November 2022

 The Registrar Audited My First Aid Kit!

Ty Haines, President Manufacturer Solutions, LLC

Yes, OSHA rules are auditable as regulatory requirements in the ISO 9001, 13485, IATF 16949 and AS9100D standards. But the auditor is expected to use some common sense in where to draw the line since they were not hired to do an OSHA compliance assessment and no one knows if that auditor is qualified or judged competent to audit regulatory.

So, in my great many audits, more for Internal Audits, but also including as an auditee and auditor for multiple Registrars, any auditor should keep alert for obvious safety issues – if only for their own survival! A nonconformance should be written for a clear obvious problem otherwise an opportunity should be noted. Obvious and common nonconformance issues can include no training records and:

  • Forklift: no inspection records, not using seatbelt, missing alarms
  • Blocked fire extinguishers or exits
  • Crane, hoist inspections
  • Machine guarding
  • LOTO rules not in use
  • Extension cord use
  • And my old nemesis: uncontained storage of pallets on end

I have written OFIs or nonconformances on the above. Having had OSHA & EPA training plus 40 years in industry, I have paused more than one audit if an immediate danger was present. However, I do not carry a tape measure to check if ladders, railings or stairs dimension meet the requirements.

The wise auditor will stay within the QMS scope and bias their audit on risk to the end customer, employees and company. The unwise can misplace time on the QMS into verifying details on the OSHA Log or DOT driver physicals, Electrical codes…or worse!

One unwise Registrar’s auditor was going to write a finding of nonconformance after checking all the expiration dates in the first aid kit to find only a squirt bottle of eye wash was out of date. I thanked him then reminded him of our QMS scope and that we did not sell first aid kits. He next precariously went behind machines to find a jug used to transfer hydraulic oil from drum to a machine. There was oil residue in it and was missing the proper EPA markings. He showed little interest in the machining processes that produced salable parts. His next step was out the door with a direction that he would not set foot on the property again. Was he technically right, yep. Did he cross the line into knit picking and out of scope: oh yeh. I later heard that a friend had kicked the same auditor out of their shop for similar unwise and unusual findings.

Our next auditor performed as expected biasing her time to processes related to the product we sold. I most often interview an unfamiliar Registrar’s proposed auditor before accepting or rejecting them. I use the scenario above as one of my questions. Not one prospect has failed to respond that the deep dive into the first aid kit’s contents was out of scope.

This story is an opinion of Ty Haines of Manufacturer Solutions, LLC; certified Lead Auditor for ISO 9001:2015 and AS9100D; a great many interpretations are possible of the QMS Standards.

Caught up in the daily grind? We can help!

Since our team has manufacturing success at various levels and responsibilities, we are focused on delivering value.  Having sat on both sides of the table we are a bit frugal and respect the part of the value formula in keeping the cost down.  Many consulting firms lack the pragmatism, some have never gotten their hands dirty setting a tool or physically running equipment making parts:  we have because it is part of learning the whole operation.

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