Tampa FL — The International Accreditation Forum has responded to an initial request by Oxebridge Quality Resources on the issue of AS9100 CB auditors requesting clients to complete PEAR and other audit forms prior to the audit, ruling that the practice is acceptable.

In response to a request for information on how to formally present the question to IAF, Mr. Norbert Borzek issued a preliminary response:

I can confirm that we do not see a problem, if the organization knowing it’s processes very well is filling in the requested audit forms provided that the auditor / audit team is verifying what is stated in the forms by the organization. Objective evidence for the verification shall be provided by the auditor / audit team.

As there are still auditors not using such a  support of organizations there is no official procedure on such an approach.

I know that similar approaches are common practice also in other accreditation / certification schemes.

Oxebridge’s VP Operations Christopher Paris, who was preparing the request on behalf of industry stakeholders, said that given Mr. Borzek’s response, “there’s no point in pursuing this further with a more formal request. They’ve already ruled.”

The ruling is consistent with responses from the AAQG, IAQG, ANAB, training organization Plexus International and multiple registrars.

Mr. Paris has issued the following response.

AS9101D clearly defines the PEAR and other forms as audit evidence. This is not in dispute.

Therefore, what the IAF is endorsing is a practice whereby auditors may request a client to complete evidence prior to an audit, and then have a CB auditor merely “verify” this evidence afterwards.

Both [IAQG and IAF] have defended this practice by saying there is no specific rule against it. I argue that when the 17021 standard says, “the audit team shall complete” this means the audit team, and not the auditee, but [the authorities] have both ruled otherwise.

This position will not be interpreted by CB’s as applying only to the PEAR. It will open the floodgates for CB auditors to conduct any practice that is not otherwise prohibited in the standard. It will affect any QMS accreditation scheme subject to 17021, not just AS9100. It will result in more of what we are seeing now: companies hiring consultants to “pre-complete” audit evidence prior to an audit, ensuring the resulting language portrays a glowing report of the client, and then merely have the CB auditor sign off. When challenged, they need only point to your decision.

Oxebridge will report more on this as it develops.


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Since 2000, Oxebridge has worked to improve ISO and related certification schemes by identifying problems and then proposing solutions. We report on issues affecting standards users because so few other news outlets do. Our belief is that in order to fix the problems in these schemes, we must first understand the nature and breadth of those problems. Our reporting aims to do just that. Elsewhere on the Oxebridge site you will find White Papers and other articles proposing ideas to correct these problems.


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