The client asks for the auditor who used to run their QMS

Threats present

• Self-review: the recertification covers exactly the areas Ms. Rahman owned - internal audit, management review, document control. She would be evaluating decisions and records she produced less than two years ago.
• Familiarity and self-interest: six years of colleague relationships; her future contract work depends on client satisfaction.
• Intimidation (commercial): the tender hint pressures you to accommodate the request.

Decision She cannot be a team member on this audit. The governing principle is that no one audits their own work, and the certification body must analyse and document impartiality threats before accepting an assignment. A cooling-off period of about two years is the usual, defensible safeguard - her 16 months falls inside it, and her former role covered the whole management system rather than a narrow technical area, so restricting her scope would not remove the self-review threat.

What to do instead Appoint the other lead auditor; close the technical gap with a technical expert (packaging hygiene, food-contact materials), who advises but does not audit or report, or a technical reviewer at file review. Technical experts carry the same impartiality obligations, so choose someone with no link to the client. Do not let the commercial pressure change the analysis - record it as context, not as a factor.

To the client (no confidential detail): explain that assignment decisions follow the certification body's impartiality rules, that auditors are not assigned to audits of management systems they previously managed, and that this applies to all clients equally. Offer the compensating competence: a lead auditor with strong manufacturing background plus a packaging technical expert, and a technical reviewer at the end. Confirm the audit dates are unaffected. Avoid explaining why in terms of Ms. Rahman's personal history - say only what the rules require.

In the audit file:

1. The impartiality analysis: threats identified, the cooling-off rule applied, the outcome, the date and the name of the person who approved it.
2. The client's request and the tender remark, noted as commercial pressure that was considered and rejected.
3. The technical-expert justification (why the competence gap existed and how it was filled) and the expert's signed confidentiality/impartiality declaration.
4. The client communication record.

This matters at the next accreditation assessment: the decision is defensible only if the reasoning is written down before the audit, not reconstructed after a complaint.

Partly, at best.

• Technical experts are subject to the same impartiality requirements as auditors, so the threat does not disappear by changing the label.
• The decisive question is influence: an expert who steers the team's conclusions on the management system she built is still reviewing her own work. Her former role was QMS-wide, which makes a genuinely narrow technical contribution hard to guarantee.
• A defensible arrangement would require: a written role definition limiting her to technical advice on hygiene and food-contact requirements; a prohibition on evaluating conformity in areas she managed; findings validated and owned by the lead auditor; and documented justification. Even then, many certification bodies would simply not permit it inside the cooling-off period.

Judgement: the cleanest and most defensible answer is to keep her off this client for the remainder of the cooling-off period. If you do allow a limited expert role, the burden is on you to show in the file why the residual threat was acceptable - and the client's insistence makes that harder, not easier, to justify.