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Volume 6 · Issue 9 · September 2001

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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 disapproval.

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…that can be applied by organizations conducting internal or external audits…. For auditors conducting certification audits or audits of similar complexity these should be the minimum indicators.

"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 NAP’s–and Subclause 7.6.4 considers this ‘illustration’ the minimum competency for a registrar auditor."

2. Section 7 is biased toward third-party (registration) auditing

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 registration assessment.

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 concerns–particularly those with Table 1–the 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 RAB’s 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 auditors–internal auditor, provisional auditor, auditor and lead auditor–but 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 fees–and additional paperwork–so 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 issues.

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