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7.2 and 9.1.3

Discussion in 'ISO 9001:2015 - Quality Management Systems' started by Niko90, May 8, 2019.

  1. Niko90

    Niko90 Member

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    Hello everyone! About a month ago, we had our surveillance audit and some minor NCs. I would like to hear your thoughts on two of those. The first one is against 7.2 Competence. During the audit, our colleagues were not able to present any evidence that a few identified interventions for competency needs were provided/implemented. However, the same auditor raised another NC against 9.1.3 citing that we had no evidence able to evaluate if the identified competency needs were addressed. This auditor was also citing the same samples from the first NC and a few more examples. To some extent, I am fine with the first one. We had lapses. We have to address it. Although, I feel like the second NC was simply a consequence of the first one.

    TL;DR: I don't think the NC against 9.1.3 is necessary (and is a bit redundant) because the fact that we did not meet the requirement for evaluating the effectiveness of actions taken was already pointed out in our NC against 7.2.

    P.S.
    Imagine responding to two separate Corrective Action Requests with basically the same thought. :confused:
     
  2. Andy Nichols

    Andy Nichols Moderator Staff Member

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    Appeal it with your CB management. Section 9 is nothing to do with competency. It's about product and process.
     
    Last edited: May 8, 2019
  3. Qualmx

    Qualmx Well-Known Member

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    Andy, why don't write down both, If both apply? The first one is absence of evidences, and second one is about monitoring, measurements , analysis and evaluating.
     
  4. Andy Nichols

    Andy Nichols Moderator Staff Member

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    See my edited comments above. The auditor is writing up competency and they clearly aren't yet competent in the standard they audit to.
     
  5. tony s

    tony s Well-Known Member

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    If necessary interventions were determined but not provided, the auditor is correct to raise this issue against 7.2 - particularly on "c) where applicable, take actions to acquire the necessary competence".
    Evaluation on whether the identified competency needs were addressed can only be done after actions are taken. Since the necessary interventions were not provided as per the first NC, then there's nothing to be evaluated.

    Analysis and evaluation in Clause 9.1.3 is intended for data and information from the results of monitoring and measurement in order to determine if processes, products and services meet requirements (see ISO/TS 9002 clause 9.1.3). Evaluation on whether the competency need was addressed by the intervention provided is a requirement of 7.2c - particularly "evaluate the effectiveness of the actions taken". There is no issue here against 9.1.3.
     
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  6. Qualmx

    Qualmx Well-Known Member

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    Tony s
    Don´t you think is worth it to raise also an NC in 9.1.3 ?
    The focus in an audit is to detect non compliments on clauses and in this case both clauses apply.
    was not detected competency evidences nor analysis and evaluation.
    Imagine an audit to a whole system and you say, resulted only one nc in 7.2
    and the boss may say ah ok, just one, no problem, but if you mention also 9.1.3 and maybe other clause
    which for sure will be in uncompliment for not comply with 7.2
    The boss or employees may think very different, what do you think?

    Thanks
     
  7. Andy Nichols

    Andy Nichols Moderator Staff Member

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    Please be careful to cite some CB practices as "most likely". This is inaccurate and misleading.
     
  8. Jennifer Kirley

    Jennifer Kirley Moderator Staff Member

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    If section 9 would apply, 9.1.1 would be the clause to use based on ISO/TS 9002:2016:
    While I agree the first step is to identify competency needs, it is also important to notice when gaps occur. Niko90 cites "first NC and a few more examples" listed as objective evidence for the second nc, but does not tell us what the other examples were. If it was only about 7.2, I would agree that the nc for 9.1.3 should be disputed. However, even with just that I have seen failure in maintaining required training schedules, in part due to lack of oversight (also lack of a target/goal for it that would have identified the overdue training for management review). I would like to know what those other examples were.
     
  9. tony s

    tony s Well-Known Member

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    No need. NC1 is valid. Needed interventions were not provided. If the interventions were provided, these should be evaluated for effectiveness. Since the auditor cited the same set of evidences sampled for NC1, where interventions were not provided, then there's no opportunity for Niko's organization to evaluate the effectiveness. Evaluation of effectiveness is a requirement of 7.2c and not 9.1.3. Clause 9.1.3 is intended for data and information from the results of monitoring and measurement in order to determine if processes, products and services meet requirements and not as intended by 7.2c.
    It is never the intention of the standard to identify nonconformities against the clauses. If this is the perspective of auditors, then they are always on a witch-hunt. Looking for negatives. Auditors should be positive thinkers. They evaluate objectively to determine the extent of fulfillment of the audit criteria - not extent of non-fulfillment. The audit evidences sampled by the auditor here can only be evaluated objectively against 7.2c and not 9.1.3.

    The clauses of the standard are interrelated. If you think 9.1.3 is related, then why can't we also call the issue against the other related clauses such as 9.1.1, 4.4.1c, 4.4.1d, 5.1.1e, etc. Auditors, especially CB auditors, should be specific. They should observe what is specifically written on their governing standard. ISO/IEC 17021-1:2015 specifically stated in clause 9.4.5 this: "A finding of nonconformity shall be recorded against a specific requirement, and shall contain a clear statement of the nonconformity, identifying in detail the objective evidence on which the nonconformity is based".
     
    Last edited: May 13, 2019
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