Are these things really required in a document control procedure?

Good day!

I work for a small engineering firm. Prior to hiring me, they hired a consulting firm who interviewed several people within the company (not all) then created 15 procedures and a QM. I am new to the QMS/AS9100 world, but I find the procedures created by the consulting firm to be overly redundant with a propensity for copying and pasting verbiage directly from the standard.

I recently worked on revising the Doc Control procedure (with input from 2 superiors) and sent the document back to the consulting firm for their feedback. Among various criticisms, two stand out to me and I would like your thoughts:
1) She stated that we must have a table in the document that references the QM, as well as all the other procedures. (I amended the "Related Documents" table to include reference to the work instructions that will support the procedure, instead). I don't have a problem with adding it back in, but it was fairly cumbersome, and I don't see anywhere in the standard to indicate all procedures must reference the QM and the other procedures.
2) The original procedure had several bullet points taken directly from the standard. I removed several of them, as to me they are givens and add no value to our procedure for document control, but she was concerned that I removed the statement "all documents are to remain legible and readily identifiable," as registrars will expect to see that verbiage, she claims.

I can see that these will be two battles I will face as I work to revise the other procedures, and before I waste time defending my position (which is possibly misguided due to inexperience), I am interested in your feedback.

Thank you in advance for your time!

JaimeB said:

Good day!

I work for a small engineering firm. Prior to hiring me, they hired a consulting firm who interviewed several people within the company (not all) then created 15 procedures and a QM. I am new to the QMS/AS9100 world, but I find the procedures created by the consulting firm to be overly redundant with a propensity for copying and pasting verbiage directly from the standard.

I recently worked on revising the Doc Control procedure (with input from 2 superiors) and sent the document back to the consulting firm for their feedback. Among various criticisms, two stand out to me and I would like your thoughts:
1) She stated that we must have a table in the document that references the QM, as well as all the other procedures. (I amended the "Related Documents" table to include reference to the work instructions that will support the procedure, instead). I don't have a problem with adding it back in, but it was fairly cumbersome, and I don't see anywhere in the standard to indicate all procedures must reference the QM and the other procedures.

Click to expand...

There is no requirement for such a table. The QM must include or reference the documented procedures, but not the other way around.

JaimeB said:

2) The original procedure had several bullet points taken directly from the standard. I removed several of them, as to me they are givens and add no value to our procedure for document control, but she was concerned that I removed the statement "all documents are to remain legible and readily identifiable," as registrars will expect to see that verbiage, she claims.

Click to expand...

Again, no such requirement. The requirement is for all documents to remain legible, etc. You don't have to parrot the standard.

JaimeB said:

I can see that these will be two battles I will face as I work to revise the other procedures, and before I waste time defending my position (which is possibly misguided due to inexperience), I am interested in your feedback.

Click to expand...

Any time you feel that dealing with a consultant is a battle, there's definitely something wrong somewhere. You seem to have a good grasp of the basic principles--keep things concise, don't cut and paste from the standard, e.g.--so I think you should fight the good fight and don't let the consultant complicate things unnecessarily.

In addition to Jim's comments, look at the standard which the QMS is based on. If it is a mandated procedure, it will tell you what controls have to be in the procedure. If it is not a mandated, then the controls listed will be up to your organization, and its needs.

Also, make sure your own documents don't have unnecessary requirements. If they do, then modify them.

Jim Wynne said:

There is no requirement for such a table. The QM must include or reference the documented procedures, but not the other way around.


Again, no such requirement. The requirement is for all documents to remain legible, etc. You don't have to parrot the standard.


Any time you feel that dealing with a consultant is a battle, there's definitely something wrong somewhere. You seem to have a good grasp of the basic principles--keep things concise, don't cut and paste from the standard, e.g.--so I think you should fight the good fight and don't let the consultant complicate things unnecessarily.

Click to expand...

Totally agree with Jim. I recently visited one of our outsourced suppliers to conduct a 2nd Party audit. They had hired a consultant to help them through the 9001 process. The level of documentation and procedures that this consultant insisted upon was extremely over the top, it was again the typical cut and paste from template management system. It was not workable and of no added value for their small engineering firm so they decided against 9001.

I have recommended another consultant who I know would do a good job.

Chrissie

db said:

In addition to Jim's comments, look at the standard which the QMS is based on. If it is a mandated procedure, it will tell you what controls have to be in the procedure. If it is not a mandated, then the controls listed will be up to your organization, and its needs.

Also, make sure your own documents don't have unnecessary requirements. If they do, then modify them.

Click to expand...

Thank you, I appreciate it! Let me rephrasee my question. While the standard does not require those elements (mentioned above), is there a value add they offer that I'm missing? Her comment that registrars will look for certain verbiage in the procedure struck me, as everything I've read (here at the Cove) has been almost unanimous that procedures should be written for the organization, and the registrar/auditors will be familiar enough with the standard that they don't need you to "parrot" it.

JaimeB said:

Thank you, I appreciate it! Let me rephrasee my question. While the standard does not require those elements (mentioned above), is there a value add they offer that I'm missing? Her comment that registrars will look for certain verbiage in the procedure struck me, as everything I've read (here at the Cove) has been almost unanimous that procedures should be written for the organization, and the registrar/auditors will be familiar enough with the standard that they don't need you to "parrot" it.

Click to expand...

If you do anything, do it for the value it brings the organization! I'm sad/annoyed to read that any consultant would be telling you there's value in such a statement! Maybe time to ask them to revisit their approach! Don't they know that if the organization 'owns' the QMS, the auditors will likely be more impressed than just 'knowing the words'...

JaimeB said:

Thank you, I appreciate it! Let me rephrasee my question. While the standard does not require those elements (mentioned above), is there a value add they offer that I'm missing? Her comment that registrars will look for certain verbiage in the procedure struck me, as everything I've read (here at the Cove) has been almost unanimous that procedures should be written for the organization, and the registrar/auditors will be familiar enough with the standard that they don't need you to "parrot" it.

Click to expand...

Procedures should be written to address your organizations processes; not a consultants or registrars preferences (which should not come in to play anyhow).

As far as adding value, that depends on your organization. A good time to evaluate this is during an internal audit in which specific procedures apply. You can determine the effectiveness/value and make revisions as necessary (continuous improvement).

Remember that the consultant works for you & your organization, they should be receptive to feedback and explain their perception/interpretation so that both sides are in common understanding. Not to generalize but often times consultants have a "cookie cutter" method that they apply. This is cost effective for them and will generally satisfy the basic requirements. However they may not address the specific needs of a given organization. As you stated, merely a regurgitation of the standard. Ok I guess if you just want a nice plaque on the wall....

Jason PCSwitches said:

Procedures should be written to address your organizations processes; not a consultants or registrars preferences (which should not come in to play anyhow).

Click to expand...

Totally agreed! In fact, if these consultants had thought about it, leaving out the standard terminology actually makes it easier for all to use!

AndyN said:

Totally agreed! In fact, if these consultants had thought about it, leaving out the standard terminology actually makes it easier for all to use!

Click to expand...

I think many consultants are more concerned with appeasing CB auditors than they are with helping their clients optimize things.

Jim Wynne said:

I think many consultants are more concerned with appeasing CB auditors than they are with helping their clients optimize things.

Click to expand...

Exactly!! The are only concerned about the ultimate goal - getting the organization certified. Beyond that they could care less. Sadly, often that's the organizations ultimate goal as well.

This is so counterproductive as the organization is satisfied because the agency did what they promised and implemented a system that achieved certification. In turn the agency gets paid and puts another notch on their belt. A good consultancy will not only do that but also implement a system that is appropriate for the organization.