Training Competence - Contract Services

[mguilbert]

During our recent certification audit we received a non-conformance I have a question about.
Background:
This facility hires an electrical contracting company to perform our maintenance.
Their employee works full time at our facility.
The employee does not have an electricians lisc.
His employee the contractor does hold an electrical contractors lisc.
We are located in Alabama
Alabama only offers electrical lisc. for contractors or journeymen
The auditor cited the following:
"Alabama


CODE

The codes and standards currently adopted and enforced by the Alabama Building Commission (for Electricians) as state building codes are:
•2008 National Electrical Code
•2006 International Building Code
•2006 International Fire Code

ENFORCEMENT

The codes and standards are enforced by the State of Alabama Building Commission.

LICENSING

Electrical Contractor

Persons applying for statewide Electrical Contractor examination must demonstrate a minimum of four (4) years experience that show that you have designed, planned, laid-out and directly supervised electrical construction activities and the installing of electrical components. The work supervised must be commercial or industrial. The license is unlimited in voltage and bid requirements. Applicants may substitute one (1) year education in electrical curriculum for one-half (½) year electrical experience for a maximum of two (2) years credit of the four (4) years experience requirement. The applicant must submit a copy of the diploma or certificate."

I do not believe this to be an acceptable non-conformance as the contractor does have a lisc.

Thanks for your input.

 

[ScottK]

Re: Training Competance

This is an ISO audit?
I've never seen an auditor dig into state regulations, although I suppose that's a vector to show competency.

If the contractor's person on-site does not "designed, planned, laid-out and directly supervised electrical construction activities and the installing of electrical components" and is not required to I see no finding.

i.e. if you're hiring a contractor to have a guy run some lines or replaces some circuit breakers and light fixtures this license doesn't look to be required.

What is the scope of the work?

 

[mguilbert]

Re: Training Competance

Thanks for the reply.

Yes this is an ISO 9001 audit.

The employee performs electrical work as well as install new equipment. This new equipment is larger than just light fixtures. He will run lines, install new service breakers etc for the new equipment.

Thanks again,

 

[Sidney Vianna]

I do not believe this to be an acceptable non-conformance as the contractor does have a lisc.

Thanks for your input.

The external auditor has definitely strayed way out of the scope of the audit. As mentioned hundreds of times before, when the ISO 9001 standard talks about statutory and regulatory requirements, it relates to PRODUCT LEGAL REQUIREMENTS.

I would strongly push back on this nonconformity, as, if the auditor is not forced to remain within scope of the audit, s/he might think they can wander anywhere in the organization.

I would only allow this "line of investigation" if the auditor had some evidence to show that poor workmanship in electrical installations are leading to nonconforming products and/or customer dissatisfaction via, e.g., late deliveries. Short of that, the auditor performing a QMS audit has no business checking into that aspect.

 

[mguilbert]

Sidney,

I do agree with you on wandering from the scope. This facility supplies many of the rest of our facilities and if it did go down it would affect our ability to supply our customers. This our only feed mill that supplies feed to 80% of our farms. So he may be able to raise that point.

Thanks again,

 

[dsanabria]

Sidney,

I do agree with you on wandering from the scope. This facility supplies many of the rest of our facilities and if it did go down it would affect our ability to supply our customers. This our only feed mill that supplies feed to 80% of our farms. So he may be able to raise that point.

Thanks again,

You need to appeal this finding to the registrar.

The auditor used his bias and old experience to go out of the scope of the standard.

Usually a license contractor would check and double check the work done and makes sure it works properly.

If you let this one go unchallenged, the auditor would come back and write you up for the roof is leaking or the telephone lines are not running to capacity and.... you get the point (and that is what Sidney was telling you).

Email your registrar and ask them to have another competent individual review the finding - time to appeal

 

[howste]

The auditor cited the following...

I don't see a statement of nonconformity in your post, just the legal requirements. Can you please post what the auditor wrote to describe the NC?

 

[mguilbert]

The auditor sited clause 6.2.2 (2008 standard).

The statement of non-conformance : "The electrical competences was not available from the Electrical Contractors".

Objective Evidence: "The contract electrician under redacted Electric Co. Inc. does not have the License to work as an Electrician."

 

[howste]

Yes, I'd appeal it. Even the requirements to apply for the license require the person to work (without a license) for two to four years.

 

[Sidney Vianna]

The statutory and regulatory requirements paper from the ISO 9001 APG clearly stipulates

Nonconformities should be issued only in situations where identification has been made of system deficiencies or of direct violations in respect of statutory and regulatory requirements applying to the products and services of the organization.