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Competence Requirements for Internal Auditors

Discussion in 'AS 91XX - Aerospace Quality Standards' started by Laura N., Jun 3, 2020.

  1. Golfman25

    Golfman25 Well-Known Member

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    Nope. In 20+ years, just two bad experiences. But in those years I also learned to pick your battles and how to make things easy for the auditors. While I agree that the number 1 goal of the QMS is to benefit your company and thus you shouldn't do anything "just for the auditor" there is a strong secondary goal which is to pass an audit with as little stress as possible.

    So you're claiming the auditor is incompetent because he referenced section 9.2. I see no such reference. The only reference is to "internal audit process." And it wasn't even a finding, more like a heads up. When asked for clarification, he pointed to 7.2 which requires competency criteria.

    Linda's question was do they need internal auditor training. Sure the technically correct answer is -- no, not specifically required by the standard. But for a small company of 12, just starting its journey, it's probably a good idea for someone to have such training at some point in their career. As I have said, it's an efficient way to get the knowledge. So when the auditor asks, how do we know auditor Bob is competent -- you can show him Bob did training with xyz and did these 3 audits in which he did a great job. Then your moving on to more important stuff. Or you can argue that Bob doesn't need training and he learned internal auditing thru osmosis.
     
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  2. Laura N.

    Laura N. Member

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    As I said originally , my history is ISO9001 with my previous company of 28 years. We went through multiple iterations before we found a system that worked for us, working with auditors that would tell us..."no do it this way" only to be told by the next one from the same company...."who told you that? it is all wrong"
    The end is that I was hired to help implement AS9100 for this company and I want to make sure it happens for them as painlessly as possible, in a manner that will lend itself to becoming an integral part of the day to day of the company, not something that is so painful that no one wants anything to do with it.
    If training is required I want to recommend it, but I want it to be training that will be the best for them and give them the best chance of not only getting certified but also maintaining the certification. Spending hours on training that will have little or no application in any environment serves no purpose and wastes money.
    It is easy to get soured on auditors, not all of them are good at being objective ;) Andy you are right - it is the legacy we leave for others, I don't intend to be a person who does just enough to get by and lets the rest slide. If I start with internal auditor training it will be up to me to prove my competency going forward and that is the direction I will go.

    I appreciate the input from everyone, it keeps a broader perspective doesn't it? Any other thoughts of suggests please add them as you think of them.

    Watch this space for updates.

    My best to everyone,

    Laura
     
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  3. Andy Nichols

    Andy Nichols Moderator Staff Member

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    Easy to say, difficult to do! It MAY have been what YOU did. Laura's options are wider. She can hire me, for example, and not even worry about competencies ever again. Job done! All my AS 9100D/9120 clients have NEVER had even a comment (at a stage 1, if unaddressed it will be a non-conformity) during ANY of their audits. Plus, their audits are more than simply compliance driven, to keep their CB "happy".

    Laura can also search hundreds of training options, but how will she discover which is the training which will impart the most effective transfer of skills and knowledge? For the budget. How will they know their chosen candidates are the right ones to even attend training? Once they'd been in class (if that's the chosen medium) how will they apply what they've learned? Who will give feedback. Glib answers don't address these questions which people are still left unable to answer.

    I make my living providing solutions which have a legacy to be proud of...
     
  4. Golfman25

    Golfman25 Well-Known Member

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    You're just arguing in circles. Sure they could contract out internal audits, but if they don't use you, they'll have the same questions in your paragraph 2. How do you know? You don't -- But you ask around and seek out recommendations. Welcome to the real world.
     
  5. Laura N.

    Laura N. Member

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    ;)So what does Laura do?

    Your right there are hundreds of training options. is a 4 hour class good enough? 8 hours? 24 hours? How do we tell if there focus or accreditation is as it should be?

    What about hiring someone from outside? what is the cost of that? should I tell our company that hired me to do this that not only they have to maintain a full time rep but they either have to put more money into training or commit to a constant outlay of cash for a auditor to come in 4-6 times a year for internal audits?
     
  6. Andy Nichols

    Andy Nichols Moderator Staff Member

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    Great question!

    Here's what I would do and this should be the way this topic is approached:

    Establish a budget figure "not to exceed" with your management. If you don't know how much they are prepared to spend, you will fail. You'll send too little or too much. You won't know the RoI and no-one doing this should forget that.

    Your QMS process for anyone to be determined competent should be followed! The process SHOULD define competencies for the role in terms of things to be demonstrated (if it doesn't, the process needs fixing). Auditor competencies can include basics like correct spelling, grammar and punctuation (some folks don't know when to use "there", "their" or "they're" etc so the audit report is going to put them in a bad light, for a start!). How about planning? Which candidates for auditor would create a shopping list before visiting a grocery store? How would that list look? How observant are they? When they look at the workplace in manufacturing, what do they see (if they've been locked in an office for years, probably not a lot). The list goes on. On personal attributes, how about open minded? Ok, so it's not the way THEY would do something, but they can critically think through what they are being told and reconcile it, without judgement, name calling and off hand-dismissal of a comment. The ability to ask questions, to evaluate facts, not jump to conclusions (ISO 19011 talks a lot about these things). In many cases people need a desire to learn, empathy for the person in the job they are auditing. Soft skills as well as hard. So often missing from people who claim to "know what they're doing".

    The hard skills are also important. Do they need to understand and be competent in AS9100D? Do they need to know and be competent the basics of the processes of the business? Can they write a one-page summary and conclude what they have seen? And so on. If anyone thinks you can get all this in a class is delusional and not a trainer (fortunately, I am and an instructional designer too).

    As far a class to help with some of the aspects of auditing, here's what I'd do:

    Determine what candidates you have to work with (1? 2? 3?) and see what they need to know - put them through the competency evaluation. If you decide an auditor course would help, you'll likely want to send a few "best fit" candidates will be sent to a locally available venue to keep logistics sensible. Your time line will also dictate this. Contact providers and have them provide details of how their Cours materials addresses demonstrating competency? Is it a test? Does the instructor provide counseling? Would provide a written evaluation on key aspects?

    Sure it seems a lot of work. But then doing "quality" is. It's planning to avoid a train wreck, not something else and certainly not bending to a silly auditor's comment.

    Laura, I have no commercial interest, but please feel free to reach out and I'd be happy to fill in details, provide documents and examples of effective auditing tools and techniques - FYI - in the "real world", I've written books, blogs and hundreds of social media posts on this, trained hundreds of people as auditors, written accredited auditor courses for ISO 9001, ISO/TS 16949, ISO/IEC 17025 and ISO/IEC 17024, as well as training on AS9100D, AS9120, and many other topics. Not blowing my own trumpet, I don't need to do that.
     
  7. Andy Nichols

    Andy Nichols Moderator Staff Member

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    As a strategy, in the interim and with your committed time line, that might be the most effective option. A day of this might cost around $2000 plus expenses. "Your mileage will vary." Check credentials, of course. References are a good way to go.

    With an external person, while they do your audits to get you to your Stage 2, your selected candidates can shadow the consultant and "see" what it's all about. Indeed someone really, really good (like me_ will tell you, "watch me, then you do one. I'll give you feedback so you can work on these things"... (I have a competency worksheet I'll share). That way, the training is "OJT" on YOUR system and your auditors won't be "deer in the headlights" when the get back from a hotel based training in SF. They know the people, skeletons, products etc.
     
  8. Golfman25

    Golfman25 Well-Known Member

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    What was your plan for internal audits? Who did your internal audits to get to your stage 1?
     
  9. Laura N.

    Laura N. Member

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    The company had a consultant that came in and did the initial set up, I was hired to basically interpret what she set up for them because after she left they still felt in the dark.
    They did a internal audit for us just before our stage 1, with Covid, that happened literally a couple days before our Stage 1.

    What was your plan for internal audits?

    The outside consultant was going to perform them until I got more experienced, then as the Management Rep, the expectation would be that I would do internal audits as well.
     
  10. Andy Nichols

    Andy Nichols Moderator Staff Member

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    I'm thinking something triggered the CB auditor into making that comment. Can you describe what the audit accomplished? Was it against a checklist of AS9100D? Or the QMS? Did the consultant have any qualifications, like CQA? If the consultant knew what they were doing, it should NOT have elicited a comment. No-one has ever questioned my competencies in this manner in more than 3 years of implementing multiple audits to a wide variety of requirements.
     
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  11. Mike S.

    Mike S. Member

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    Laura,

    I'm simply gonna tell you what several AS9100 certified companies I know of have done: Send their "lead internal auditor" to a 3-5 day class titled something like "AS9100 Internal Auditing" or "AS9100 Lead Internal Auditor" or "AS9100 Lead Auditor". Have that "lead internal auditor" person "train" and then "certify/verify competence" of other "internal auditors" within the company, and document it. Some form of evaluation or testing often accompanies the "training", especially if the internal auditors are inexperienced.

    In the real world where most of us live, working in the middle of the organization with 2 or more bosses above us, there are 2 things you need to do, and do as efficiently as possible: 1. do what you need to do to help your company, and 2. satisfy the registrar auditor so you get/keep your cert. Hopefully there is a lot of overlap there, but invariably there will be some things you do "just to satisfy the auditor". Yeah, I know to some purists that last part is heresy, but nevertheless it is real life for most of us.
     
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  12. Laura N.

    Laura N. Member

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    I went back over my notes from the Stage 1 audit, which was our documentation audit.

    from my notes - We have a written procedure for how Internal Audits are to be performed. Our Stage 1 CB auditor said that the auditor qualifications should be noted in the procedure, it should note minimum competence requirements. Then he suggested that AS9100 Internal Auditing Training was a acceptable training record.

    from my notes - we need to determine minimum competence for the internal auditor - if it is our internal audits and we are supposed to determine competency - why is he able to tell us that the specific auditor training would be sufficient?


    "Did the consultant have any qualifications, like CQA?"

    Our consultant came to the company before my hire, I understand that she was recommended to us by the CB company, I have records of her training which seems extensive to my AS9100 untrained eye, but appears to be diverse, it did not give myself or my boss reason to doubt her.
     
  13. Andy Nichols

    Andy Nichols Moderator Staff Member

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    Thanks, Laura, for posting this. As a past (global) CB Lead auditor and also CB management, I lived in this "real world" and this is precisely what your auditor should NOT do - consult. He clearly doesn't understand that training does not equal competency. It's exactly this type of thing - plus others, which have brought the whole certification industry into disrepute and those who have a laissez-faire attitude (allowing the auditors to go unchecked) don't have to pick up the pieces of organizations such as yours and who cannot afford to do "busy" work. You'd be well within your rights to ask your CB not to send that auditor back for the stage 2.
     
  14. Golfman25

    Golfman25 Well-Known Member

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    Sounds to me like he is simply suggesting that you identify the required competencies for your internal auditors. Your auditing procedure is likely a good spot for it. Since you are using a consultant who I assume has the internal audit competencies, you should be fine. When you are trained and competent, "fire" the consultant. It's really not worth a big fight.
     
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  15. Andy Nichols

    Andy Nichols Moderator Staff Member

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    Not their job, period. An Accreditation Body would sanction such commentary.
    And if they already have a process for determining competencies? Now we have 2? Why is that good? An audit procedure is for auditing, not for ensuring competency.
    How about on-going development of the system? Once the certificate is on the wall, that's it?
     
  16. Andy Nichols

    Andy Nichols Moderator Staff Member

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    For those who may be following this thread, some clarification:

    The Stage 1 Audit is to determine the state of readiness and to plan for the Stage 2 Audit - the actual implementation of the process, results etc. According to ISO/IEC 17021, it is performed to a) ensure there's a management system in place, implemented and achieving results. Auditors are required to verify that there's been customer feedback, process/product results, internal audits performed and management review. Also the required documents are present. The Stage 2 is planned. Any issues discovered during the Stage 1 which may become issues at the Stage 2, such as internal audits not performed, are reported.

    By "simply suggesting" anything, the auditor is outside the scope of the stage 1! They are to determine if audits had been done. Period. Not the effectiveness etc. That's for the Stage 2. Making suggestions, without having determined if the client has addressed competency in another process etc. throws clients into confusion. The auditor has not evaluated the process for competency at this point, yet is offering advice.

    If the client then takes this advice because they adopt the path of least resistance, and at subsequent audits, another auditor says "Why do you have two processes to determine competence? Or "Why did you include competency in the audit process, when it's not included any other process - or similar statement - what's the client to do? Despite what others may claim, this IS what happens "in the real world". It is contrary to the rules of (IAF) accreditation.
     
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  17. Golfman25

    Golfman25 Well-Known Member

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    You act like people are stupid or something. Obviously, if they have competency determined elsewhere then they can just handle it there.
     
  18. Golfman25

    Golfman25 Well-Known Member

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    God forbid an auditor gives a client a "heads up" on something to watch out for in the Stage 2 audits. If it's already taken care of then there is no problem. If not, you have a chance to fix it. Auditors aren't robots, they are people. And in most cases they are looking out for the best interests of their clients. And clients aren't stupid. They can figure out if and where they address a particular issue in their system to avoid duplication. They can also choose to ignore 100% of what the auditor says.
     
  19. Andy Nichols

    Andy Nichols Moderator Staff Member

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    Let's go with the "or something" for a moment. People who are assigned responsibility for getting the organization through the audit don't know many things about the process or the auditor. It's often the first time. For a few people, they may have 2 or maybe 3 experiences with what, 4 or 5 auditors AND possibly 3 Certification Bodies. There's a LOT they don't know of the "inside baseball" stuff which affects the outcome of the audit. Clients don't want to take contrary interpretations to their auditor since they believe their auditor should know the answers, or they fear "reprisals". What makes the auditor competent? Lead Auditor class? Ha!

    Experience shows all kinds of situations exist with auditors which are never revealed for the benefit of others to learn by.
     
    Last edited: Jun 9, 2020
  20. John C. Abnet

    John C. Abnet Well-Known Member

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    Good day all;
    I'll chime in for a bit if I may.

    In my professional experience, most organizations and the individuals within those organizations (often the "gal" or "guy" tasked with the "ISO stuff" responsibility. I'll leave that for another discussion), views the auditor as one views a medical doctor. The doctor (auditor) tells you to disrobe, and we simply obey (even if we are there because of a sore thumb), because we give them a "god like" status. @Laura N. is likely an exception to this, as made clear by her wise and well articulated post on Friday, @ 2:31 pm

    @Golfman25 is correct. The majority of the auditors I have dealt with are intelligent, cooperative, and care deeply about their chosen career and their clients.

    However, as @Andy Nichols correctly points out, that good-hearted/intelligent nature of most auditors does NOT excuse wrongly placed "suggestions" and bogus "non-conformance findings". Many of my clients have blindly followed an auditor down a foolish path because in most cases, those organizations hear the auditor "tell" them to do something and so they simply follow that "advice/direction" and add burdensome layers of meaningless/cumbersome requirements to their QMS. Often these additions result in "due dates' or "check lists" or...., which require someone in the organization to constantly feed the monster they are creating.

    The intent and scope of ISO standards are clearly laid out in the scope of each standard, with the requirements obviously following within the body of the standard. Anything more is simply wrong UNLESS it is at the need/will/in-the-benefit-of, the organization. There's a practical principle to NOT allowing auditors to extend beyond that. @Laura N. sums it up best herself when she states..."it is the legacy we leave for others".

    Hope this helps.
    Be well.
     
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