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Does the phrase "take into consideration" mandatory?

Discussion in 'ISO 9001:2015 - Quality Management Systems' started by tony s, Sep 1, 2016.

  1. tony s

    tony s Well-Known Member

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    The Management Review Inputs clause mentioned the statement: "The management review shall be planned and carried out taking into consideration..." My take on this is that - it is not mandatory that all inputs specified are to be included on management reviews.

    I based this stand on "A.3 Clarification of concepts" given by ISO 14001:2015 where it is specified that: "The word 'consider' means it is necessary to think about the topic but it can be excluded; whereas 'take into account' means it is necessary to think about the topic but it cannot be excluded.

    What's your take on this?
     
  2. Randy A. Kaczynski

    Randy A. Kaczynski Member

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    Your question is very interesting. In looking through ISO 9001:2015 I see that the phrase "shall consider" is used multiple times in other clauses. To me, that means a requirement. Therefore based on this alone, I would interpret "taking into consideration" with respect to management review as you do. However, all of the listed inputs to management review seem quite necessary to me. Which ones are you considering to exclude?
     
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  3. RoxaneB

    RoxaneB Moderator Staff Member

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    I consider it a requirement. ;) It doesn't mean that there will be anything to discuss or address, but it does mean that the item/activity listed was formerly taken into account as possible input to the process.
     
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  4. Chris Glover

    Chris Glover Active Member

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    ..and the odd thing is there is no requiremnt to keep any records of that consideration

    I can see this happening..
    Auditor: Did you take into consideration XXX
    Auditee: Yes , we did.
     
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  5. MCW8888

    MCW8888 Well-Known Member

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    That is a good question. Now that my company has embarked on the CI journey, they are not going to have a new Management Review just to satisfy ISO9001:2015. The auditor will look at their planned meetings and will ask if they have taken into consideration the review of the agenda items defined in their plan. We had this conversation during the recent upgrade. The only agenda item that was not considered was supplier corrective action. That was a minor NC.
     
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  6. RoxaneB

    RoxaneB Moderator Staff Member

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    If records are maintained for management review, there should be some form of record of that consideration, I would think. If other processes do not indicate the retention of records, your loophole is plausible, Chris.
     
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  7. Andy Nichols

    Andy Nichols Moderator Staff Member

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    We mustn't lose sight of the "context of the organization" and if, in interviewing the leadership, the top person (in a small organization) says, "Yeah, we considered it and we have nothing significant to review", then I'd say that was fine...A larger business may not get away with that. My point being that evidence isn't ALWAYS documentary.
     
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  8. MCW8888

    MCW8888 Well-Known Member

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    I think we have lost sight of the fact that every quarter, this company is reviewing the Business Plan and these are documents that are maintained as "Context of the Organization". We just call it something else.
     
  9. tony s

    tony s Well-Known Member

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    Almost, if not all, audits by CB auditors on the management review process - they didn't miss to check whether an organization had covered all the required inputs as per 2008's clause 5.6.2. I'm just a bit anxious if auditors will still find records of the management review less than acceptable if an organization "considered" to include an input in 2015's 9.3.2. The reason I posted my position.
     
  10. MCW8888

    MCW8888 Well-Known Member

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    The first thing the auditor asked was Management Review schedule and agenda items. Then he looked at the minutes. It was then easy for him to find the NC he was looking for- Review of Supplier Performance. In a way the 2015 version of Management Review is as comprehensive as the TS16949.
     
  11. Paul Simpson

    Paul Simpson Member

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    I'd go along with the general response that all elements are mandatory. My take on this is that a review of the QMS by the organisation's top management is the requirement (covered in the general piece on 9.3.1).

    For a management review to be comprehensive all of the elements in the list in 9.3.2 are to be considered.
     
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  12. luisdiaz980

    luisdiaz980 New Member

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    Based on the quoted statement "The management review shall be planned and carried out taking into consideration..." those elements shall be considered, but maybe not all of them are relevant, because of the context of the organization. Still it's possible that auditors request evidence of how those elements were considered.
     
  13. Golfman25

    Golfman25 Well-Known Member

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    Doesn't this assume you use a "schedule," "agenda," and "minutes?" Aren't there other ways?
     
  14. MCW8888

    MCW8888 Well-Known Member

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    The is the best way for us to demonstrate objective evidence. These 3 elements are common to both old and new ISO9001 standards. There's one thing: Management Review does not have to be a formal meeting. We just needed to show the records that the required agenda are covered.
     
  15. Andy Nichols

    Andy Nichols Moderator Staff Member

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    I'm not sure I agree with this MCW8888 - the context really doesn't change much -maybe over 3 - 5 years, but rarely more frequently and, therefore, reviews more frequently are unnecessary. The primary "idea" of this requirement is to provide a "kick off" point for the whole QMS. ISO 9001 has gone from being something pushed onto an organization by a customer, to be a voluntary set of requirements, often leading to certification. The previous standard didn't have a starting point which was a problem for those new to implementation. It's an anchor for things like the quality policy and in turn, the objectives, risk considerations and so on. On that basis, you're not going to go back to the start to see if it's moved!
     
  16. tony s

    tony s Well-Known Member

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    Erratum on my previous post.
     
  17. MCW8888

    MCW8888 Well-Known Member

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    Andy, I appreciate your feedback. In 2008 Management Review was scheduled quarterly to cover all the agenda items specified by the standard as well as our own business plans. Graphs and charts are presented during these reviews. Action plans are assigned and followed up. In 2015 the needs of internal and external customers, risk and opportunities are considered. The most important in the minutes are the outputs Our CB surveillance audit is once a year. So we need to make sure that the outputs are analyzed for its risks; action plans are implemented and followed up. The first time we had an NC on Management Review is during our upgrade to 2015. It was associated with missing review of supplier performance.
     
  18. tony s

    tony s Well-Known Member

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    This is what I'm worried about. The standard says "management review shall be planned and carried out TAKING INTO CONSIDERATION...". What if the review of supplier performance was done outside of the typical setup for a management review (i.e. meeting). Just because it was not included in the minutes, auditors will take it as an NC against 9.3.2c.7? I would rather raise the issue of "missing review of supplier performance" against clause 9.1.3f or 9.1.1 last paragraph.
     
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  19. MCW8888

    MCW8888 Well-Known Member

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    That's exactly what I was telling everyone prior to the upgrade. We do not need to create a separate agenda of supplier performance to satisfy the requirements of ISO9001:2015. We just needed to reference the results of those supplier performance conducted quarterly by logistics. It did not happen so the result was a minor finding. We have so many business meetings that could be considered as agenda items for Management Review but the minutes need to be improved and organized.
     
  20. MCW8888

    MCW8888 Well-Known Member

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    That's exactly what I was telling everyone prior to the upgrade. We do not need to create a separate agenda of supplier performance to satisfy the requirements of ISO9001:2015. We just needed to reference the results of those supplier performance conducted quarterly by logistics. It did not happen so the result was a minor finding. We have so many business meetings that could be considered as agenda items for Management Review but the minutes need to be improved and organized.
     

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