Guidance on ESD Control Program Audit Findings

During the audit process the auditor may identify opportunities for improvement within the ESD Control Program.

ESDA has defined three categories of findings that may be used:

  1. Observations - Potential areas for improvement that are not formal non-conformances. They provide valuable insights to enhance the overall robustness and effectiveness of the ESD Control Program.
  2. Minor non-conformances - Less severe deviations that may not directly jeopardize the effectiveness of the ESD Control Program but require corrective action. For Facility Certification, minor non-conformances must be addressed by the Organization and responded to via a Corrective Action Response to the Certification Body before a certification can be issued.
  3. Major non-conformances - Critical deviations from the requirements that could significantly impact the effectiveness of the ESD Control Program in achieving its intended outcomes. For Facility Certification, major non-conformances result in the Organization not achieving certification until Certification Body completes a follow-up visit to the facility to verify corrective actions are effective.

Organizations that have an internal audit program may have defined their own categories of findings which may be used instead of the ESDA definitions. Certification Bodies likely use the same, or similar, categories to what ESDA has defined, in the event there is a discrepancy between the Certification Body may use their categories of findings if they are technically equivalent to ESDA’s.

The auditor must use their expertise and judgement to determine what type of finding should be issued based on the objective evidence they have gathered. Some examples of findings may include:

  1. Observations
    • Not a problem yet, though may become a problem in the future, such as:
    • References to out-of-date standards.
    • Employees nearing retraining due date.
    • Long compliance verification or recurring training intervals.
    • Opportunities for improvement, such as:
    • Inconsistent use of terminology.
    • Implementation of preventative maintenance.
    • Implementation of acceptance testing.
    • Implementation of industry best practices (e.g., redundant controls for high-reliability applications, compliance verification trend analysis, etc.)

  2. Minor non-conformances
    • Incomplete training records, for example, 5 of 100 employees are overdue for ESD training by one week.
    • Some ESD control items do not meet specification, for example, 2 of 25 worksurfaces have a resistance to ground > 1x109 Ω.
    • Some employees are not grounded while handling ESDS items, for example, 2 of 30 employees were not using a wrist strap system / groundable static control garment system while seated.
    • Some employees did not complete personnel grounding verification, for example, 1 of 30 employees did not complete verification as prescribed in the organization’s procedures.

  3. Major non-conformances
    • Requirements of ESD Control Program Missing
    • Training examples: no ESD training plan documented or implemented, or ESD training plan documented though large quantity of employees not trained.
    • Compliance Verification examples: no compliance verification plan documented, many compliance verification records missing, large quantity of ESD control items do not meet compliance verification requirements.
    • Product Qualification examples: no product qualification plan documented, many product qualification records missing.
    • Technical Requirements examples: absence of ESD control methods (e.g., no use of personnel grounding, no use of packaging, etc.), EPA boundaries not defined, no plan to manage insulators or isolated conductors.
    • Multiple minor non-conformances