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This article presents physical security steps to be enforced in an organization to achieve effective information security. It has been published in the SEI Repository.
Recently, I encountered a few queries and clarifications on implementation of controls in ISO 27001. Almost in all cases, details available in ISO 27002 cleared doubts and gray areas. I advise practitioners to frequently refer to ISO 27002 for all their doubts.
Teresita Cirelos wrote this query to me:
Can you please advise me if it is mandatory to have a trained first-aider and a fire marshal for a company with less than 5 employees? If yes, kindly mention in which standard/ requirement / guideline should I refer to.
A building administrator is having one qualified first aider and one qualified fire marshal. This building is occupied by more than 50 small offices. One of the offices furnish a copy of the training certificates (first aider and fire marshal) from the building administrator (with consent) and claim during audit that these trained personnel will be in-charged with their emergency preparedness as well. Is this case conforming to the requirements?
And, this was my response:
Requirements for first aider and fire marshal are imposed by local regulators. For example, in India each factory establishment has to have trained first aid male and female employees at each location as mandated by our Factories Act. The act also mandates which all organizations are authorised to provide such certificate. Similar laws I have witnessed in Singapore and Indonesia. I don’t know what is the legal requirements in UAE. In China, building administrators used to train people for fire precautions and that meets their legal requirements too.
As an auditor: I would like to examine if the law of the land has a requirement for first aiders and fire marshals and are there any numbers of them required per 100 employees. If there is no legal requirements, I would like to examine if the first aider and fire marshal are actually ‘competent’ and have past experience in such roles. If not, merely having a certificate from building administration may not be considered as ‘adequate’ for the purpose. Also, one fire marshal is not sufficient for the job which needs round clock the attention/ vigil. S/he must be going on leave, and who will be responsible during the leaves- remains an open issue. A person cannot be expected to remain on vigil on 24X7 basis- month after month. Same is true for the first aider. Another aspect is the demand of the process of the company. Since, auditors audit against the defined process of the company, you as an auditor need to examine the compliance from this angle too. A few probing questions to fire marshal and first aider by the auditor may expose them if they are really not competent for the job. Three such questions may be: a. What was the learning from last round of mock fire drills/ last 10 first aid incidents and where are they recorded? b. Are these people members of professional forums/ discussion groups/ societies to keep their knowledge up-to-date on subjects of fire fighting and first aid. c. How can a male first aider handle a pregnant lady in distress because of sickness or fire? Finally, you may take a lenient view as the organization is a tiny one as far as no. of employees is concerned.
As an auditee: Rather than depending on just a single first aider and single fire marshal, I would like to have more of them and also have an agreement with the building administration to come forward to assistance when needed.
Internet is full of best practices for fire fighters and first aid professionals. See this link for best practices in fire fighting: http://www.iaff.org/tech/ops/CurrentEvents.htm . The second article in this link says more fire fighters were found to be more effective in case of real fire incidents. You can go through articles on first aid and fire fighting on www.irca.org.
The attached article provides some insights and clarifies issues being raised about the draft international standard ISO 9001:2015, scheduled to be published in Q-3 of 2015.
As mentioned in last few lines, I have declared copyright of this article to Quality and Process Improvement fraternity, not to myself.
Can someone clarify on following issues:
1. There is no mention of ‘Management Representative’ in the draft standard. Why?
2. CAPA: I don’t see the clause on Preventive Action. Also, the no. of review inputs and outputs have been reduced. Why?
3. Whether the company remains responsible for the quality of outsourced product or service is not clear as before.
4. Internal audit: ‘Auditors will not assess their own work’ is missing. Why?
I have seen auditors being nervous while planning and conducting audits of top/ senior management executives. While auditing and reporting findings of such audits may be a sensitive issue, seasoned auditors get considerable professional satisfaction by adding value through this mechanism. If conducted in a planned and professional manner, the auditee also gets new insights into their organizational processes and appreciate time invested in auditing.
Confidentiality must be maintained at all costs during and after top management audits. ‘Non attribution’ of audit findings, specially the negative ones, to any person or department should be avoided to the extent possible.
Planning, based on organizational process maturity, cultural and social aspects plays a vital role in such audits. Rather than throwing closed and leading questions to senior people in the auditee organization, the auditor must ensure most of the questions are open ones (example: would you please tell me the highlights of the organizational policy on project management?). The duration of the audit, its venue and who all will participate from the auditee & auditor’s side must be worked out prior to the audit and communicated to all concerned. Some of the initial questions may be about organizational strengths, weaknesses, opportunities for improvement, current management concerns, and management goals in measurable terms. All the questions, follow-up questions and their responses should be recorded. Later on, audit trails should be used to corroborate the responses received from top management.
Auditors must ensure no one gets insulted while presenting the audit findings during closing meeting or otherwise, especially those in the top management. At the same time, nothing worth mentioning, positive or negative, should be avoided.
See this article from the ISO site: http://www.gsprogress.us/Resources/Auditingguidance/Annex_9_AuditTopManagement.pdf .
My post on this topic in LinkedIn ISO 27001 Forum:
Famous quality Guru Joseph Juran says quality does not come a company without management commitment. He says he didn’t see a single exception to this rule in his entire career (and his career spanned over 80 yrs). While earlier, ‘management commitment’ used to be a requirement of process improvement standards, off late it has been ‘Leadership and its commitment’…see MBNQA, EFQM, ISO 27001:2013 etc. Effective and planned management review at pre-defined intervals is one such act of demonstrating management and/ or leadership commitment.
Why is it important?
Management in any company is at the driving seat. Unless they review various aspects of business performance, it will not be able to achieve defined objectives.
In very large corporations, 2 or 3 tiered management reviews may be planned and conducted with top management reviewing only with a few senior managers who have conducted their respective management reviews. Some of the companies conduct management reviews on video conferences while in a few smaller ones, such reviews are conducted by top manager going to different locations or different lines of business, one by one.
Inputs and outputs:
All those specified in the standards (e.g clause 9.3 of ISO 27001:2013) and BUSINESS DEVELOPMENTS/ EVENTS/ INCIDENTS/ POLITICAL OR SOCIAL SCENARIO/ EMPLOYEE ISSUES etc-etc.