Prior consultancy, a cousin at the depot, and client pressure
A certification body is planning a stage 2 ISO 45001 audit of a road transport company with three depots and 420 drivers, including dangerous goods. The lead auditor provided two days of consultancy to the company 18 months ago, helping it rewrite its incident investigation procedure. A team member's cousin is the HSE manager at the depot scheduled for day 2. The team includes a dangerous-goods technical expert who has 15 years of tanker experience but has never conducted a management system audit. During the opening meeting, the client's operations director asks that one auditor be removed because that auditor issued a major finding at another client and 'will be biased'. The audit is two weeks away. The certification body's impartiality procedure requires threats to be identified and controlled, and the audit programme must ensure competent coverage of hazardous goods activities.
1. Identify the impartiality threats and decide what actions the certification body should take before the audit.
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Impartiality threats: the lead auditor's prior consultancy is a self-review threat; the cousin relationship is a familiarity/conflict threat for that team member; the client's request to remove an auditor is an intimidation threat to the certification body's independence. The certification body should apply its impartiality procedure: disclose and record the threats, check the cooling-off period for consultancy, replace the lead auditor if the prior consultancy is within the restricted period, and remove or reassign the team member with the cousin at depot 2. The client's request should not be allowed to determine team composition, but the concern should be heard and the rationale for the team explained. If the threats cannot be controlled, the audit should be postponed or transferred. The decision and reasons should be documented before the audit.
2. Evaluate the team's competence and roles, including how the technical expert should be used.
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The team needs audit competence, not just technical knowledge. The dangerous-goods expert has valuable tanker experience but no management system audit experience; using him as an auditor without supervision would be a competence gap. He could act as a technical expert advising the team, while a competent auditor leads the audit of dangerous-goods activities. The team also needs knowledge of road transport operations, OHS law, incident investigation and the client's processes. I would check whether the lead auditor and other auditors have the required sector and audit skills, and adjust the team or audit duration. The technical expert should be briefed on audit principles, evidence and reporting, and his role should be clear to the client.
3. How should the lead auditor respond to the client's request to remove an auditor?
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The lead auditor should acknowledge the client's concern, explain that the certification body is responsible for team competence and impartiality, and that auditors cannot be removed simply because they have issued findings. The lead auditor should ask for the specific factual basis for the bias allegation. If there is a genuine conflict, it should be handled through the impartiality process; if not, the team remains. The response should be firm but not confrontational, and should be recorded. The client should be reminded that audit findings are based on evidence against criteria. If the client refuses to allow the audit, the certification body should consider whether the audit can proceed and document the consequences.