Tampa FL — The debate over whether AS9100 certification body auditors may request, or even require, audit clients to complete their own evidence reports prior to the audit is being escalated to the International Accreditation Forum (IAF).

Representing aerospace clients in the United States, Oxebridge Quality Resources International has been pushing for clarification of the practice since it was first discovered in September of 2011, after an auditor with QMI/SAI Global sent an email to clients asking them to complete required Process Effectiveness Assessment Reports (PEARs) prior to the on-site audit. Oxebridge discovered the problem was being seen amongst a number of registrars, and requested clarification of the practice from US accreditation body ANAB.

ANAB’s Randy Dougherty responded that the issue should e addressed to the International Aerospace Quality Group (IAQG), who authors the AS9100 standard. But in the response, Mr. Dougherty indicated that he likely did not see a problem with clients providing some of the information.

Oxebridge and other organizations contend that asking clients to complete PEAR and other forms in advance of an audit — whether in whole or part — not only offloads work to the client that the auditor is being paid to perform, but also introduces serious problems related to audit objectivity and the value of accredited third party certifications. In Oxebridge’s view, having clients complete their own audit forms reduces third party auditing to first-party auditing, and therefore violates international accreditation rules.

Oxebridge requested clarification from the IAQG but the issue went unanswered for months. A discussion of the matter broke out on popular business social network site LinkedIn, at which point it was reported that a trainer with Plexus International had been training auditors on the practice. As the discussion heated, and more companies reported the problem, Plexus representative Jim Collins threatened a lawsuit over the discussion, and shortly thereafter the AAQG shut down its entire LinkedIn page, deleting all discussion entries, and removing its presence from the social network entirely.

(The lawsuit did not come to fruition as it appears that Mr. Collins did not have authority to make any such threats. Multiple requests for clarification on this point were sent to Plexus senior management, and while the requests were confirmed as received, they went unanswered.)

Oxebridge then submitted a formal, written request for clarification to the IAQG’s Director, Xavier Sahut d’Izarn, who forwarded it to Tim Lee, the head of the IAQG’s Registration Management Committee (RMC). Months passed without a response to Mr. Lee, and so Oxebridge requested a few registrar representatives to pressure Mr. Lee at an RMC meeting in July 2012.

Rather than provide an official response from the RMC membership, Mr. Lee instead wrote a personal email to Oxebridge VP Operations Christopher Paris, defending the practice and indicating that “we have no issue with the clients completing the forms,” because “there is no requirement that prevents a CB from requesting that their clients complete the form as an audit prep activity.”

Oxebridge had requested a more formal consideration and response, but as of October 2012 has not received a response.

Mr. Paris is now escalating the problem to the IAF, under the charge that the practice undermines the entire notion of third party certification, and puts the value and validity of accredited certifications at risk.

“The IAQG has clearly indicated that it does not take this position seriously,” Mr. Paris says. “The IAF will have to rule on it for them. They have to decide once and for all if first-party self-auditing is allowed under a third-party conformity assessment scheme.”

Oxebridge asked ANAB’s Mr. Dougherty to recuse himself, as he is also the Chair of the IAF. He has agreed to pass the matter onto Norbert Borzek, Chair of the IAF Technical Committee and appointed liaison to the IAQG.

Mr. Paris is considering a second submission to the IAF at a later date, to review whether AS9101D’s requirement that auditors gather evidence proportionate to the breakdown of an organization’s customer base violates accreditation rules requiring objective sampling of evidence.


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