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Sample ISO Training & Tips from Brandon Kerkstra

Four Steps to Fix a Registrar's Non-Conformance

What do you do if you do not agree with a nonconformance written by your registrar?

4 Steps

msg non conformance area1. Take a step back and really consider the nonconformance
  • Are you overly attached to your management system or
  • Is it really Not Valid (No direct requirement in the standard) or not value added?
  • Is it really a requirement in the standard, (or your company’s defined Management System) or was the auditor auditing to their own opinion?
  • Ask the auditor to show you the requirement and explain what is missing or in conflict with the requirement. This will require the auditor to read the requirement and may give the auditor a different viewpoint on requirement and will often confirm that the issue is not a valid finding. Worst case, you will have a clearer understanding of the issue.
2. If it is really not a requirement and a bad nonconformance, you really should appeal the finding, following your registrar’s process. There are several good reasons for doing this:
  • Your registrar needs to be aware of these types of findings so they can use this information to ensure their auditors are trained and consistent. This is how we can contribute to a better, more value-added audit experience
  • When you win an appeal, future auditors will know that you will not just accept a bad nonconformance, this helps when you calmly let the auditor know that you do not agree with a finding they plan to write.
  • It is very difficult to prepare a corrective action on a bad nonconformance and the root cause analysis and resulting corrective action are oftentimes not to the level that is expected.

3. Be aware that preparing a good appeal can take almost as much time as completing a basic corrective action, so sometimes when a corrective action to a bad nonconformance is easier than appeal, we might just follow that path, but if the nonconformance is really poorly written or not valid, we miss the opportunity to provide the registrar with the important opportunity to improve the overall process.

4. Appeals that result in an overturned nonconformance are typically written directly against the written nonconformance. Many times, there are additional discussions and issues that were verbally covered with the auditor. Additionally, some nonconformances are not very well written. However, the appeals committee members do not, in most cases, have all of the background information. They are left with reviewing the written appeal and the written nonconformance only, so it is best just to directly address the written nonconformance.
This general approach may also work for other types of audits including internal, corporate, or customer etc…

Most good auditors do not take appeals personally if they are aware that you do not agree with a finding and know that you will likely appeal. I find it best to let the auditor know right away that you really do not agree with the finding, but if it is toward the beginning of the audit, I would not argue too much. I leave that to just prior to the closing meeting and calmly and firmly let the auditor know that I do not agree with the finding. At that point I would likely just let the auditor know how much I disagree with the finding and let them know what I will likely appeal the finding. Notice that I use the word “Calmly” several times. In many cases the auditor feels passionate about their work and the organization’s staff can feel very passionate about their management system. It is important to work to take the emotions out of the discussion as much as possible to allow the discussion to be around the facts, the objective evidence observed and the requirement in the standard. It is always good to go back to the standard requirements directly to critique the objective evidence against.

I personally have participated in the appeal review process for accreditation bodies and have seen how a good registrar or accreditation body can and will use this information to improve consistency and provide necessary training and interpretations for their auditors.

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New AIAG / VDA FMEA Handbook Training for Design and Process PFMEAs (1st Edition 2019)
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