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APPLICATION ARTICLE

The following application article is part of a larger set of articles published under the title ISO 9000 in Scientific Computing as a special supplement to Scientific Computing & Automation magazine.


Survival Guide:
Surviving a Third-Party Audit

The bad news first: despite the prodigious effort involved, everyone is caught unawares on some aspect of the requirements. That's to be expected and the presence of nonconformances does not reflect negatively on any company. After all, you're paying the auditor to find something wrong. With a standard so open to interpretation as ISO 9000, that's exactly what will happen.

To make it even trickier, every auditor has a different perspective and every registrar a different approach. The experiences described below are sometimes cumulative observations by the managers for several sites under their supervision, sometimes the experience happened only once.
Now for the good news: everyone survives the audit, fixes their nonconformances, and receives a certificate. Because ISO 9000 is relatively new, the organizations who share their experiences here are the scouts who caught the arrows while blazing the trail. You have the advantage of learning from their experiences; but be forewarned that you will have nonconformances too. The path to process improvement is never easy.

What happens during audits

What gets inspected during an audit depends on your type of business, your industry, and the scope of your practices.

Most of the organizations interviewed for these articles, while being part of large corporations, are relatively small sites of 100-200 staff. As a result, they typically hosted two to three auditors for three to four days. If the company sought a TickIT registration, the audits took longer.

Be prepared to have your auditors arrive early the day your assessment begins. During the opening meeting, the auditors explain the purpose and scope of the audit, and present an agenda of the areas they wish to cover.

Next, the auditors spend an hour or two reviewing your quality manuals. They then split the various functions between them and take off with their guides to examine the processes within those areas. One auditor may visit the department handling contract review, while another may start with quality assurance.

Essentially, auditors look for consistency between what's written and what's in practice. A good auditor will investigate a point, find out what the issue is, and ask for a response before asking you to fix it. Auditors will re-word questions to ensure understanding. The object is not to catch you but to verify the process.

"During an audit," states Richard Sisk, PE Nelson. "They ask you to describe your operations, where you get your directions, and what do you do when there's a problem -- not "what does paragraph 2, section 10 say?" They ask, "if you don't know, where can you find out? Where is that information?"

"They question everyone," he continues. "They asked our Division Manager about his business plan, what his form of communication is, whether there were minutes, what issues were covered, and if there was evidence of closure on action items. The auditors were also looking for a clear definition and statement of responsibility and delegates."

"We found that the auditors chose a project and audited that project from start to finish; they don't wander the halls aimlessly," Varian's Fred Klink recalls. "During the pre-assessment, the auditors found a couple of nonconformances in operations. We had written it down and were doing it, but hadn't documented that we'd done it. Also, in R&D we found that part numbers had occasionally been written down in pencil. That's a no-no."

"Auditors have the knack for finding the weakest point," explains Geoff Belton, Fisons. "We found that they looked closest at quality control reviews for documented evidence and evidence of planning and reporting. They also wanted to know how we handled corrective actions."

Your auditors will use a checklist to track the clauses that they review in each area, checking off nonconformances and making observations in each area. Toward the end of the afternoon, the auditors assemble in a closed meeting to discuss their findings. They'll be comparing what they've found and looking for trends. You will also meet with them at the end of each day for a summary of their daily findings.

When the audit is complete, a final meeting is held to announce the results. Typically, you're passed with qualifications and given a set period of time to address the nonconformances. If you fail at this point, it will generally be caused by a significant collection of minor nonconformances. The auditors will typically stop the auditing process immediately when a major nonconformance is discovered to return at a future date when the problem is fixed. You have the option, however, to ask them to continue if you wish to uncover other areas of weakness.

Nonconformances

How many companies pass an audit the first time? The number varies depending on your source from as low as 30% to as high as 75%. It also depends upon your interpretation of "pass".

"At the end of the audit," states BSI's James Davies, "there will be one of three recommendations: One, unqualified registration. We've registered few companies with no nonconformances. Two, qualified registration. Usually there's a collection of minor nonconformances which the company has 30 days to address and provide evidence of corrective action. Three, fail. Companies usually fail due to a collection of minor nonconformances or one major nonconformance. Some companies have passed with 60-70 minor nonconformances, but it depends on the type and scope of those nonconformances."

Fisons, PE Nelson, and most of Beckman's, Varian's, and Hewlett Packard's divisions passed the first time. With the exception of Thermo Separation Products who is in the midst of implementation, everyone interviewed is currently registered to the standard.

"We had been under the impression that if we failed, we'd have to do it all over again, not just where the nonconformances arose," Mettler's Walter Kupper adds. "In fact, we were given 90 days to fix our nonconformances. If it's a minor nonconformance that can be fixed by correcting the documentation, all you need to do is send evidence to the auditor by mail that the nonconformance is fixed. If it's a major nonconformance, the auditor comes back for reinspection of that particular item. It reassured us to know that we couldn't flunk the process."

According to Davies, "The best audits happen when you've got well-prepared guides, the staff is briefed on what to expect, and the auditors don't find any major nonconformances. Eight to 10 nonconformances is a good audit. But it's not unusual to see 100 nonconformances if the site has 500-1000 employees and it's a long process."

Of the two types of nonconformances, minor nonconformances cover issues such as not signing forms. Major nonconformances include not implementing a process, not writing down what you've done, or writing "not applicable" on a clause that does apply. Major nonconformances can also be a collection of 60-70 minor incidences in the same area, such as document control.

"Our final audit didn't uncover any discrepancies in the level three procedures," Waters' Marq Ransom observes. "They did find weaknesses with the management review procedure because there was no history. Now we have monthly reviews by our QAG teams. This was the only thing they checked during their follow-up visit."

When Bio-Rad was audited, John Goetz points out that the auditors zeroed in on training issues. "We found it difficult to assess the qualifications of the trainer and lacked documentation to back it up. One of the key questions was "if you were trained, who trained you?"

"We had a chapter in our manual for Internal Audits but we hadn't implemented it," states Kupper. "This hadn't come out in the pre-assessment audit, so we weren't prepared, but that's due to the random nature of audits as to what they find and when. It gave me a new perspective on ISO -- that internal as well as external enforcement is an important component of the quality system and that this is what puts teeth into the process."

"Calibration!" declares Jim Quirk, Beckman. "Things were not calibrated, or out of calibration, or things that should have been calibrated weren't. The registrar wanted a record of all the details, whether in spec or out of spec, not just a note stating "in spec". Only two groups didn't pass the first time. They didn't have proper control over returned goods. The biggest point is do not document something you're not doing; you've got to be doing what you say you're going to do. Implementation is key!"

No other company mentioned being grilled about returned goods. In fact, that seems to be a relatively insignificant procedure when compared to the importance of other processes. Beckman's experience points out, however, that there are no insignificant procedures.

If something is not examined during the original assessment, it will be looked at the next time. "Nothing escapes," stresses Will Cowan, Hewlett Packard. "I'm sensitive to corrective action and nonconformances because it's difficult to get all the required signatures when you have hundreds of documents. The good news is that lately our auditors couldn't find any noncompliances so they were looking at things like page numbers. Now we only have minor errors such as occasionally finding an old procedure on a wall."

When all else fails

Chris Rew of Bio-Rad brings up an interesting point. "You can argue like hell with registrars to defend your procedures because one of the problems with the standard is that it is not looking for efficiency or effectiveness. Remember that you are the final decision-maker on how to run your business, and that's why it comes down to interpretation of the standard. If you don't agree with what the registrar says, you can actually send their decision to be arbitrated."

Follow-up audits

Certification is good for one year to three years depending on the registrar, with surveillance audits occurring one to four times a year depending on the results of the initial assessment. In follow-up surveillance audits, each time an assessment is conducted, certain clauses of the standard are always examined. The remaining clauses are covered over a period of one to two years of continuous assessments so that there is a complete system reassessment over time.

"All we do now for surveillance audits is refresh our memory and keep the binder area up-to-date," adds Klink. "There's not a lot of detail to remember because we do process improvement all the time."


The above article was written by Helen Gillespie, Web Master for the LIMSource, and reprinted from
Scientific Computing & Automation, February 1994


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