This article is the third part in a three part series on how auditors can successfully navigate some of the obstacles and roadblocks conveniently adopted by more experienced auditees.
In the first article we discussed time wasting tactics, the next article looked how to avoid challenges associated with scope of work confusion. Today we will be discussing the deliberate attempts we’ve experienced throughout the years to mislead us or keep us in the dark by auditees during the audit process. Specifically roadblocks in this area come under disclosure, transparency and non conformance.
Locked in dedicated room
Often, upon arrival to site, our Auditors are introduced and quickly thereafter shown to a room where the Auditee expects you to reside for the duration of the audit. The more experienced Auditors will not fall for this trap.
Our Auditors, during the opening meeting, quickly establish the grounds or rules of engagement and make it clear that they will be working throughout the site and that they will be seeking objective evidence from a range of sources determined by them, not the Auditee.
Experienced Auditees will often;
a) Try and keep you in a dedicated meeting room filled with various books and records that they want you to look at, not the ones they don’t.
b) Try and keep you in a room whereby you have limited access to other persons or materials for review.
c) Insist that you need to stay put for safety or security reasons.
One Auditee, after having agreed to the scope of work and processes to be audited, waited until our Audit team arrived at site to advise that they could not move between operational areas without the required security clearances or a personal escort. While this is acceptable, as we must adhere to clients policies and procedures, it was a totally unacceptable situation as the escort promised to be provided by the auditee was never readily available and the security clearance passes were not issued until the last day of the audit.
Senior Management or Operations staff not available
One of the major obstacles in performing an audit is having access to the relevant Senior Management team and key operational staff. All too often we find that, being made aware of the audit, its duration, in advance, they are conveniently not available. We find that, conveniently:
a) Senior Management team are called for an urgent off site meeting
b) Key Operations staff call in sick or go home on the day of the audit
c) Senior Management and Key Operational Staff allocate a subordinate with limited knowledge to respond to the audit questions
d) The activity to be audited is managed by a third party/contractor who works off site and not available without prior notification
There are a range of situations which render the Senior Management team or Key Operational staff unavailable. This makes it all the more difficult to get to the bottom of things, when only half the answers can be provided.
To avoid any confusion, we always state in our audit preparations / opening meeting that if the objective evidence (verbal, illustrated or documented, etc.), cannot be provided at the time of the audit to demonstrate compliance, it will be deemed to be Non-Conforming.
Records for inspection not retained on site
Often during the course of the audit, the Auditee will state that the records that we are seeking to validate conformance are unavailable, off site or otherwise. This is a frequently applied decoy to throw the Auditor off track, especially once the Auditor has an inclination that there is a deficiency, e.g. Training Records.
Our audit team are often provided with responses such as we don’t have access to these records, as:
a) they are held by Corporate/Head Office
b) the person you need to speak with is away today
c) these records are retained by our contractor
d) the dog ate them
In other instances(what is the first instance?), the Auditee will go to the immense trouble of preparing folder after folder to review as part of the audit. They are often disappointed when we insist on selecting our own sample of records (from the workplace) to review, rather than the perfect set of records they have provided our team.
Beware, do not let your Auditee select items to be audited, rather insist on selecting your own “random sample” of plant, equipment or processes to audit. This will give you a more accurate reflection of what’s really happening.
We even encounter (have even encountered) situations whereby records are crafted immediately following the opening meeting or a line of enquiry. When they are provided to the Auditor as objective evidence, the ink is still wet and the information doesn’t align with other information provided. Needless to say we don’t accept these types of records as valid proof.
Unfortunately, whilst the majority of Auditees aspire to comply with standards and requirements, in practice they cannot demonstrate this with the appropriate objective evidence – records.
Handling Non Conformances
During the course of the audit process our team will communicate to the Auditee areas of Non Conformance. These are often clarified and tabled at the closing meeting just in case anyone should object or seek further clarification.
In our experience, Auditees deliberately;
a) Avoid attending the Audit Close out meeting intentionally, so they can dispute the findings later on, by saying they were never asked for specific information
b) During the audit throw up a red herring, which they hope the Auditor will latch onto. This is a common strategy to divert the attention of the Auditor away from a bigger problem
c) Try and negotiate the re-qualification of an audit Non Conformance form Major to Minor after the report has been issued, by offering to surrender information which they deliberately kept from the Auditor during the audit.
So in order to ensure you are receiving full disclosure and transparency during the audit, we advise you be clear and upfront about what records you will need to study and who you expect to participate before the audit commences.
For further assistance in managing auditees during the audit process, Compliance Experts have developed a free app designed to optimise your auditing process and make your life easier.
Learn more about it here.
