Scope, Sample and Deadline Pressure
You are lead auditor planning a stage 2 certification audit for Kestrel Build, a contractor with a head office, two directly managed projects and one joint-venture project where the JV partner holds the principal contractor duty. The client's proposed scope reads: 'Construction of commercial buildings in the northern region'. Certification is promised within six weeks because the firm is bidding for a framework. Your team is you (construction OHS background, 12 ISO 45001 audits), a chartered civil engineer with 20 years of site experience but no auditor training and no previous management-system audits, and a technical expert on plant. The client asks for two sites to be sampled out because they are at fit-out stage only. Planned duration: three days in total, two auditors.
1. Assess the proposed scope statement and the requested exclusions. What must you establish before accepting the scope?
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Clause 4.3 sets the test. The scope must be available as documented information, must state the activities, products and services covered, must be credible given the issues in 4.1 and the interested-party requirements in 4.2, must take account of the compliance obligations in 6.1.3, and may not be used to exclude activities, products, services or workers within the organization's control or influence that can impact OH&S.
- 'Construction of commercial buildings in the northern region' is imprecise. It does not state that the organization works as a contractor, does not identify the work-related activities (site establishment, groundwork, structural, fit-out, demolition?), and says nothing about who performs the work (own workers, agency, subcontractors) - which matters because 8.1.4 applies.
- The joint venture is the critical question, not a footnote. If Kestrel's workers perform work on that site, the site is within its control or influence regardless of who holds the principal contractor duty; excluding it would be an impermissible scope exclusion. Establish the JV agreement, the legal duties, and who directs the work, then define the boundary explicitly in the scope statement.
- The fit-out exclusion confuses scope with sampling. Fit-out is a performed work-related activity with its own hazards; the client cannot delete it from the scope. Whether those sites are visited is an audit sampling decision - a different question, decided by you, on risk.
Do not accept the scope statement as drafted. Return it with the gaps identified and require a revised documented scope before stage 2.
2. Is your audit team competent for this audit, and how do you handle the civil engineer?
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Competence is a combination of education, training, experience and audit attributes, and it must cover the standard, the audit techniques and the sector. The engineer has strong sector and technical knowledge but no auditor training and no audit experience, so the team as constructed has one auditor plus two technical resources.
Options, in order of preference:
- Engage him as a technical expert under ISO 19011. He can advise on construction methods, plant, temporary works and legal duties, and can accompany an auditor, but he must not audit alone, cannot count towards audit duration as an auditor, and must work under the direction of the audit team. Brief him on the audit criteria, the confidentiality and impartiality requirements, and what he may and may not say to auditees.
- Add a second competent auditor - which changes the duration arithmetic and must go through the programme manager, not be absorbed silently.
- Delay if neither is possible. A stage 2 with one auditor across a head office, two projects and a JV is not credible.
Also check sector-specific competence for the JV and for plant: who on the team can evaluate legal compliance (9.1.2) for lifting operations and work at height? If nobody can, that is a resource gap to solve before the audit, not during it.
3. How do you deal with the six-week deadline and a three-day, two-auditor duration?
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Duration is not a negotiating position; it is derived from documented criteria - the size and complexity of the organization, the scope, the number and nature of sites, the significance of risks, the maturity of the system and the results of previous audits. The calculation must be traceable, and any reduction must be justified on those grounds and recorded, not on the client's commercial deadline.
- Three auditor-days for a head office plus three construction projects including a JV is very unlikely to be adequate. Assess it against your CB's documented procedure, record the basis, and propose a realistic duration with a cost and schedule consequence. If the client will not accept it, the programme manager decides, not the lead auditor under pressure.
- Sequence matters. Stage 1 must be completed and its findings resolved before stage 2 is planned; a six-week promise is only achievable if stage 1 is already done and shows readiness. If stage 1 identifies that the JV and subcontractor controls are not yet in place, stage 2 moves.
- Keep the pressure visible: document the client's request, your assessment, and the outcome. A duration cut to win a framework bid is exactly the situation impartiality controls exist for, and the record protects both you and the certification body.