5.1 Initiating the Audit: Contact, Feasibility & Audit Team Assignment

Key Takeaways

  • ISO 19011:2018 Clause 6.2 covers initiating the audit: 6.2.2 establishing contact with the auditee and 6.2.3 determining feasibility.
  • Audit objectives, scope and criteria are set at programme level under Clause 5.5.2 before initial contact, and the team leader is appointed under Clause 5.5.5.
  • Feasibility turns on sufficient information for planning, adequate auditee cooperation, and adequate time and resources.
  • If an audit is not feasible, ISO 19011 requires an alternative to be proposed to the audit client in agreement with the auditee.
  • A technical expert works under the direction of an auditor and does not audit independently; an observer does not audit at all.
Last updated: September 2026

Initiating the Audit: Contact, Feasibility & Audit Team Assignment

Quick Answer: ISO 19011:2018 Clause 6.2 covers everything that happens before preparation begins: 6.2.2 establishing contact with the auditee and 6.2.3 determining the feasibility of the audit. Feasibility is the gate. If sufficient and appropriate information for planning, auditee cooperation, or adequate time and resources are not available, the audit should not proceed — and proposing an alternative to the audit client is a Lead Auditor responsibility, not a discourtesy.

Candidates lose marks here because initiation looks administrative. It is not. Almost every catastrophic audit — the team that arrives without the right technical competence, the audit that cannot reach the second shift, the auditor who turns out to have consulted for the client two years ago — traces back to a failure at Clause 6.2 or at team selection.

Where Initiation Sits

  Clause 5.5.2  Define objectives, scope and criteria for the individual audit
  Clause 5.5.4  Select audit team members
  Clause 5.5.5  Assign responsibility for the audit to the audit team leader
        |
        v
  Clause 6.2.2  Establish contact with the auditee   <-- team leader now leads
  Clause 6.2.3  Determine feasibility of the audit
        |
        +--- NOT FEASIBLE --> propose an alternative to the audit client
        |
        v  FEASIBLE
  Clause 6.3    Prepare audit activities (document review, plan, work allocation)

Note the ordering trap: the objectives, scope and criteria are set at programme level under Clause 5.5.2, and the team leader is appointed under Clause 5.5.5, before Clause 6.2 begins. A sequencing question that puts "define the audit objectives" after "establish contact with the auditee" is testing exactly this.

Establishing Contact with the Auditee (6.2.2)

ISO 19011 expects initial contact to:

  • Confirm communication channels with the auditee's representative.
  • Confirm the authority to conduct the audit — for a third-party audit, the certification agreement; for a second-party audit, the supply contract clause.
  • Provide relevant information on objectives, scope, criteria, methods and audit team composition, including any technical experts.
  • Request access to relevant information, including records, for planning purposes.
  • Determine applicable statutory and regulatory requirements, and other requirements relevant to the auditee's activities.
  • Confirm the arrangements, including the roles and approval of guides and observers.
  • Agree site-specific arrangements — health and safety, security, escorts, personal protective equipment, confidentiality and any site induction.
  • Establish arrangements for specific locations, including remote or virtual access where audit methods will be applied off site.

For an EMS audit, three of these carry disproportionate weight. Confirming statutory and regulatory requirements early is what allows the team to obtain the site's permits before arrival; a lead auditor who first sees a trade effluent consent during the opening meeting has already lost the ability to plan a compliance trail against it. Health and safety arrangements matter more on an EMS audit than on most others, because the evidence lives in tank farms, effluent plants and waste compounds. And team composition disclosure is what gives the auditee its right to object to a team member on impartiality grounds.

Determining Feasibility (6.2.3)

ISO 19011 states that the feasibility of the audit should be determined to provide reasonable confidence that the audit objectives can be achieved. Feasibility considers whether there is:

FactorPractical EMS test
Sufficient and appropriate information for planning and conducting the auditAre the EMS scope statement, aspect register, compliance obligations register, permits, internal audit results and management review minutes available?
Adequate cooperation from the auditeeWill the auditee release operators for interview, permit site access to bunded areas and outfalls, and provide guides?
Adequate time and resources for conducting the auditDoes the allotted duration match the site's complexity, shift pattern and number of significant aspects?

If the audit is not feasible, ISO 19011 is explicit that an alternative should be proposed to the audit client, in agreement with the auditee. Note the direction of that communication carefully — the proposal goes to the audit client (the organization or person requesting the audit, Clause 3.12), not simply to the site contact.

Realistic Feasibility Scenario

A certification body schedules a two-day Stage 2 audit at a metal finishing plant. During initial contact the Lead Auditor learns that the plant runs three shifts, operates two separate discharge consents, and that the electroplating line — its largest source of significant aspects — will be shut for a full rebuild across both audit days.

Correct action: the audit is not feasible as scheduled. Objective evidence of operational control over the plant's most significant aspect cannot be obtained if the process is not running. The Lead Auditor informs the certification body (the audit client) with the reasoning, and proposes rescheduling or splitting the audit so the electroplating line is audited in operation.

Incorrect actions candidates choose: proceeding and writing a nonconformity because the line was not observed (there is no requirement to operate during an audit); proceeding and sampling only the running processes while still recommending certification for the full scope (the recommendation would not be supported by evidence); or quietly extending the audit by a day without the client's agreement.

Selecting the Audit Team (5.5.4) and Assigning Work (6.3.3)

Team selection is a programme-level decision under Clause 5.5.4, taken so that the team collectively holds the competence needed to achieve the audit objectives. For an ISO 14001 audit that means more than generic audit skill:

  • Generic auditor competence — ISO 19011 Clause 7.2.3 knowledge and skills, plus the personal behaviours of Clause 7.2.2.
  • Discipline-specific EMS competence — environmental terminology, aspect and impact methodology, life cycle perspective, environmental metrics and monitoring techniques.
  • Sector-specific technical knowledge — for a chemical plant, an understanding of bunding, secondary containment, scrubbers, effluent treatment and hazardous waste consignment.
  • Applicable statutory and regulatory knowledge — the permitting regime in the jurisdiction being audited.
  • Impartiality — no team member may have provided consultancy to the client, and certification bodies apply defined cool-off periods before a former employee or consultant may audit an organization.

Where the team lacks technical knowledge, a technical expert (ISO 19011 Clause 3.16) may be added. The exam point that catches people: a technical expert acts under the direction of an auditor and does not audit independently. An observer, by contrast, accompanies the team but does not audit at all, and must not influence or interfere with the audit.

Once the team exists, Clause 6.3.3 assigns work to individual members — allocating processes, functions, sites and activities. The team leader makes those assignments in consultation with the team, considering competence, impartiality, effective resource use, and the different roles of auditors, auditors-in-training and technical experts. Assignments may be changed as the audit progresses to ensure the objectives are achieved.

Common Initiation Failures and Their Consequences

Failure at initiationDownstream consequence
Permits not requested before arrivalNo compliance audit trail can be planned; Clause 9.1.2 gets audited superficially
Shift pattern not establishedSecond and third shift operational control never sampled; a systemic gap survives certification
Team composition not disclosedAuditee raises an impartiality objection at the opening meeting, derailing the audit
Feasibility not tested against site availabilityKey processes not running; evidence unobtainable; conclusions unsupported
Audit duration accepted without challengeTeam runs out of time and samples too thinly to support a recommendation

The professional habit worth carrying into the exam: feasibility is a decision, and the Lead Auditor owns it. When a scenario question offers "proceed anyway and note the limitation" against "advise the audit client and propose an alternative", the second is almost always the ISO 19011 answer.

Test Your Knowledge

Under ISO 19011:2018 Clause 6.2.3, an audit is found not to be feasible. What does the standard require?

A
B
C
D
Test Your Knowledge

A Lead Auditor discovers during initial contact that the electroplating line — the site's largest source of significant environmental aspects — will be shut for a rebuild across both scheduled Stage 2 audit days. What is the most appropriate action?

A
B
C
D
Test Your Knowledge

Which statement correctly describes a technical expert on an ISO 14001 audit team?

A
B
C
D
Test Your Knowledge

In which sequence do these activities occur under ISO 19011:2018?

A
B
C
D