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Our newsletters provide guidance on ISO 9001,
AS9100, ISO 13485, ISO/TS 16949, TL 9000, ISO
14001,
ISO 27001, ISO 20000, ISO 22000, and related ISO
standards, as well as, Six Sigma.
If you have any questions about the articles
appearing in this issue, or you want to suggest
topics for future issues, please let us
know.
ISO 24762 for IT Disaster Recovery
Fires, earthquakes, and pandemics, as well
as, terrorism and piracy, may cause
organizations to become disaster victims at
any time.
A new standard, ISO 24762, will help
businesses deal with the unexpected and
safeguard their reputation, brand, and
value-creating activities.
ISO 24762:2008, Information Technology -
Security Techniques - Guidelines for
Information and Communications Technology
Disaster Recovery Services, as the title
indicates, offers guidance on the information
and communications technologies and services
necessary for disaster recovery as part of
business continuity management. With this
guidance, ISO 24762 supports the operation of
an information security management system by
addressing the information security and
availability aspects of business continuity
management in time of crisis.
A business continuity plan includes an
organization's strategies to prepare for
future national, regional, or local crises
that could jeopardize its capacity to
continue with its core mission, as well, as
its long term stability.
According to ISO 24762, business continuity
management is an integral part of any
holistic risk management process and involves:
identifying potential threats that may
cause adverse impacts to business operations
and associated risks
providing a framework for building
resilience for business operations
providing capabilities, facilities,
processes, action task lists, etc., for
effective responses to disasters and
failures
With ISO 24762, organizations will be able to
build resilience into their information and
communications technology infrastructure
critical to their key business activities.
This will complement their Business
Continuity Management initiative (to better
manage relevant risks possibly interrupting
their business activities) and their
Information Security Management initiative
(to effectively protect the confidentiality,
integrity, and availability of information).
The fallback arrangements included in the
standard will help out during periods of
minor outages and, more importantly, will
play an essential role in ensuring
information and service availability during a
disaster or failure, and for a long-term
complete recovery of activities.
The standard includes guidelines on the
implementation, testing, and execution
aspects of disaster recovery, and can be
applicable to both "in-house" and
"outsourced" providers of physical facilities
and services.
ISO 24762 is complemented by two other
standards providing control objectives for
information security aspects of business
continuity management to further reduce risk:
ISO 27001:2005, Information Technology -
Security Techniques - Information Security
Management Systems - Requirements, and
ISO 27002:2005, Information Technology -
Security Techniques - Code of Practice for
Information Security Management.
ISO 20000 - What is Coming Next?
The 1Q08 issue of the TickIT quarterly
journal contains an article by Graham Cox on
the future of ISO 20000, the IT services
management standard. ISO 20000 was published
in 2005 in two parts. Part 1 is the
Specification and used for certification;
Part 2 is the associated Code of
Practice.
Parts 1 and 2 of ISO 20000 are in the review
process and a revised Part 1 is expected in
2009 and the updated Part 2 in 2010. Both
parts will take into account ITIL v3.
The new Parts planned for the ISO 20000
family are:
Part 3: Guidance on Scope and Applicability.
This new Part may be issued as a Technical
Report to allow faster publication, perhaps
by the end of 2008.
Part 4: Process Reference Model. This new
Part will work in conjunction with ISO
15504-8 as the Process Assessment Model for
service management. Together, they will
define a multiple stage capability and
maturity model aligned to ISO 15504, also
known as SPICE: "Software Process Improvement
and Capability dEtermination", a framework
for the assessment of software processes.
In addition, an incremental approach to
conformity has been approved for development. The
first stage of this approach would give
advice to companies on requirements for
reactive activities. The next stage would be
mainly advice on requirements for proactive
activities. The final stage would be advice
on requirements for full integration. This
incremental approach might lead to the
requirements being subdivided to provide
stages for conformity.
You can read the full article, and its
discussion of TickIT and CMMI in relation to
ISO 20000, at the TickIT
Web Site.
ISO 13485 and GMDCAS
GMDCAS stands for "Global Medical Device
Conformity Assessment System", a program
initiated by the International Accreditation
Forum (IAF).
As many as 150 countries have no medical
device regulations. Several of these
countries are considering establishing their
own, unique regulatory requirements, with
more countries to follow. As a result, there
is a strong need to develop a third party
accreditation program that can be used by all
countries.
Since these countries rely heavily on
imported medical devices, their development
of national QMS accreditation requirements
could cause a serious adverse impact on that
country's local healthcare system. Why?
Because most medical device manufacturers
cannot justify making special accommodations
for a single, small market. In addition, many
certification bodies might find it
economically infeasible to apply for a
separate accreditation for just a few
clients.
Without a globally accredited QMS
certification program for medical devices,
the unintended consequence for these
developing countries may be to lose their
current access to healthcare technologies.
The IAF has established a Working Group for
the ISO 13485 GMDCAS program. This group
includes representatives from the United
States, Canada, European Union, Australia,
Japan, and China. It also includes industry
experts in medical device regulations and
standards. For more information, contact the
Chairman of the IAF Working Group, Grant
Ramaley, at (gramaley@aseptico.com).
Nonconformity, Defect, or Finding
Nonconformity
Are you using the right term? What do you
call it when a requirement is not met? ISO
9000:2005, 3.6.2, defines the non-fulfillment
of a requirement as a "nonconformity". As
expected, "conformity" is defined in 3.6.1 as
the fulfillment of a requirement.
However, some auditors use "conformance" and
"nonconformance". Does it matter? ISO
9000:2005, 3.6.1, states that although
conformance is synonymous with conformity, it
is deprecated. What does that mean? Well,
"deprecated" refers to a term that is
considered obsolete and being phased out.
That being the case, it is preferable to use
the terms Conformity and Nonconformity.
Defect
If a nonconformity relates to the intended or
specified use of the product, the correct
term becomes "defect". ISO 9000:2005, 3.6.3,
cautions that using the term "defect" has
legal connotations related to product
liability issues and should be used with
extreme caution.
Finding
When you hear about audit findings, you
probably think that problems or concerns are
being reported. Is that always the correct
interpretation? ISO 9000:2005, 3.9.5, defines
a "finding" as the result of an evaluation of
the collected audit evidence against audit
criteria. It states that findings can
indicate either conformity or nonconformity
with audit criteria, or opportunities for
improvement. So, findings can also be good.
It's just that audit reports tend to focus on
those findings that are nonconformities.
More on e-Audits
Our December 2007 newsletter included an
article titled, "Are e-Audits in Your
Future?" It discussed the advantages and
possible drawbacks of conducting electronic
audits from a remote location.
Having remote access to documents and records
for audit preparation, and then conducting
interviews by teleconference, can save travel
time and expenses, as well as, be less
disruptive to the auditee. However, not being
present at the remote location may reduce the
effectiveness of the audit.
The article examined e-audits by assessing
their impact on the four primary types of
evidence: Documents, Observations, Records,
and Statements. One of our readers, Eric
Bawden, responded with his e-audit approach
using that same framework for analysis. See below in Italics.
Documents: With the proper
authorization, auditors could review the
remote location's electronic documents while
planning the audit and also see them during
the execution of the audit. However, use of a
collaboration tool and/or a teleconference
will not allow the auditors to see if any
uncontrolled or obsolete documents are in
use.
"This is not the case in our businesses.
Documents are accessed real time and viewed
using Microsoft NetMeeting. We take screen
shots of the auditee's desktop and capture
file names and retention software that is
used for our objective evidence. If an
obsolete or uncontrolled document is being
used we know as if we were physically at the
site."
Note: The reader is correct for electronic
documents. I was referring to any printouts
that might be in use.
Observations: Since the audit is
remote and video cameras will not be
available for full viewing of the facility,
the auditors will not be able to see if the
work is being done per planned arrangements.
So, evaluating conformity will be limited to
what can be judged through interviews and
electronic records. Auditors will not see
poor housekeeping at the site or observe body
language during interviews.
"In our remote audits, we ask for pictures
to be taken of the areas and sent to us via
email. These pictures can be used for poor
housekeeping issues, work being done per
planned arrangements, and specifically in our
test and measurement labs to verify test
equipment is labeled correctly."
Note: Good idea, as long as the photographer
is impartial and objective. The auditor could
provide instructions on the areas to be
sampled with the pictures.
Records: If an organization creates
electronic records and scans hardcopy records
into electronic format, these records will be
available for remote access by the auditors.
However, some companies may have a
significant number of completed forms that
are kept as hardcopy records. Even if the
auditors request some of these hardcopy
records be scanned for viewing, the auditors
would not be physically selecting the sampled
records.
"Sample records may not be physically
selected, but while viewing a process or
procedure where records are required to be
retained, we have the ability to complete a
random sampling as we are the ones
controlling what processes and procedures to
view."
Statements: In a traditional audit,
the person being interviewed is reluctant to
have their responses captured on a recording
device. As a result, auditors write an
abbreviated version of the comments in their
notes. If an auditee wanted to, they could
later say it was a case of
miscommunication.
With remote audits, the auditor keys the
questions into the collaboration tool and the
auditee types in the responses. A concern is
that a more experienced employee could be
coaching the interviewee and the auditor
wouldn't know it. Also, with a typed
response, you don't hear the tone and
inflection of the voice to aid you during the
interview.
"While using Microsoft NetMeeting, we also
are teleconferencing. Generally speaking, we
set up our interviews with one person at a
time, and while coaching could be happening
at the other end of the phone, a savvy
auditor will pick up the pauses in the
conversation and be able to act if necessary."
Although the answers are recorded, they will
not become a direct part of the audit report.
And, the auditee should be made aware of this
fact to alleviate any fear they may have
about their responses being captured
verbatim.
If a teleconference is being held, the
auditor captures the responses in their
notes, as with a traditional audit. However,
they won't be able to observe the body
language during the interview. Even if a
video feed is available, what can be gained
through observation will be limited.
"I agree with this statement."
"We have been conducting remote audits in
our program for over three years now and
while we do find them somewhat limiting
compared to onsite audits, we have not run
into the issues that you state in your
article."
Thanks very much to Eric Bawden. Comments
from other readers?
Whittington & Associates provides training, consulting and auditing services for
quality systems based on
ISO 9001, ISO/TS16949, TL9000, AS9100, ISO 13485,
as well as, ISO 27001, ISO 20000, ISO 22000, and ISO 14001.