Auditing Non-Documented Procedures


I don’t normally do requests, but for Cheryl Gallagher, I will make an exception

Can you audit a process if it is not supported by documented procedures?

This is a question I ask at an early stage in all my IRCA auditor courses. It always gets the same response. A few shrugs. One or two firm “no’s” and an occasional “Erm … yes?” The question I ask proves only one thing. It is a concept that few are totally comfortable with. The session moves on. I suggest that it is possible to audit in the absence of procedures, at which point the guys who had previously given me the firm “No!” generally retort along the lines of “You’re a mad man. It cannot be done!” Or something. They invariably fall right into my trap

“Why do you think you can’t audit in the absence of procedures?” I ask.

“Well, without procedures you can’t tell what they are supposed to be doing” they often respond
“Why can’t you ask them?” I respond
“Because they could tell you anything” they generally reply
“So could their procedure …”

At this point I can almost smell victory. But the argument usually has one last hurrah along the lines of …

“How can the auditor decide whether they are doing the right things though?”
“Well, there are standards, specifications, orders, contracts … the auditor could check those”

At this point we start to see that the procedure is not the be all and end all that we conveniently pretend that it is. Often they are little more than a cover, a smoke screen or a diversion. The critical thing for the auditor is to check the required standards are being met (contract, order, standard etc) and verify that they are through the records and testimonies that are available. Procedures may help along the way, let us not suggest that they are all worthless, but they are not always that significant in the mix

If I was to be granted one wish with regard to QMS auditing and how it may improve, it would be for the discipline to be blessed with a greater degree of intelligence and consideration. Auditing by numbers just does not work, and an auditor that needs such a comfort, really needs to try another profession. It is said that we humans utilise no more than 10% of our brains at a time. For many QMS auditors I have met, the figure is considerably less

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