broke yet!:nope:
 

Coury Ferguson

Moderator here to help
Trusted Information Resource
Re: Should the Registrar write a NC on something that was found during the Internal A

Sidney,

I agree with what you are saying, however, this is not Soft-Grading, it is a matter of: Should the Registrar document a NC for something that has been identified during an Internal Audit?

Soft-grading isn't the issue as I have posed.

Now is there any requirements either in AS9104/1/2/3 or AS9014 that specifically address this? AS9100 or the AS9101 Checklist don't.
 
D

D.Scott

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

I didn't vote either way because I feel there are two conflicting answers to the question.

First, if the auditor was auditing I/A and found a major or minor (we don't separate them) N/C that was still open and then wrote it up, I would answer your question - NO. The auditor should make a note of it for follow up and verify the condition did not still exist.

Second, if the auditor found the condition on the floor in his normal audit or if the verification above showed the condition still existed, I would answer YES.

Let's complicate it and say the condition still existed but a temporary interim action was in place until a permanent corrective action could be established. I would consider writing that up as "low hanging fruit". I do agree a note should be made of the condition and the corrective action to allow follow-up at a later audit.

On the other hand, it only costs about $1500 to have the auditor come back to close the N/C. :sarcasm:

Dave
 

BradM

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

I voted No, and here's my rationale:

1. I am not there, and cannot see what the auditor is observing. However, if opportunities have already been noted, documented and such, what value/purpose is served by documenting it again? Aren't you pointing out the obvious? If I'm taking an introductory course in hammering, I don't need a master carpenter to show up and tell me I don't know how to hammer. Improve my situation; not make it worse.

2. I find it hard to believe that an auditor cannot find opportunities for improvement. Are there not other areas that should be observed? What about the management system that should have identified preventive activities that would have avoided the initial NC's in the first place.

I see no value for anyone by documenting the same observations previously noted, if they are truly the same.:D
 

Sidney Vianna

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

I agree with what you are saying, however, this is not Soft-Grading, it is a matter of: Should the Registrar document a NC for something that has been identified during an Internal Audit?
I understand your perspective, but I contend it is part of the broad aspect of softgrading, since the NC's do exist and you expect the CB auditor not to report it.

I know that is not your case, but what if the internal audit was done the day before the CB stage 2 audit started and the internal procedure for internal audits and corrective actions would allow for the non-conformity to linger for 1 year, before being considered delinquent? You would have a certified system with a bunch of unresolved NC's in the system?
What if the person reviewing the proposed CA's in the system does not know the distinction between correction and corrective action?

Let me ask you this: If the NC has already been reported and you are in the process of "resolving" it, what is the concern then? A lower score in the 9101 checklist? The fact that the CB will have to look for effectiveness of the CA, before closing the NC and recommending your certificate to be issued?

I voted yes in the poll, because of the context these audits are surrounded with, presently. However, as I tried to explain in my post from the other thread, as an external auditor, I would take many things into consideration, before deciding if an internally uncovered NC should be reported as part of my audit results, or not.
 

Randy

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

Wellllllllllllllll, seeing as that I don't audit AS because I don't have sufficient experience in the aerospace field to do so:lmao:, I'll back out here.
 
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