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articles:how_to_appeal_nonconformance [2020/05/19 09:25] – [Issuing an "Appeal"] rrandallarticles:how_to_appeal_nonconformance [2020/05/19 09:46] – [Preparing for an Appeal] rrandall
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 A MAJOR problem exists with almost every Management System Standard published by ISO (e.g., ISO 9001:2015, ISO 14001:2015) and, through extension AS 9100:2016. This problem is the proliferation of ambiguous/nebulous/vague requirements that promote subjective interpretation and inconsistent application.    A MAJOR problem exists with almost every Management System Standard published by ISO (e.g., ISO 9001:2015, ISO 14001:2015) and, through extension AS 9100:2016. This problem is the proliferation of ambiguous/nebulous/vague requirements that promote subjective interpretation and inconsistent application.   
  
-Consequently, when encountering these ambiguous/nebulous/vague requirements, some auditors will adopt their own subjective, and therefore arguable, interpretation of the “intent” behind the requirement.+Consequently, when encountering these ambiguous/nebulous/vague requirements, some auditors will adopt their own subjective, and therefore arguable, interpretation of the “intent” behind the requirement. This often happens because it's beyond the comprehension of an experienced Quality Professional, and well-trained auditor, that the standard would have ignored (or left out) several "key" concepts essential to requirements for the effective implementation of a basic Quality Management System (QMS). Struggling to make sense of this, many auditor's minds will attempt to "fill in the gaps"... "imagining" requirements that don't actually exist
  
 When auditors issue nonconformities to organizations for not meeting (their interpretation of) the “intent”, rather than the "actual" (verbatim) requirement, they’ve violated ISO 17021-1:2015, “//Conformity assessment — Requirements for bodies providing audit and certification of management systems — Part 1: Requirements//”. This document contains some important requirements that the registrars/Certification Bodies (CBs) must comply with. When auditors issue nonconformities to organizations for not meeting (their interpretation of) the “intent”, rather than the "actual" (verbatim) requirement, they’ve violated ISO 17021-1:2015, “//Conformity assessment — Requirements for bodies providing audit and certification of management systems — Part 1: Requirements//”. This document contains some important requirements that the registrars/Certification Bodies (CBs) must comply with.
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 ===== Preparing for an Appeal ===== ===== Preparing for an Appeal =====
  
-Every accredited CB is required to have an appeals process (as specified in ISO 17021-1:2015, section. 9.7, "Appeals"). However, they’re not required to post their appeals process on their web site or make it easy to find. You may need to phone or e-mail your registrar to appeal an invalid nonconformity.+Every accredited CB is required to have an appeals process (as specified in ISO 17021-1:2015, section. 9.7, "Appeals"). However, they’re not required to post their appeals process on their web site or make it easy to find. You may need to phone or e-mail your CB to appeal an invalid nonconformity.
  
 ISO 17021-1:2015 states: ISO 17021-1:2015 states:
 <blockquote>9.7.4 The appeals-handling process shall include at least the following elements and methods: \\ <blockquote>9.7.4 The appeals-handling process shall include at least the following elements and methods: \\
-a) an outline ofthe process for receiving, validating and investigating the appeal, and for deciding what+a) an outline of the process for receiving, validating and investigating the appeal, and for deciding what
 actions need to be taken in response to it, taking into account the results of previous similar appeals; \\ actions need to be taken in response to it, taking into account the results of previous similar appeals; \\
 b) tracking and recording appeals, including actions undertaken to resolve them; \\ b) tracking and recording appeals, including actions undertaken to resolve them; \\