Volume 6 · Issue 9 · September 2001
US Balloting Supports Auditor Competency Concerns
US to Vote "No With Comments" on ISO/DIS 19011
On August 31, 2001, balloting and comment on
the Draft International Standard (DIS) of ISO 19011, Guidelines
on quality and/or environmental management system auditing,
concluded in the United States with a two-thirds majority
voting to "disapprove with comments".
Plans are for the US comments to be reviewed and collated
and for a formal US position to be developed at a September
25-26, 2001, meeting of the US Environmental Auditing/Quality
Auditing Liaison Group at the Hilton-Tysons Corner Hotel in
McLean, VA, near Washington Dulles International Airport.
In a separate development, the Registrar Accreditation Board
(RAB) is considering the development of Integrated Management
System (IMS) Auditor Certification to respond to the final
acceptance of ISO 19011.
Within the US Technical Advisory Groups (TAGs) to ISO Technical
Committees (TCs) 176 and 207, responsible for the quality
management system (QMS) and environmental management system
(EMS) standards, members of the SubTAGs responsible for quality
and environmental auditing standards respectively were eligible
to submit votes and comments on ISO/DIS 19011.
A total of 97 members of the US SubTAGs and liaison groups
cast ballots, with 23 (23.7%) voting in favor of the DIS,
65 (67.0%) voting to disapprove and 9 (9.3%) abstaining. A
total of 35 pages containing approximately 275 individual
comments on the DIS were submitted by 18 members.
"The 35 pages does not include the majority of voters
who simply indicated in returning their ballots, I agree
with John and Gary," commented Erin Hogg, ASQ Standards
Group Coordinator. The reference is to the position paper
developed by John H. Stratton, a member of the US TAG to TC
176 and its Task Group (TG) 19011 and a lead US delegate to
the Joint Working Group on Quality and Environmental Auditing
(JWG), and Gary L. Johnson, Environmental Engineer at the
US Environmental Protection Agency (EPA), a representative
of the US TAG to TC 207 and a US delegate to the JWG.
This review and collating meeting was originally scheduled
to take place at the Reagan Building in Washington, DC, September
11-12 to permit consideration and approval of a formal US
position at meetings of the US TAGs to TCs. "Although
the EA/QA Liaison Group members arrived at the Reagan Building
on Tuesday to hold their meeting, the unfortunate events that
morning resulted in the facility being closed and our meeting
was cancelled," remarked Bud Smith, Chair of US SubTAG
2 to TC 207 and a member of the Liaison Group. Subsequent
cancellation of the full TAG meetings resulted in a decision
for the Liaison Group to meet in McLean, VA, on September
25-26, 2001, to develop a US position and prepare the US vote
and comments by the October 31 deadline (see "US TAG
Meetings Cut Back" on page 2 for details on the cancellations).
Concerns With Auditor Competency and Third-Party Bias
The US ballot results were in support of a negative vote
and, according to initial reports on the comments submitted,
raised the concern stated by the US leadership in calling
for a vote of disapproval in the June 15, 2001, position paper:
The principal reason for this vote is to
support the removal of references to recommended or suggested
levels of auditor experience for any specific auditing situation.
Inclusion of such recommended levels of experience is inconsistent
with the stated goals of the standard and may create considerable
confusion among users.
"The DIS must be recognized as an improvement over what
we have presently in terms of environmental and quality auditing
guidelines, but it is still not where it needs to be,"
emphasized Johnson. In a presentation at the Environmental
Innovations Summit 2001 in Pentagon City, VA, on September
10, Johnson reiterated two issues behind for the US vote of
1. Inclusion of specific criteria for auditor experience
and training in Table 1
Although Table 1, Illustration of Indicators of Education,
Work Experience, Auditor Training and Audit Experience, which
is reprinted on the next page, is referred to as an "illustration"
of auditor criteria in its title and referred to elsewhere
as an example, the inference in most places in Section 7,
Competence of Auditors, and the wording in certain passages
give the reader the impression that Table 1 represents an
expected level of minimum competency. Subclause 7.6.4,
Setting the Indicators of Education, Work Experience, Auditor
Training and Audit Experience, includes the following statement:
Table 1 illustrates indicators
can be applied by organizations conducting internal or external
. For auditors conducting certification audits
or audits of similar complexity these should be the minimum
"The problem with Table 1 is that the numbers included
for auditor competency levels do not agree with the NAP criteria,"
explained Johnson in reference to the US National Accreditation
Program (NAP), which accredits QMS and EMS registrars and
is jointly run by the American National Standards Institute
(ANSI) and RAB. "Some Table 1 criteria are higher than
the NAPsand Subclause 7.6.4 considers this illustration
the minimum competency for a registrar auditor."
2. Section 7 is biased toward third-party (registration)
Despite improvements to the guidelines due to reworking of
Section 7 when the JWG revised Committee Draft (CD) 2 and
elevated it to DIS status in late March 2001, the language
in many instances continues to address auditor competency
and audit planning to suit the purposes of conducting a third-party
For example, Figure 6 from the DIS, which is reprinted on
the next page, discusses the initial evaluation process for
the internal audit program and seems to indicate that internal
auditor evaluation guidance is provided.
However, Figure 6 does not provide guidelines for auditor
competency in a fashion similar to Table 1 and it cites Table
3, Example of a Structure for Auditor Evaluation in an Internal
Audit Programme. Table 3 may be helpful to the internal audit
program manager in determining what is required for a program
to be established, but it offers little guidance on how to
conduct an internal audit or on internal auditor competency.
Future of Auditor Competency and IMS Certifications
The participating member bodies (P-members) of Subcommittee
(SC) 2, Environmental Auditing and Related Environmental Investigations,
of TC 207 and of SC 3, Supporting Technologies, of TC 176
have until October 31, 2001, to submit their ballots and comments.
Although the US SubTAGs to these TC 207 and TC 176 SCs could
have extended balloting beyond August 31, they concluded balloting
early to permit the US delegates to the JWG to work with the
SubTAGs at the meetings that were scheduled to take place
September 24-27 in Crystal City, VA. Instead, the Liaison
Group, which consists of approximately 10 members of the SubTAGs,
will rely on the balloting and comment results alone in formalizing
the US vote and comments.
Johnson noted that, if the JWG does not address the US concernsparticularly
those with Table 1the NAP and many other members of
the International Accreditation Forum (IAF) may have difficulty
reconciling their existing registrar accreditation criteria
with the "illustrations" in Table 1. Joseph Dunbeck,
CEO of RAB, also presented at the Environmental Innovations
Summit and indicated that RAB as administrator of the NAP
will not be making any decisions until ISO 19011 is finalized.
"The IAF submitted a set of comments on the DIS that
reflect our concerns with Table 1," noted Dunbeck. "It
is RABs expectation that modifications will be made
in response to the comments from many P-members and liaisons,
and that everything will be worked out."
Dunbeck also acknowledged that RAB is looking into the possibility
of offering IMS auditor certifications. At present, RAB offer
four levels of auditor certification each for QMS and EMS
auditorsinternal auditor, provisional auditor, auditor
and lead auditorbut not a single combined or IMS certificate
for those levels. "Some auditors are separately certified
by RAB to audit both quality and environmental management
systems, and many others are competent to do both types of
audits but only choose to maintain one certification,"
acknowledged Dunbeck, in response to a question at his presentation.
"We recognize that obtaining and maintaining two certifications
involves the expense of separate courses, exams and application
feesand additional paperworkso we are examining
how an IMS program could be established to allow a qualified
environmental and quality auditor to get one certification
for both, an IMS certification program. However, it will likely
be about 18 months before such a program is in place, and
there will probably be no details available until after ISO
19011 is finalized."
THE OUTLOOK will provide reports on the
Liaison Group meeting and progress on ISO 19011 in coming
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