Updated: Nov 19
On a regular basis over the years, Assessors from Registrars, also referred to as Certification Body (CB), have attempted to limit the participation of MSI personnel from assessments. Almost universally, Assessors will cite “prohibitions” against what they term as “consultants” participating in these assessments, rather than only client personnel participating. Generally, the manner in which Assessors address the issue with Client personnel and with the MSI employee is quite often poorly handled by the Assessor and results in embarrassment to the MSI employee and the client. Unfortunately, experience has shown that it is usually the less-competent, more insecure Assessors who attempt to bar MSI personnel from the assessments. The competent Assessors who have confidence in their own ability to conduct a fair and valuable assessment do not object to our participation.
Every MSI employee is thoroughly trained to maintain a high degree of professionalism when dealing with anyone on behalf of our client; including CB personnel. The manner in which we advocate for the client, essentially our employer, on matters pertaining to compliance, is always done in an atmosphere of respect for the parties involved. Registrars and MSI have shared clients for years. It is continually disappointing that certain Assessors are unable to manage the relationship more professionally.
Ironically, a key factor that the Assessors do not consider is that the vast majority of they, themselves, are contractors. Very few registrars maintain Assessors as dedicated employees. Most Assessors are independent contractors; most of them working for multiple registrars. Certain registrars even utilize the services of contractors for other functions within their CB organizations. It is puzzling why Assessors cannot understand the business needs of the shared Client given these factors.
Throughout the business world, the "gig economy" is quite accepted and seen as a way for organizations to increase their competence levels, productivity and cost-management. Quite a few MSI clients have now turned over a substantial portion of their Management System responsibilities to us. At some clients, MSI personnel are the named Quality Manager, or equivalent. Assessors will have to accept the fact that clients see benefits, financial as well as professional, in using MSI personnel.
ISO 9001:2015 (and the other management system Standards) recognizes that companies will be outsourcing processes. Clause 8.1 of the Standard reflects the requirement “The organization shall ensure that outsourced processes are controlled (see 8.4)”. Clause 8.4 includes the requirement that “…The organization shall determine the controls to be applied to externally provided processes, products, and services when: c. a process, or part of a process, is provided by an external provider as a result of a decision by the organization”. Within the requirements of ISO 9001:2015, and the client system, certain activities are implemented to reflect the control of the processes provided by MSI including:
Basis for qualification of MSI:
“Grandfathered”; at most Clients, delivery of our services pre-dates implementation of formal qualification processes.
History; most MSI clients have been serviced by us for years, some decades.
References; these are provided to all prospective clients and available to any interested party on request.
Our website, msi-aqr.com, provides plenty of information regarding our history, capabilities and qualifications.
Referrals; almost all of our new clients have been referred to us by past or present clients.
On the “Approved Supplier List” (ASL), or equivalent “…register of its external providers…”
Descriptions of roles, responsibilities and authority:
MSI personnel are usually reflected on the Client Organization Chart.
The Statement of Work (SOW) in the MSI/Client contract provides a detailed description of our services.
As presented in applicable process descriptions (i.e.: procedures, flowcharts).
Also of significance is the difference between the “consultant” and the “contractor”. A convenient comparison is provided by James F. Rogers II:
“The short answer is that the Consultants role is to evaluate a client's needs and provide expert advice and opinion on what needs to be done while the Contractors role is generally to evaluate the client's needs and actually perform the work”.
In other words, the consultant will tell the client what to do while the MSI contractor actually also performs the work. Given that, the MSI employee is part of the processes and management system of the Client organization.
The Assessor has no basis for refusing to interface with any personnel that the client puts forward as representing them. MSI personnel are on contract to the client and perform an increasingly large number of functions based on the needs of the client. It is within the rights of the client to retain personnel based on their business needs. The fact that some of those personnel are paid on a contract basis, as opposed to being a permanent employee, is not the concern of the Certification Body (CB). If the person is recognized as being within the client organization, as represented on the Organization Chart and other descriptions of authority and responsibility, that person is allowed to participate in the assessment as the client directs.