PODCAST TRANSCRIPT:

Internal audits are an important aspect of the R2 Standard.  In fact, there are specific requirements for internal audits in three key areas:  legal compliance; data security and sanitization; and for the audit of the R2 requirements overall. So how can your facility build an effective internal audit program? That’s the topic of this episode of Ask the R2 Guru. I’m  RG from SERI – Champions of Electronics Sustainability.

Because of the importance of the internal audit process, in addition to this podcast and other guidance materials, SERI is also developing detailed  training on internal audits to help R2 Facilities build their internal audit programs.  While we won’t get into all of those details in this podcast, we’ll  review some of the key elements of an internal audit program, including identifying one or more internal auditors, deciding if or when to use an outside consultant, developing an internal audit schedule, and working with your internal auditor or consultant to develop an internal audit plan.

To begin, let’s take a look at why a robust Internal Audit process is so important. Like your R2 certification audit, the internal audits examine your operations to assess whether they are being performed in conformance with a set of specified requirements.

The most important benefit to a well-designed internal audit program is that potential issues can be identified and corrected before they become a problem. Another benefit is that an internal audit can be a much more detailed assessment of an R2 facility than an R2 audit that only samples processes. And the internal audit process can go beyond merely identifying areas of possible nonconformance by helping a facility ensure that adequate evidence, such as process records or work instructions, are available. These records and other evidence will help the facility to clearly demonstrate conformance with all R2 requirements.

To be effective, the internal audit must be a detailed process.  What you put into the process, will determine how effective it is and what you get out of it. As we mentioned earlier, there are some broad areas to examine and to plan for. You can complete these in any order… once again, here they are:

You need to select and engage one or more qualified internal auditors. More on this in a moment, but this should be completed early in the process because their availability will determine a lot of your remaining internal audit activities.

You should also decide whether to use an outside consultant to help your facility prepare for one or more of these internal audits. This may be required to address auditor competency requirements or to ensure the auditor is independent of the processes being audited.  Again, lead time is your friend on this one.

You should plan and develop your internal audit schedule around the audits conducted by your Certification Body.  This will enable you to allow plenty of time to correct and close any nonconformances found in your internal audits prior to undertaking your R2 audit.

And you should develop an audit process and plan including any forms or other resources you and your internal auditors will be using to conduct your audits and to record any findings. The plan will cover details on how the audits will be conducted; what is to be audited; how the audits will be scheduled; and the individuals responsible.

Once again, those four large items – auditor selection, use of consultants, internal audit schedule and audit plans and forms, can be completed in any order – whatever makes the most sense to you and your management team.

Another important point of the internal audit process; In the R2 requirements, you’ll see the phrase competent auditor mentioned more than once. This means that internal auditors must be adequately trained and experienced in auditing techniques and they must have knowledge of the subject matter in two areas: the processes they are auditing and the criteria they are auditing against.  Competence can be demonstrated using a combination of three things – formal education, training and experience.

Properly trained and competent auditors will look beyond whether or not you just have the basic documented procedures but will assess whether the operations are actually being conducted in conformance with those procedures and the other requirements of the standard, and that the results of the process are producing the intended outcomes. An auditor will do this by identifying and following audit trails which are a series of related inquiries and observations around any function or activity in your facility. These audit trails help to test the processes in place and confirm they are operating in conformance with the applicable requirements.

An example of an audit trail might be selecting a processed device that is destined for reuse and confirming that it was properly processed by reviewing the data sanitization and test records specific to that device.  Based on the records generated through those processes, the auditor could then confirm whether the proper cosmetic and functioning product categories were assigned to that particular device.  Of course, the auditor would want to sample numerous devices in this manner in order to get a reasonable level of confidence that the process is working as intended.  And, where there are issues or nonconformities identified, the auditor would follow those audit trails further to assess potential causes and even the extent of the issue.

Another example of an audit trail would be to assess incoming products and determine which focus materials they contain.  The auditor would then confirm that the FMs are included in the FM Management Plan, and then verify with appropriate processing and shipping records that the FMs are being sent to properly qualified downstream vendors.

So, an audit trail can be developed through a combination of activities such as visual observations, records reviews, verification of any product or packing labels, employee interviews – really, anything that demonstrates the processes performed or the results from those activities.  And, while this technique can be an effective way to identify and correct issues before your R2 audit, it can also be a valuable way to identify trends such as common or recurring issues.

To be successful, internal auditors must have the full support of the facility and not be restricted on what the audit covers.  Nor should the audit be so time-limited that the auditor can only make a cursory review of the activities involved.  And of course, any nonconformities identified through the process must be recorded and addressed using the corrective action process.  Other potential issues that are identified should also be tracked and where necessary preventive actions should be implemented to avoid these issues from becoming a nonconformance in the future.

But, an internal audit is not just for addressing issues. It can also be used to highlight positive activities and opportunities for improvement that can be further leveraged by your facility.

Overall, a robust audit program will not only help you to identify and prevent issues before they become nonconformances, but it can also help you to identify the different pieces of evidence that demonstrate conformance to the requirements, so that you are prepared for your R2 certification audit.  Remember, the overall goal of the internal audit process should be on preventing nonconformances, as opposed to simply finding them.

As I mentioned earlier, at SERI we know how important an internal audit program can be. We continue to develop new training tools to help you, including new videos, information sheets and sample forms. Anything new is announced in the SERI Knowledge Base on the SERI website. Search for Internal Audit or check the Recently Added column on the Knowledge Base page.

That’s it for this episode of Ask the R2 Guru. Thanks as always to the SERI team for their assistance in producing this podcast series. There’s a lot of information in this podcast, so you can find this complete script with links in the Podcast section of the R2 Knowledge Base on the SERI website. You’ll find that at sustainable electronics.org.