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Internal audits and pastures new?
By Allan J. Sayle, President Allan Sayle Associates

Does the idea of process review comply with ISO 9001:2000?
Might process review as a surrogate for internal audits accord with my publicly expressed views?
If the precedent becomes the norm – will we visit fresh woods and pastures new?
Self certification
Effects on the registration industry
What should be the ISO position and that of the TC committee?
Appendix 1
Appendix 2 - My publicly expressed views over the years

If the precedent becomes the norm – will we visit fresh woods and pastures new?

New thinking and change is always welcome. Auditors must think and accept new practice, new ideas. Semantics are less important than business needs and results.

So, are these developments to be welcomed? Yes. Jim Wade has it right in writing:

“…it is less a case of eliminating a requirement and more of taking a fresh look at the requirement and coming up with creative interpretations that:
[primarily] make good business sense in the light [of] accepted good management practice.
[secondarily] meet the requirements of the standard.”

If the precedent of accepting PR in lieu of internal auditing becomes the norm, in the ISO 9K registration industry, the following key matters deserve consideration:

What does an ISO 9K certificate mean to the user?
The effects on auditor training
The effects on the registration industry.
The effects on ISO 9K et al.

What does an ISO 9001:2000 certificate mean to the user?

Perhaps the first consideration has to be, who has issued the certificate? Judging by initial expressions of concern and dissent posted on the Elsmar Cove by some individuals working for different registrars, there is now potentially any number of certificates each reflecting individual registrar’s views about compliance. Each would be based on the particular registrar’s auditor’s and registrar’s organization’s interpretation of the meaning of the standard and what is and is not acceptable as a means of complying with its content.

That being so, one must ask is there a need for a “sanctioned interpretation” about PR etc, as Mr. Wade describes? Moreover, and more crucially, should there be any sanctioned interpretations at all? I will not advise on either of those two questions as they are of less relevance to business actualite. That actualite raises more important considerations.

Even if the ISO 9001 and registration industries agreed there should be sanctioned interpretations, if the customer is going to participate in the PR, does he or should he care about them for his particular business needs? Does or should he care about a registrar’s interpretation of the supplier’s compliance: in other words, does that customer effectively need a registrar’s approval for how it will work with the supplier and meet ISO 9001: for its own contract?

The answers, of course, are respectively: no; no; and no. In effect, they strike at the heart of the original purpose of ISO 9000. The customer and supplier may be guided by some of the standard’s precepts but will formulate their own practical QMS and certify it with execution of their contract. This will change the terms and conditions, T’s and C’s, of the customer’s contracts. No longer will the customer require compliance with the requirements of the standard: rather it will be more appropriate for the customer to stipulate the standard shall be used as a guide.

So, one could argue in accepting a company’s views on how to comply with ISO 9001:2000, the particular registrar(s) accepting PR et al have paved the way for the abandoning of registration as a mandatory requirement. To coin an American expression, have turkeys voted for Thanksgiving? Perhaps not, for reasons explained below. There is a world beyond ISO 9001:2000.

In the case of auditor training and certification schemes, probably ”yes”, for those registrars who are providing them. For the RABQSA and IQA’ own schemes, they may well prepare for a significant drop in certifications (and associated cash flow.) I find it all rather pleasing for, as I mention elsewhere in this article, the general quality of results has long been poor.

A fall-off in auditor training, though, is only one possible outcome. More significant is the possibility for entering a new era of self-certification by the supplier.


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