I would like to ask for your opinion regarding our practice of declaring several minor non-conformities as a major non-conformity. The minor findings may be found in one or several departments and we usually call this system non-conformity.
I agree with that practice and use it myself in my audits. If I find several minor nonconformities about a similar topic throughout an organization, I normally write a major nonconformity because it is a systemic problem and each previous minor nonconformity support that conclusion.
Another thing is whenever there are 3 or 4 observations, we elevate and consolidate them into a non-conformity.
About observations I have a problem. There is no ISO 9000:2015 or ISO 19011:2018 definition of observation. What do you consider an observation? Your findings either are conformity or nonconformity. If they are conformities and you think there is an opportunity for improvement it is your opinion based on your experience. You as auditor can suggest that there is an opportunity for improvement. What do you consider as an observation?