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When do I rebrief my procedures

Discussion in 'ISO 14001:2004 - Environmental Management Systems' started by Edd Scitt, Apr 18, 2016.

  1. Edd Scitt

    Edd Scitt New Member

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    Currently going through an external review audit and had a clash of heads with the auditor - they said every incremental change to a procedure needs to be communicated to the staff - I said no it doesn't - they were briefed on the first release and any major changes. If I carry out small tweaks to the procedures then they are not rebriefed. All employees have full access to the latest version.

    So question - if the process remains unchanged and I update the procedure so I have to re communicate and brief/train my staff?
     
  2. RoxaneB

    RoxaneB Moderator Staff Member

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    Minor changes such as spelling and grammar typically do not require training, in my experience. Larger, process-based changes (e.g., sequence of steps, actual activities, personnel involved) do require training.

    I would ask the auditor where it says in the standard that every procedure change requires training...but to ensure you've something solid to support your case, I'd also recommend that your own document control and training processes be updated to indicate when training is required.
     
  3. Andy Nichols

    Andy Nichols Moderator Staff Member

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    "Training" is only required when a change affects competency. Everything else is "communication". Take, for example, the ISO 9001:2015 standard. Who really needs "training" on that, when they've been working on 2008? And, who would provide that training?

    Take a look at competency and the effects. You are correct - the auditor is overstepping their bounds in making this an issue...
     
  4. RoxaneB

    RoxaneB Moderator Staff Member

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    Further to Andy's point, if the employees always have access to the latest version and the document includes a revision log/history, they'd be able to see what changed (include minor things such as typos and grammar). Consider it communicated. :)
     
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  5. tony s

    tony s Well-Known Member

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    Do you find any value for doing so? I don't think so.
    This, I find value.

    The next time you meet your auditor. ask him/her: "Where is the SHALL?" about this, and more importantly, "Where is the VALUE on this?"
     
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  6. David Graham

    David Graham Member

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    I think Andy, Tony and RoxaneB have the skinny of it, I am not conversant with the ISO 14001:2004 Environment standard but I assume they all share a common core, document control being one of those shared elements.

    In AS9100 I have personally seen two extremes of this, and a much more narrowed view point from the Transport Canada Auditors when I worked for a Helicopter company here in Calgary. Basically, AS9100, under 4.2.1 General (Documentation Requirements) has a bold note in it meaning this is an addition to the ISO standard by the AS9100 group, this states " The organization shall ensure that personnel have access to, and are aware of, relevant quality management system documentation and changes." There is that pesky shall word.

    When you take a literal view, if your procedure changes, the folks that use the procedure need to know, especially if it affects conformity of your product. Now is that training or simply notification of the change? I opted for notification as explained more in detail two (2) paragraphs below.

    When I worked for the aforementioned Helicopter company, Transport Canada was very narrow and strict with respect to document changes, any document change required documented evidence that those affected by the change where instructed about the change, this was a PVI finding against us (Major) for not having a record of the training covering the change. If you have had any experience with an aviation regulatory body you soon understand that arguing with an Aviation regulator is like arguing with a pig, sooner or latter you come to the conclusion that they enjoy it. Since they literally can shut your doors and suspend operational tickets you tend to do as they ask, which is what we did, we created the records required as part of our CAP response.

    My current employer has a Document software ERP, that tracks changes, not with change bars but through a document compare set up which compares the two documents for the reader and the changes are highlighted, those directly affected by the change had to sign off in the system as having read the newest version of the document and those that were not directly impact get a system email notification that "Blah blah" document had been changed and if you wanted to view it click on the link, but they have no obligation to do so. This seems to have passed muster with our auditor, but it by no means indicates this is correct, just that they accept what we are doing and by accepting they are indicating we have meet the spirit and intent of the standard.

    I think you need to do what you feel is best, right and proper for your situation. Probably not much help but my two cents worth anyways.
     
  7. tony s

    tony s Well-Known Member

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    I couldn't agree more.
     
  8. Andy Nichols

    Andy Nichols Moderator Staff Member

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    I'd agree, wholeheartedly, however I think that's what is commonly overlooked is that this actually means - especially to those without the experience of what the three things mean. "Best", "right" and "proper" is often a goal and initially unattainable. It might be sufficient to start with "right and proper" and work on becoming "best", because you have to learn from trying.
     
  9. Jennifer Kirley

    Jennifer Kirley Moderator Staff Member

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    I worked in semiconductor, for which process documents saw lots of changes, both temporary for experiments and permanent for the experiment's outcomes. Periodic reviews were set at one year, but even then the document owners sometimes missed revisions that should have been made...

    Overall it is about that which can affect customer satisfaction first, business considerations second and convenience third. In this sense the procedure review has always been about risk.
     

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