December 2010 - Don’t let auditors cross the lines!

We already have written papers either about Bill Mooz(1), Met-L-Chek, or different Penetrant Professor issues, a monthly newsletter about Penetrant Testing. Penetrant Professor may be downloaded from the MLC website(2).

The November 2010 Penetrant Professor issue details two examples of how some auditors may go beyond their duty, and may be prone to “interpret” or even “invent” requirements. This is a worry for auditees, who, quite often, do not know that also they are allowed to ask questions.

First example: ‘‘In-used’’/‘‘Reused’’ penetrant’’

Penetrant that is in tanks and used in production must have periodic checks to assure that it is still functioning as it should. ASTM E1417(3) describes these tests and requires them to be conform on ‘‘in-use’’ penetrant.

We think that this describes what should be done adequately, and our certifications describe the penetrant ‘‘in-use’’ in accordance with ASTM E1417.

However, we had one customer who was audited and told that the penetrant should be described as ‘‘reused’’.

This will go into our records of things that we just do not understand.’’

Second example: emulsification time--again

‘‘After our discussion about the emulsification time, we received the following comment from a reader:

- ‘‘I read you October Issue and I would like to add another twist to your story. We were just audited and the auditor brought up the same question of how was determined our emulsification time. He would not accept the ASTM recommended way and wants us to do various tests to prove that our time is acceptable.

In addition he asked how we know that our emulsification time is still valid after the emulsifier has been in use for several months and to provide proof by doing several tests that he does not say how he wants it done.’’

We have several questions about what apparently is going on with regard to this subject.

It seems to us that the auditor or auditors in question are crossing the line between auditing and either inventing or implying tests or conditions that are not part of any written specification.

In principle they may be correct in wanting an answer to their question about how the emulsification time was determined, but if this is not addressed in the relevant specification, it would seem that it is improper for them to require an answer.

But even so, if they insist that the person under audit supply evidence of the determination process, to our knowledge there is no procedure for doing so. And, if it is the case, one wonders how the auditor would know whether it was proper or not.

We suppose that the method would simply have to satisfy the auditor, putting him or her in the position of developing a specification without the review of approval of any of the organizations charged with this task and responsibility, such as ASTM or similar bodies.

This paper made some readers write their feelings:

- From a NADCAP auditor: ‘‘Just want to add my voice to the article stating "auditors should not be inventing requirements". When writing a non-conformance, or a non-compliance, the auditor should be able to cite the document, and the requirement, being violated. If not, there is no finding.’’

- Penetrant Professor’s answer: ‘‘we are not familiar with the sequence of the audit and the findings of non compliance, but from the anguish that we hear, it seems like the auditor is insisting on compliance with the invented requirement before he writes anything up. Clearly this seems to be a subject worth clarifying and pursuing on your end. But with your permission, we will use your answer to us in a future issue. Perhaps if a person under audit has that issue with your words on it, it may help if an auditor begins to get ‘‘inventive’’ ’’.

- The NADCAP auditor answered: No problem. ‘’This is the message we preach to all the auditors, and to the suppliers in the open meetings …”

- From another auditor: (document edited) ‘‘Very good articles this month. I really, really enjoyed it and had some good laughs.  Thank you. It seems like more and more, we are revising the ASTM and AMS spec's to satisfy auditors or to keep them from writing up suppliers. Maybe it is time we cancel all of these specs and then they would not have anything to write someone up for. Although an auditor organization may have its own take on requirements and is even generating its own requirements that are not even industry norms, plus, the way auditors work, I am sure that they would come up with something or find something to write suppliers up against. GREAT JOB!!!!!!!!!!!!!!’’

- From a consultant: ‘‘Hey Professor! Well said without preaching! Every wonder who in the heck these Auditors are and where they got their training to be NDT Auditors? They have no clue based on the feedback received.’’

Our own opinion is that auditors should stick to the relevant specifications, where the person under audit is aware of the requirements and prepared to answer questions related to them.

The auditor should not be allowed to invent questions that cannot be answered from the specifications, and the auditor has no business imposing criteria or procedures that are not in the specification.

If the auditor has strong feelings about the failings of a specification, he or she should volunteer to join AMS Committee K(4) or ASTM Committee E-07(5) or whatever other organization is the proper one to develop and maintain the procedures by which inspectors operate. Blindsiding a person under audit serves no useful purpose and expense for the auditee.

Of course we are happy to see that auditors, as a general matter, agree that it is not their duty to ask auditees for things not specifically required in the applicable documents. We could add that being an active member of standardization committees is on a voluntary basis; it costs money, is time-consuming, even if only travel expenses/time are considered. This is not a for-profit business for the participants themselves, even if one may be in the opinion that primes as well as small- and medium-size companies find then some opportunities to “lobby” for some of their own techniques/processes.

Auditing is a very lucrative business for auditing companies, and is quite expensive for audited companies.

The more auditors "invent" new questions not written in the applicable specification, the more means they have to issue non-conformance reports (NCR), the more they multiply audits, hence significant additional revenues for auditors and audits bodies.

Auditees must have in mind that, if they are requested to show records of some process not written in the applicable document, they can, and they must, ask the question: “please, show me the paragraph in which this is required”.

Further, after an audit, an auditee may report to the auditing body if he or she thinks that the auditor has been “unfair” during the audit.

One of us, who attended the NADCAP meeting held in DYSNEYLAND PARIS, some years ago, remembers also Phil KEOWN saying that auditors have to know some of the habits of the country which they are welcomed in: he specifically reminded the audience (about 100 people!) that, in France for instance, an auditor should not be surprised to be invited for 3 hours in a row in a very good restaurant. This is NOT to prevent the auditor to perform his (her) job; it is the way VIP visitors are shown … they are VIPs!

So, don’t let auditors cross the line!

References

(1) Patrick DUBOSC and Pierre CHEMIN, An American in Paris ... who likes Paris when at its best in May, Editorial June 2010, on our Website:
http://www.ressuage-magnetoscopie-penetranttesting-magnetictesting-dpc

(2) Penetrant Professor, on the Website:
http://www.met-l-chek.com/pages/penetrant_professorpag.html

(3) ASTM, E1417 - 05e1: Standard Practice for Liquid Penetrant Testing, American Society for Testing and Materials, West Conshohocken, Pennsylvania, 2005.

(4)AMS K (Non Destructive Methods and Processes) Committee of the Society of Automotive Engineers (SAE).

(5) ASTM Committee E07 on Nondestructive Testing of the American Society for Testing and Materials (ASTM).