The Repeat Finding and the Auditor Who Audits Himself
At a components manufacturer, an internal audit in May 2023 found liquid waste drums placed in the general waste skip. The corrective action was a toolbox talk and re-signing the waste procedure by all 40 production staff. In November 2024 an external auditor raised the same finding as a minor nonconformity; the plant's response was another toolbox talk and a laminated poster above the skip. The skip stands 30 m from the production line; the licensed hazardous waste store is 200 m away and, according to operators, is regularly full by Friday afternoon. The internal audit programme is also weak: the maintenance supervisor audits maintenance, all audits are announced two weeks in advance, and three of four planned audits were completed last year. The QA manager says the repeat finding is 'a behaviour problem, so training is the right fix' and that the audit programme is fine because 'we audit everyone eventually'.
1. Evaluate the corrective action taken. What does 10.2 require, and what does the repetition tell you about the likely cause?
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10.2 requires the organisation to react to the nonconformity and, as applicable, take action to control and correct it and deal with the consequences; evaluate the need for action to eliminate the cause so that it does not recur or occur elsewhere; implement the action; review the effectiveness of the corrective action; and make changes to the EMS if necessary. It also requires retaining documented information on the nature of the nonconformity, the actions taken, and the results of the corrective action.
What happened here is a correction - re-training - presented as a corrective action. No cause was evaluated and, critically, no effectiveness review was defined. The two-year gap between identical findings is itself proof that the action did not work, which makes the absence of an effectiveness check the primary failure.
The operators' account points away from competence entirely: the hazardous store is 200 m away and fills by Friday, while the skip is 30 m away. That is a layout, capacity and logistics problem governed by 8.1 operational control, with resource implications under 7.1. Training cannot overcome a container that will not accept the drum.
A defensible response: verify the claim by observing Friday afternoon, quantify drum volumes against store capacity, then act on the system - increase collection frequency, add or relocate storage, assign named responsibility for waste transfer, and change the contractor schedule. Training remains appropriate only if a genuine competence gap is found. The effectiveness test should be physical: weekly skip inspections for at least three months, waste transfer notes reconciled against quantities generated, and a re-audit, all with a named owner and a review date.
2. Assess the internal audit programme against 9.2. Which points are actual nonconformities, and which are merely poor practice?
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9.2 requires internal audits at planned intervals to determine whether the EMS conforms to the organisation's own requirements and to the standard, and whether it is effectively implemented and maintained. An audit programme must be planned, considering the importance of the processes, changes, and the results of previous audits; audit criteria and scope must be defined for each audit; auditors must be selected and audits conducted to ensure objectivity and impartiality.
Nonconformities:
- Impartiality. The maintenance supervisor auditing maintenance is a direct breach of the requirement that auditors ensure objectivity and impartiality. He cannot raise a finding against his own area and is unlikely to have the authority to do so.
- Programme not implemented. Three of four planned audits completed means the planned programme was not delivered. The programme must be implemented, not aspirational; the reason for incompletion and its risk should have been reviewed.
- No evidence of risk-based planning. 'We audit everyone eventually' is a rotation, not a programme based on importance, change and previous results - and it is precisely why a repeat waste-handling failure was not caught.
Poor practice but not automatically a nonconformity:
- Announced audits. Forewarning is permitted and can be appropriate for document review; the problem is if every audit is announced, so normal practice is never observed. That belongs in the planning rationale, not in a finding by itself.
The underlying gap is competence and independence of auditors (7.2), and the programme's effectiveness belongs in management review input (9.3). The programme's design is the reason the audit system failed to detect a two-year-old problem - that is the systemic finding, not the poster.
3. The QA manager wants to close the nonconformity by adding a third toolbox talk. Draft the response, explaining what evidence must exist before the finding can be closed.
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The response should be written to the auditor, in the 10.2 frame, and should refuse the shortcut politely but clearly.
Containment. Immediate check of the skip and the hazardous store; any drums recovered and disposed of correctly; confirmation that no waste left the site improperly in the preceding period, checked against transfer notes.
Cause. Record the actual findings: store capacity versus peak drum generation on Fridays; distance and layout; absence of a named owner for waste transfer; contractor collection frequency. State that competence was assessed and found not to be the cause, citing operator statements and the physical evidence.
Action. Increase collection frequency and store capacity; introduce a designated accumulation area near the line that is emptied daily; assign ownership of waste transfer to a named supervisor; add a weekly skip check to the operational control schedule; revise the waste procedure accordingly.
Effectiveness. Define before implementation: three months of weekly skip inspections with zero drums, transfer notes matching quantities generated, and a follow-up audit by an independent auditor. If a single drum appears, the action is re-opened and the cause revisited.
Closure evidence. Documented information on the nature of the nonconformity, the actions taken and the results of the corrective action (10.2). A third toolbox talk plus a poster supplies none of this: it repeats an action already shown to fail and provides no test of whether the cause was removed. That argument, put in writing and signed by the plant manager, is what changes the outcome - and it is also what an external auditor will expect to see at the next visit.