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December 2000
Vol. 9, No. 12, pp. 43–44.
Regulations and You
Compliance and Compassion

checked boxThe behaviors of the auditor and the auditee can determine the success of a systematic review.

Over the past two decades, compliance audits have become increasingly commonplace in the chemical industry. The reasons for this are straightforward: Companies must continually meet increasing regulatory, client, and certification requirements. Both internal and external audits are conducted for the purposes of measuring procedural adherence, ensuring conformity with expressed standards, and as a means of discovering methods for quality improvement. The success of any audit, however, depends most importantly on the behavior of both the auditor and the auditee.

Good Auditor Behavior
The first thing to remember is that an auditor is a human being with human frailties. An auditor should not look upon himself or herself as someone from a higher plane, and neither should an awed auditee. Fiorentino and Perigord (1) suggest that an auditor should not behave like an Albert Einstein (lecturing the auditee), a Merlin the Magician (exposing good and bad by waving a magic wand), an Albert Schweitzer (diagnosing a company’s strengths and weaknesses and giving remedies), or a Lt. Columbo (sleuthing to place the blame on the guilty party).

The personal traits that make a good auditor are readily apparent, and those individuals who are in a position to conduct such reviews should bear them in mind. First and foremost, an auditor should exhibit professional behavior and possess the appropriate level of experience, education, knowledge, and training to properly evaluate the area of concern. It is also important to remember that those being reviewed generally feel uncomfortable and may even be quite nervous. A good auditor will take this into consideration when discussing areas of concern with specific individuals and when raising potentially sensitive issues. In addition, several other “good auditing behaviors” should be taken into account:

  • the ability to deal with, and react to, diverse populations openly and honestly;
  • the skills necessary for clear and effective communication;
  • the ability to pose effective questions;
  • the knowledge of ways to resolve problems within the audit team and also between the team and those being audited;
  • the possession of a detail-oriented and investigative nature;
  • the self-control to remain neutral and objective at all times;
  • and the ability to avoid arguing, criticizing, or otherwise becoming emotionally involved.

Possession of the aforementioned traits are key to providing a valuable service without seeming difficult, annoying, or objectionable. In addition, the auditor’s job can be simplified by establishing a professional rapport with those being audited. These traits are not the only elements in an auditor’s personality that can favorably affect the outcome of a review. Some aspects of an auditor’s main work have been described previously in this department (TCAW, Nov. 2000, p 61). However, there are other things a good auditor can do to enhance the completeness and success of a review:

  • Avoid all conflicts of interest with the audited organization.
  • Always maintain the confidentiality of the audit; a company’s proprietary information must be treated with the utmost discretion and must never be shared with unauthorized persons.
  • Control the sample selection for auditing. The auditee should not choose which personnel are interviewed or which documents are ultimately reviewed.
  • Determine the duration, breadth, and depth of the audit without input from the auditee.
  • Provide sufficient time to allow for a full response to verbal queries, and listen carefully to those answers.
  • Consider the workplace environment as a whole and not just the words of personnel being questioned. Many times, the office atmosphere, people’s appearances, body languages, and relationships with one another speak volumes about the quality of an establishment.
  • Remain within the scope of the audit. The goal is not simply to uncover misdeeds or remonstrate with a guilty party—nor should a review turn into a search for the Holy Grail!
  • Base all judgments solely on documented evidence, and record all findings that support the negative observation.
  • Do not draw broad conclusions in place of specific factual summaries.
  • Communicate and clarify all audit requirements, and promptly report the audit results.
  • Verify the effectiveness of corrective actions taken as a result of previous audits.

The Internal Auditor
Many organizations have dedicated quality assurance departments comprising internal auditors. Their tasks can be particularly treacherous, because they must triangulate a difficult course between conducting a fair and impartial audit, maintaining corporate friendships, and remaining loyal to an employing organization. Various individuals’ experiences with, and attitudes toward, external reviewers may further complicate this difficult relationship. For example, if an auditor is generally perceived by the auditee’s organization as an unavoidable nuisance, an internal auditor may be looked upon as “the lowest form of life in [the] organization,” as Rice (2) puts it. Hard as it may therefore be, under no circumstances during the audit should an internal auditor’s fears of corporate retaliation or a co-worker’s rebuke color any of the audit. To do so would be to turn it into a mockery and, finally, negate its usefulness.

In smaller companies where one person may have multiple responsibilities, it is not always easy separating the roles of auditor and colleague. Auditees often include not just co-workers but also superiors. In some cases, local supervisors may have insufficient resources to correct the discovered problems, and, if the central management is not willing, little can be done to remedy the situation. Thus, many times, the internal auditor may also have to pitch in as a problem solver. This situation is unique and it requires the auditor to remain neutral, while exhibiting a cooperative and team-oriented attitude toward the workplace. No man is an island, and no internal auditor can be successful in improving the organization if the rest of the organization fails. A Pyrrhic victory is the last thing an internal auditor would want to attain.

The Other Side of the Coin
Auditing is, after all, a two-way street. The duties and obligations of a good auditor have thus far been described. However, to have a successful and fruitful audit process, the audited organization also has to meet some requirements. The individuals being audited need to know ahead of time what the scope and objective of the audit are, which areas will be audited, and which documents will be needed for review. If the auditor has not communicated this information beforehand, the auditee needs to make an effort to obtain this information directly. Having key people and necessary documents readily available at the time of the review makes life easier for those involved. Just as there are certain ways that an auditor should behave, there are also proper ways for the personnel being audited to act. This behavior is just as critical to the process and includes the following:

  • Keep the atmosphere and the conversation friendly but professional.
  • Do not try to influence an auditor’s judgment.
  • Answer only what is asked. Do not volunteer information unless it is requested, and don’t unnecessarily expand on any answers.
  • Recognize when you are right and when you are wrong.
  • Do not become emotionally involved in the review.
  • Do not “wing it” if the necessary information is not documented. It’s probably better to admit the lack of documentation than to argue something without proof.
  • If unsure, ask for time to consult with other staff members. No one will take exception to, “I would like to consult with my colleagues before answering.”
  • Show interest in the audit results.
  • Respond to written queries quickly, and follow up with the auditor’s suggestions before the next review.

An Audit’s Conclusion
In an interesting analogy, Fine (3) compares the conclusion of the audit process with that of accepting personal loss. Similar to coping with loss, he identifies five emotional stages through which the auditee must pass. At first, Fine says, there is denial that a problem ever existed. Then there is anger directed at the auditor for having pointed out the irregularities. Anger is followed quickly by an effort to bargain with the auditor in the hope that the report will not emphasize these discrepancies. However, when the report is issued and reflects the auditor’s areas of concern, depression can appear with the mindset that the required changes are impossible to achieve. Then, finally, when the process is complete and improvements have been made, there is an acceptance that the changes were good and that the organization is better for having made them.

Audits are stressful encounters for both the reviewer and the one being reviewed. The process runs the risk of being personal, confrontational, undisciplined, and unreasonably invasive. But when both parties in an audit remember the purpose of the review, plan for it, and approach it honestly, open-mindedly, and professionally, it is always a win–win proposition.


  1. Fiorentino, R.; Perigord, M. Quality Progress 1994, 61.
  2. Rice, C. M. Quality Progress 1994, 39.
  3. Fine, E. S. Quality Progress 1996, 144.


R. A. Kishore Nadkarni is a quality assurance auditor at Hill Top Research, Inc., in East Brunswick, NJ. Comments and questions for the author can be addressed to the Editorial Office by e-mail at tcaw@acs.org, by fax at 202-776-8166 or by post at 1155 16th Street, NW; Washington, DC 20036.

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