Would you spend your own $$$ for ISO 9001 registration

[Jim Wynne]

Offering (by that I mean a friendly gift of advice) is one thing. Selling it to compete against consultants and other auditors is something else.

The Standard, itself, is completely silent on the question of advice from 3rd party auditors.

Guide 62 comprises the rules for auditors. My attachment is an excerpt from previous editions of Guide 62. I am not aware of new versions which make these excerpts obsolete. In my mind, they seem to say ANY form of consulting is completely off limits. Please read them and make up your own mind. I have already rendered my opinion. What's yours after reading these excerpts?

Thanks for posting a good reference and striking a blow on behalf of objectivity in a thread that has been characterized for the most part by unsupported assertions (including some of my own).
I think Guide 62 is unequivocal in asserting that "...giving specific advice towards the development and implementation of management systems for eventual certification" is verboten. The document clarifies the intent further by saying that registrar's auditors are allowed to "...[add] value during assessments and surveillance visits, e.g., by identifying opportunities for improvement, as they become evident, during the audit without recommending specific solutions." (Emphasis added.)
Pretty hard to argue with. I would be interested in hear Mr. Simpson's response to this, as it appears that his strong assertions in favor of value-added auditing are not supported by the ISO requirements for auditors.

 

[Paul Simpson]

I think Guide 62 is unequivocal in asserting that "...giving specific advice towards the development and implementation of management systems for eventual certification"is verboten. (Further emphasis added.)

Excuse the added emphasis. Not sure if any of the above contradicts what I have been saying. The intent of the guide is to ensure you don't have organizations implementing systems and then going on to register them - there may be a conflict with this! Once the system is in place the section on adding value comes into play ....

The document clarifies the intent further by saying that registrar's auditors are allowed to "...[add]

value during assessments and surveillance visits, e.g., by identifying opportunities for improvement, as they become evident, during the audit without recommending specific solutions." (Emphasis added.)

Pretty hard to argue with.

I have no argument with any of this. If you read back through my posts (and those of others who advocate value add in an audit process) it is clear there is still a dividing line between identifying where a process is not working effectively and recommending the organization investigates ways of bringing it on track or suggesting that they look at industry tools and techniques for improvement and the "...without recommending specific solutions." that ISO / IEC prohibit.

I would be interested in hear Mr. Simpson's response to this, as it appears that his strong assertions in favor of value-added auditing are not supported by the ISO requirements for auditors.

I think you will find that my "assertions" fit quiter neatly into the Guidance that is ISO / IEC Guide 62.1996 "General requirements for bodies operating assessment and certification/registration of quality systems." If I can paraphrase: Thanks for posting a good reference and providing further support for my "assertions" in this thread.

 

[Jim Wynne]

Excuse the added emphasis. Not sure if any of the above contradicts what I have been saying. The intent of the guide is to ensure you don't have organizations implementing systems and then going on to register them - there may be a conflict with this! Once the system is in place the section on adding value comes into play ....

Sorry Paul, but you're straining here. Eventual certification clearly refers to anything that happens before certification. Suffice it to say that the plain language of the guide runs counter to your personal and frankly self-serving interpretation of it.

I have no argument with any of this. If you read back through my posts (and those of others who advocate value add in an audit process) it is clear there is still a dividing line between identifying where a process is not working effectively and recommending the organization investigates ways of bringing it on track or suggesting that they look at industry tools and techniques for improvement and the "...without recommending specific solutions." that ISO / IEC prohibit.

So what you're saying is that it's OK to say, "Your document control system doesn't meet the standard, so you should try to do better, and look at 'industry tools and techniques.'"? Not much help there, I'm afraid, so I'm not sure what you're arguing for. Can you give an example of what you feel would be offering a suggestion without recommending a specific solution?

 

[Paul Simpson]

"Self-serving" - interesting slant

Sorry Paul, but you're straining here. Eventual certification clearly refers to anything that happens before certification. Suffice it to say that the plain language of the guide runs counter to your personal and frankly self-serving interpretation of it.

It is not too big a stretch for me. Sorry I don't have access to the guys who developed the guide right now to support my view but that was the intent when it was put together. Believe it or not, you still can get some unaccredited certification where a "consultant" will put in a system and then send the registrar (sometimes the same guy) to assess it. That is specifically the area they were trying to close out.

If you can't read that same interpretation from the words as you quoted them then I suggest we have nothing further to say on the matter.

So what you're saying is that it's OK to say, "Your document control system doesn't meet the standard, so you should try to do better, and look at 'industry tools and techniques.'"?

Not an area I would pick as an example of where there is plenty of room for improvement but I'll give it a go. If the customer's document control system does not meet the standard that is a non compliance. Period. I would write it up and cite the clause of the standard. If they then asked me what the problem was I would try to explain where I thought the root cause lay.

On the other hand if their document control system met the requirements of the standard but was taking a large amount of time to administer for no real benefit then I might make an observation that there are other ways of demonstrating control of documents other than the CEO signing and authorizing each page of all the work instructions in logistics. Or that holiday forms do not have to have form numbers and issue levels to be controlled documents - or even if they have to be controlled at all. None of these findings would be recorded as non compliances - observations at best - sometimes verbal observations.

Not much help there, I'm afraid, so I'm not sure what you're arguing for. Can you give an example of what you feel would be offering a suggestion without recommending a specific solution?

A typical observation I raise would normally refer to the process concerned - highlight the problem and then suggest areas to investigate, such as:
"The manufacturing process for XYZ product is producing scrap above its target level. The analysis of root cause may be supported by using a disciplined problem solving methodology such as 8D."

 

[Jim Wynne]

It is not too big a stretch for me. Sorry I don't have access to the guys who developed the guide right now to support my view but that was the intent when it was put together. Believe it or not, you still can get some unaccredited certification where a "consultant" will put in a system and then send the registrar (sometimes the same guy) to assess it. That is specifically the area they were trying to close out.

If you can't read that same interpretation from the words as you quoted them then I suggest we have nothing further to say on the matter.

I can't, so your suggestion is accepted.

A typical observation I raise would normally refer to the process concerned - highlight the problem and then suggest areas to investigate, such as:
"The manufacturing process for XYZ product is producing scrap above its target level. The analysis of root cause may be supported by using a disciplined problem solving methodology such as 8D."

So, from the standpoint of Guide 62, you think it is permissible to suggest specific solutions?

 

[Paul Simpson]

Read all the words

The key phrase is "such as". The customer can then look at 8D and any other tools he / she cares to and then decides which, if any, are appropriate.

 

[Jim Wynne]

The key phrase is "such as". The customer can then look at 8D and any other tools he / she cares to and then decides which, if any, are appropriate.

OK, now we're getting somewhere. It seems to me that Guide 62 specifically and categorically enjoins auditors from offering material assistance to an auditee in achieving registration. The example you give assumes that no major findings have occurred, thus the guidance rendered will not have an effect on whether or not the auditee gets registered. If this is correct, then it appears that non-specific observations that will have no effect on the auditee's prospects for registration are not prohibited by Guide 62.
Just for purposes of clarification, can you give an example of what you would consider a violation of the Guide 62 requirements?

 

[Paul Simpson]

Progress?

OK, now we're getting somewhere.

I'm glad you can see the progress, I'm not sure I can.

It seems to me that Guide 62 specifically and categorically enjoins auditors from offering material assistance to an auditee in achieving registration.

Enjoin is the wrong word - prohibit is the word I used earlier.

The example you give assumes that no major findings have occurred, thus the guidance rendered will not have an effect on whether or not the auditee gets registered.

Agreed. There should be no link between advice and non compliance or between advice and continuing registration.Any "advice" would have to be in one of two forms:

• advice as to means to investigate and find out what is wrong (in the case of a non compliance)
• advice as to what (other) tools and techniques are available (in the event that a process is operating outside its optimum (effectiveness / efficiency)

If this is correct, then it appears that non-specific observations that will have no effect on the auditee's prospects for registration are not prohibited by Guide 62.

That is my understanding

Just for purposes of clarification, can you give an example of what you would consider a violation of the Guide 62 requirements?

Any setting up of systems prior to assessment, any advice to the client that implies there is only one way of addressing the problem - my way!

 

[Jim Wynne]

Enjoin is the wrong word - prohibit is the word I used earlier.

"Enjoin" and "prohibit" are synonymous in this context.

Agreed. There should be no link between advice and non compliance or between advice and continuing registration.Any "advice" would have to be in one of two forms:

• advice as to means to investigate and find out what is wrong (in the case of a non compliance)
• advice as to what (other) tools and techniques are available (in the event that a process is operating outside its optimum (effectiveness / efficiency)

Now my Waffling Detector is going off again. You use the term "continuing registration"; why assume that registration has taken place already, when Guide 62 specifically refers to "...giving specific advice towards the development and implementation of management systems for eventual certification."? (My emphasis)
You also say that you think it's OK to offer advice "as to means to investigate...(in the case of a non compliance)" which means that you feel that it's OK to offer advice that assists the auditee in solving problems which would otherwise prevent registration. This sort of thing is clearly prohibited, so I must again conclude that your interpretation is biased and self-serving. The clear intent of the referenced language in Guide 62 to is to enjoin third-party auditors from assisting auditees in the registration process; that is, providing help or advice that could make the difference between achieving registration or not.

 

[Paul Simpson]

Circular arguments

"Enjoin" and "prohibit" are synonymous in this context.

My apologies, I have checked the dictionary and find that there is a use for enjoin that includes prohibit. Although why anyone should replace a word with one meaning with another with two diametrically opposite meanings is beyond me.

Now my Waffling Detector is going off again. .

I am afraid your waffling detector is malfunctioning.

You use the term "continuing registration"; why assume that registration has taken place already, when Guide 62 specifically refers to "...giving specific advice towards the development and implementation of management systems for eventual certification."? (My emphasis)
.

I think you either do not follow the thread - which I can't believe as you appear to be a reasonably intelligent man - or you choose to ignore part of my earlier post for reasons unbeknown to me. In the first part of my earlier post I specifically dealt with consultancy leading up to registration being prohibited. I then proceeded to the case of the extract from guide 62 you posted

"...[add] value during assessments and surveillance visits, e.g., by identifying opportunities for improvement, as they become evident, during the audit without recommending specific solutions." (Emphasis added.)]

How do you manage to lose the thread so quickly? I cannot be bothered with going round in circles chasing your arguments back and forth.

You also say that you think it's OK to offer advice "as to means to investigate...(in the case of a non compliance)" which means that you feel that it's OK to offer advice that assists the auditee in solving problems which would otherwise prevent registration. This sort of thing is clearly prohibited, so I must again conclude that your interpretation is biased and self-serving.

Your twisting of words does not work with me. You appear to have gone from the words of Guide 62 to another form of wording that fits your argument. Again. I have better things to do than go chasing your grammer.

The clear

In your opinion

intent of the referenced language in Guide 62 to is to enjoin third-party auditors from assisting auditees in the registration process; that is, providing help or advice that could make the difference between achieving registration or not.

Just go back to the words of the guide again and compare with what you have written - compare and contrast.