Background
Over time our NAB has noticed an increase in reductions related to Effective Number of Personnel (ENP) when determining audit time, related to similar or repetitive processes. This has previously been raised in FAQ EA CC 40.9.
Our observation is that the size of reductions made have increased, which have an effect on the starting point according to Tables 1 (QMS/EMS/OH&SMS) in the Annexes of IAF MD 5:2019. Heavy reductions of ENP gives considerably lower starting points.
We ask for clarifications regarding expectations of risk considerations according to IAF MD 5:2019, 2.3.4, as well as acceptable size of reductions of ENP.
IAF MD 5:2019 gives no limitations regarding extent of reductions.
Questions
We have seen different principles to generalize reductions and ask for guidance of what can be accepted:
- Generic risk-classification of activities/positions used on every certified company regardless branch/industry, without statement to different risk related to each activities/positions. Using generic reduction for each activities/positions.
- Maximum 1/3 (or 33%) reduction of the total number of personnel. Reduction is done related to personnel perform certain activities/positions. Can the reduction to one certain activity/position be bigger than 1/3 (or 33%)?
- Personnel perform certain activity/position that are considered repetitive and/or similar, can the reduction be 100%, i.e. this personnel is excluded from ENP?
- Personnel perform certain activity/position that are considered repetitive and/or similar, can the reduction be square root of, i.e. 100 persons gives an ENP of 10?
- Personnel perform certain activity/position that are considered repetitive and/or similar, can the reduction be 50% on general basis?
- What evidence should the CAB present to confirm that the model for reduction is appropriate?
September 2022
The requirements of the IAF MD 5 relevant to the ENP are general and connected to concepts like risks, consistency, and effectiveness of the audit activities. Furthermore, the justification to determine the ENP shall be available to the client organization and to the Accreditation Body for review during their assessments and on request from the Accreditation Body (reference IAF MD 5 Clause 2.3).
For the 6 specific situations outlined in the Question, it’s not possible to define a YES/NO answer, but we have tried to evaluate each of them and give an answer if these situations are considered appropriate or not (always considering the effectiveness of the audit activities) as follows:
A1:
The method and criteria for determining ENP should be defined by the accredited CB, where criteria are related to activities/positions/functions and consideration of the risks connected with their effect on the specific management system.A2:
This approach could be appropriate based on defined methods and criteria and proper justification for the reductions (see also Q4). There is no such reduction limit for ENP.A3:
This is not appropriate and permitted (see also ENP definition – IAF MD5 – Clauses 1.9 and 2.3).A4:
This could be an appropriate approach. However, with such big reductions, it should be limited to similar/repetitive activities/processes/functions that are considered simple in the way that they require limited skills/knowledge/education, are executed under direction by others, and what they do has a limited effect on the outcome of the management system or its scope (ref. e.g., type of functions listed in IAF MD 5 – Clause 2.3.4).A5:
This approach could be appropriate based on defined methods and criteria and proper justification for the reductions (see also A4).A6:
There needs to be methods/criteria defined for determining ENP, and for a particular client, there needs to be appropriate records to show the activities/positions/functions identified for reduction and the number of personnel connected to them as a basis for a reduction in the calculation utilized.