Appealing already accepted corrective action.

Good Morning everyone,

Just a quickie really.
We recently had an audit to which an NCR was raised (The details of the NCR don't matter in this instance)
Now, my superior accepted the NCR & declared intent on corrective action, no questions asked.

I reviewed the audit outcomes, the NCR was utterly unnecessary and was no requirement anywhere within the standard for what it was addressing. I spoke to another auditor within their organisation who agreed, that it should of been raised as an observation.

My question is, whilst it's too late (most likely) to appeal this NCR, would there be repercussions if this were just ignored for the next surverllieance audit? Or do we have to commit to the corrective action that was documented?

As a note, my superior only declared his intent (Plan) for the corrective action, without actually implementing it yet.

Thank you for any replies & have a nice day.

 

There is no such thing as “accepting” a non-conformance. After the audit you have the opportunity to address them either thru corrective actions or appeals. You can’t ignore it as I don’t think your CB will continue your certification with non-addressed NCs. With that said I have found our CBs audit process to be a sad joke. Good luck.

 

I agree with Golfman - whether or not the NC is 'valid', you cannot just ignore it. That will DEFINITELY lead to a significant NC during the next audit.

If you feel that the NC is not justified, you can appeal it. In the meantime, be prepared for your appeal to be denied......until you are informed that your appeal has been approved/upheld, then you need to be prepared to file your corrective action.

If you assume that your appeal will be approved and it isn't, you will be running around at the last minute trying to put the CA together.

 

Thank you all for your guidance so far. The plan at this very moment is to address the NCR unless an appeal is sent.

I'd like to appeal and I've reviewed the auditing bodies terms & conditions which states, rather ordinarily, that any replies to any findings must be received within 45 days. However it doesn't state if appeals should occur within that same 45 day window, as unfortunately, the 45 day window has since closed, it's only upon my review of the findings some time later that I've questioned & raised the validity of the findings.

I absolutely want to push back against this as there are significant costs that would occur for us should we proceed with the 'corrective action.

 

My crappy CB only gave us 14 days after closing meeting to appeal. If it's really BS and you'll incur significant costs I would appeal. You'll probably loose and probably get frustrated, but the CB can't make you spend money you don't have on a made up non-conformance. If you provide details, folks on here aren't shy about telling you to appeal or not.

 

Thanks guys, I've sourced the appeal process for my manager to initiate, I just need to keep pushing, I'll post the information regarding the finding(s).

The standard in question is: BREG PN111 Factory Production Control, a British standard that supplements LPS 1175.

https://www.redbooklive.com/filelibrary/PNs/PN111-Factory-Production-Control.pdf

PN111 is freely available, no worries about copyright etc.

The findings:

Clause 4 - 15/03/23 - Minor NCR - "Welding operators are currently checking their own work. There should be supervisor sign-off or final check on Security Rated Fencing welded products."

First of all, the auditor raises this against the wrong clause, secondly, there's absolutely no requirement for secondary supervisory approval in the standard, it's also my impression that an auditor shouldn't be making suggestions like this?


Clause 4 -15/03/23 - Minor NCR "Welder m/cs that are potentially to be used for welding Security rated Fencing Jobs are not calibrated."

This one I'm not sure on, I've searched all the 'big' quality forums for answers on this and it's mostly disagreements with no one solid consensus on whether MIG welders should be calibrated. I personally wouldn't mind too much if we had to get these calibrated, but then again it's additional cost for pricey services in the UK. But on that, there's no way for our welders to verify these welds other than visual inspection. However, point a) of clause 4 seems to read, at least in my interpretation that any equipment regardless of whether the output is measurable, should be calibrated?


There's more findings however I'll start with these 2, plus it's a first thing Monday morning and I've yet to have a cup of tea

 

Thanks Andy, that confirmed my suspicions.

I also forgot to mention as you've probably already seen, this standard isn't ISO 9001, more of an "add on", having to hold ISO 9001 certification is a pre requisite to PN111, however the standards are more or less the same which makes zero sense in itself.

To address your quoted response, isn't that the case with all "Calibration" (Verification) of all items in house? We only verify measurable outputs of equipment to items that were calibrated to a national standard, UKAS in my case.

For example, If I were to verify a Vernier Caliper & found that it's out of tolerance, I can only remove it from service or repair, as with the MIG Welder, isn't the process similar? Verify the output, if it's out of tolerance then remove/repair? I'm not sure if that makes sense.

thanks for the reply!

 

Unbelievably ignorant NC (i.e. bogus as specified by @Andy Nichols .

The "cost" of sending the wrong message to your teams (not just leadership) and causing your organization to incur/manage work that may not be beneficial to your organization, is far greater than the 'cost' of appeal. Do not accept these as written.

Be well.

 

Absolutely fantastic reply Andy, Thank you! It appears yourself & others here are an absolute fountain of knowledge!
I'm aware that we could use a clamp meter, (I'm unaware as to if we already use this) which would sit much more comfortably with the definition of verification, rather than calibration. If all else fails, I suppose this is a much cheaper alternative we could implement.

I'll most likely keep this thread updated with the outcome of aforementioned appeal.

This interests me though, exactly how have you come to ascertain this information? I'm not privy to any sort of information which may be published publicly regarding their historical certifications. I don't plan on using that information in anyway, just curiosity!

 

I searched for "BRE Global" and got some hits to which it seems they have a certified acoustics testing lab which is UKAS certified. not really applicable to me but it's there I suppose.

https://bregroup.com/services/testing-certification-verification/acoustics-testing/
https://www.ukas.com/find-an-organisation/?q=BRE Global&lab

 

well I most certainly didn't know that!

Edit: Found it! Had me worried for a second.

https://www.ukas.com/wp-content/uploads/schedule_uploads/00011/04947/0007Management-Systems.pdf