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Page 1 of 2 |
August, 2000 |
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This Month's Feature:
Challenges To Audit Findings
One of the hardest and most stressful things for a lead auditor or an
auditor to deal with is when an auditee challenges your findings. Typically, the
most challenged item is the severity. No one wants a Major. All managers want
only Minors in their departments. That is a political question, and was answered
in part in April's issue.
It is much more of a headache when they challenge the finding itself. There
are a few things you can do to help deal with this problem.
Preventing them from the start.
The easiest way to avoid challenges is to avoid them from
the start. There are two very active things you can do to accomplish this.
First, is to accurately quote the standard (or procedure, policy, work
instruction, etc.). Don't just cite the reference, but actually quote it. There
should be absolutely no doubt as to what the noncompliance is not compliant to.
This is very important. In many cases, the auditee can't tell what compliant
looks like. For example, if the purchasing procedure states purchases will only
be made from vendors on the approved vendor list, quote it. "All purchases
will be made from companies and organizations on the approved vendor list."
The other step is to make sure you list the evidence is
enough detail as to eliminate all doubt. List what you looked at and what you
found. In our example, if you looked at four purchase orders, and two were to
companies no on the list indicate that. "Of four purchase orders examined,
two were to companies not on the approved vendor list."
Notice It did not say they were using
"unapproved" vendors. That could start an argument as to whether the
two were in fact approved. There is little the auditee can say. There is little
room for argument if you follow this.
(Continued on next page) |
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Title:
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Notes: Training your frontline workers in the
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You can order this book from internal-auditor.com at:
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Tips/Tricks/Laughter:
A name can make a world of difference. One company uses the term
"Deviation" to indicate a noncompliance. This may seem like a little
thing, but to a manager it sounds much more palatable than a
"nonconformance". Even a major deviation sounds less than a minor
nonconformance. Managers seem to accept the NCRs, called "Deviation
Reports" with little argument.
One caveat though is managers may not take the corrective action
as seriously as they should. After all it only a deviation. It isn't like it is
a nonconformance or anything.
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Observations from the field:
During an audit, it appears that the procedures are not being followed. What
can be done? Anytime our activities conflict with our procedures, we need to
change something. There can only be two choices. Either your activities must
change, or your procedure must change. Look at both to determine which is most
valid, and change the other. One important thing to remember though. As internal
auditors we should not be concerned with what changes. Our only concern should
be that whatever changes will be effective.
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Page 2 of 2 |
July, 2000 |
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This Month's Feature continued:
When they occur:
Should a challenge occur, only one of two things could happen.
They will either be founded, or not. If it turns out you were incorrect,
graciously thank the auditee for straightening you out. Usually when this
happens the auditor does not have all the information. Sometimes it occurs when
the auditee brings last minute documentation. But if your goal is to have an
effective system, that may be all right. If the auditee should have the
information readily available at the time, like with a work instruction for
example, you might want to keep the noncompliance.
If the challenge is unfounded, you have a potential nightmare
on your hands. If you did a good job in the preparation, you can find some
common ground, which the auditee should agree to. Start there, and build
consensus. You might also need to uncover what the true objection is. In many
cases what the auditee is arguing is only covering for the real complaint.
Discovering the truth may be painful, but necessary.
If all else fails, take the challenge up to ladder. At all
times show nothing but respect for the auditee. Argue the case, not the person. If
necessary, have executive management settle the dispute. If you win, don't
gloat. Continuing to show respect. If the settlement goes against you, do
nothing more than respectfully your differing opinion. Don't push it. Do not
plan any revenge, and don't run straight to your Registrar. If the finding is
valid, it will show up in a surveillance audit. When
it does, once again, no gloating, no "I told you so". Maintain your
professionalism.
Summary:
Challenges are inevitable. How you handle them is a choice.
Good Auditing!
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Internal Auditor Resources: The
MMTC is announcing it now offers an advanced internal auditor course. Visit
our special offer page for more information.
This site, and others can be located on our links page at:
http://www.internal-auditor.com |
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Questions and Answers:
Q - I wrote an NCR and included how I think the
nonconformance should be handled. They decided to handle it differently. Can I
write them up for that?
A - As auditors, our job is to get a clear picture of the current state of
our QMS. It is not our job to tell someone else how to implement their
corrective actions. If the method they chose to close the NCR is effectively
implemented and achieve the desired results, rejoice with them!
Q - How long should an auditee have to respond to an NCR?
A
- That depends on the severity of the NCR. I have seen some that have been
closed within a couple of days. This is especially true if all they need to do
is to document what they do. In case of a major problem it may take time to find
the root cause. In any case, you should have their plan for the corrective
action back within days. About the longest I've seen has been two weeks.
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Element Understanding:
4.18 Training
"Personnel performing specific assigned tasks shall be qualified on the
basis of appropriate education, training and/or experience." This is
an important and often overlooked part of Training. We want to use it to our
advantage, but we don't want to use it when it requires us to do something. Let
me explain. If you are going to say an individual is qualified because of
training, you must be able to show that the training did in fact qualify the
person. Just attending a training class or seminar is not enough. Can the person
perform as a result of the training. You really need to be able to determine
training effectiveness too! |
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Copyright notice: internal-auditor.com is fully protected under US and International copyright laws. Copying, or re-transmitting all, or any part of the internal-auditor.com is expressly forbidden
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