Three overdue gauges and 45 minutes left
During a 2-day internal audit of a medical-device component plant you are auditing calibration control. The gauge register lists 412 instruments. With 45 minutes left before the closing meeting, you sort the spreadsheet by instrument ID and test the first 20: three are overdue for calibration - by 11, 26 and 40 days. All three sit in the same production cell and were last calibrated by the same external laboratory, whose accreditation scope was reduced four months ago. The maintenance supervisor says: "When we're busy we slip a bit; everyone knows. Nothing has ever failed a check because of it." You have found no product nonconformity and no customer complaint related to measurement. This process has not been audited for two years.
1. What can you legitimately conclude from these 20 records, and what can you not? How do you close the gap before the closing meeting?
Read the worked answer
What the sample supports 3 of 20 (15%) in the sample are overdue. That is enough to establish that the control is not operating as intended - a nonconformity exists. It is not enough to say "15% of 412 gauges are overdue" or to conclude anything about the population.
Why the sample is weak Sorting by instrument ID and taking the first 20 is not a random sample. IDs usually correlate with asset type, purchase year or cell, so those 20 may over- or under-represent the risk. Two things were lucky and must not be mistaken for method: all three failures landed in one cell and with one laboratory.
What to do in the remaining time
- Draw a small stratified sample: about 15 instruments split across cells and weighted towards gauges used for product acceptance and final inspection.
- Test the consequence, not just the date: were the overdue gauges used to accept product since they expired? Pull the inspection records.
- Check the lab's reduced scope against the instruments it calibrated - if it calibrated gauges outside its remaining scope, the calibration itself may be invalid, which is a product-risk issue, not a paperwork issue.
- Ask what detects an overdue gauge before use. The supervisor's remark suggests the answer may be "nothing", which changes the finding's severity.
If time runs out: report what the evidence supports, state explicitly that only 20 of 412 were examined, and flag the population question as requiring follow-up - do not paper over it with a percentage.
2. Minor or major nonconformity? Lay out the reasoning.
Read the worked answer
Classification turns on system failure, not on the count of bad records. Twenty wrong records can be minor; one missing control can be major.
Pushing towards minor
- A register, an external calibration provider and a defined interval exist; the process is designed.
- No product impact identified so far.
- A small, localised lapse is a candidate for correction plus corrective action.
Pushing towards major
- "When we're busy we slip a bit; everyone knows" describes a known and accepted deviation, not a lapse. If true, the process has no effective detection or prevention and the system is failing systematically.
- Medical-device context: measurement traceability feeds conformity decisions and is subject to regulatory expectations, so the consequence of failure is high.
- The failed instruments cluster by cell and by laboratory, which suggests more than random slippage.
- Two-year audit interval means this would have gone undetected by the audit programme.
How to decide Resolve the two open questions - is there a control that blocks use of an overdue gauge, and did expired gauges influence product acceptance? If no blocking control and/or product was accepted using them, raise it as major and say why. If there is a functioning pre-use check and the lapses are recent, minor is defensible. Write the rationale in the report either way; an unexplained classification invites dispute.
3. The auditee asks you to recommend a software tool that blocks use of overdue gauges. What do you do?
Read the worked answer
Decline, and say why. As an internal auditor you may identify that a control is missing - that is a finding. Designing or selecting the fix moves you into implementing the process you will later audit, which destroys the independence the audit function depends on.
What to do instead
- Write the finding against the requirement and the evidence; leave the how to the process owner.
- If asked for ideas, keep them clearly outside the finding: an observation or opportunity for improvement, labelled as advisory, non-binding, and not something you will later verify as "your" solution.
- It is legitimate to ask the auditee to demonstrate that whatever they choose actually prevents use of an overdue gauge - that is testing effectiveness, not consulting.
Also flag the systemic point in the closing meeting: the auditee's real question implies their current detection relies on a person noticing a date. Whether they buy software or change the interval is their decision, but the corrective action must address why the deviation became normal practice, not just the three gauges.