Our NAB has noted an increase in the use of the argument personnel with “similar or repetitive processes” in order to reduce the number of personnel involved in the management system of the client and seeks a clarification.
The origin of this argument is that it is reasonable, when “number of personnel” is an important factor in determining the audit time necessary, that some form of correction to effective number of personnel may be made for repetitive low and unskilled functions (cleaners, security guards, drivers, packers, etc.), where in some parts of the world, a lot of these persons are included as staff, which would distort audit time calculations (and would not ensure a level playing field). Indeed in such cases, it is reasonable to assume that the effective number of staff is smaller and may be comparable to those organization where the same functions are performed by machines/electronic surveillance etc.
The same argument is not reasonable for highly qualified and trained staff, that also may perform repetitive functions (providing personal care (such as nurses, home care specialists, pharmaceutical assistants), designing buildings, performing audits, holding interviews, etc.), but that require personal judgement (and consistently elevated competences) to ensure that each client, customer or patient is treated appropriately, in line with customer expectations and/or professional standards. If we move down this path, practically every organization is mostly made up of repetitive functions, from organizations with auditors, architects and astronauts down to zoo keepers, zoning managers or Zork Game-developers.
Thus, the question is whether the argument of “repetitive functions” may be used to reduce the number of personnel in functions such as (para-)medical staff or other highly trained and qualified personnel. It is the opinion of the RvA that they should not, since we consider their activities not as “repetitive”, in the sense of the MD.
September 2020
The consensus position is to agree with the final paragraph above, The direct reduction on the number of personnel has a strong impact on the audit time. So, it should always be seen a high-risk decision, unlike the application of other “factor for adjustment” of the audit time, The activities within the parenthesis in IAF MD 5 #2.3.4 are very clear about the type of positions expected to be considered. The CB´s method used for time reductions shall include consideration of the risk of the activities/positions and have to be sensitive to that approach.