Control of Records Definition - Controls needed and the 'disposition' of records

[DAHSR]

What is meant by "A documented procedure shall be established to define the controls needed for the ...and the disposition of records"? Do I need to define the manner of disposition?

[Neil]

Hi Dashr, you have to define in writing who is responsible for each quality record, who approves them, how they are organized, where they are stored, how they are protected, how long are they retained and who/how the are destroyed or permanently archived. The way I usually do this is through an excel spreadsheet with a lot of columns (master list). My company is pretty decent sized so I send out a record keeper specific summary of the master form list each year by email to get confirmation from each record keeper that the storage and retention information is still valid for every record. There are computer software programs that will manage your documents and records but to me they are an unnecessary expense. MS office and pdf writer do everything I need them to do. You will need a small procedure to explain how this all works. Don't forget to include the electronic only records. In my internal audits at other sites in the organization I'm writing a lot of CARs about access, protection, password, virus, read/write, cut/paste, local hardrive only etc. issues with electronic records.

[Wes Bucey]

Originally Posted by DAHSR

What is meant by "A documented procedure shall be established to define the controls needed for the ...and the disposition of records"? Do I need to define the manner of disposition?

I think you may be a bit over-concerned about the ambiguous term "disposition."
As used in the Standard, the writers used a legitimate term to mean two things (out of 4 possible meanings for "disposition" - I blanked the non-pertinent ones):

1. Arrangement, positioning, or distribution: <CITE>a cheerful disposition of colors and textures; a convoy oriented into a north-south disposition.</CITE>
2. A final settlement: <CITE>disposition of the deceased's property.</CITE>

So, part of "disposition" is the task of sorting, storing, transmitting, retrieving, modifying, retention, AND "DISPOSAL" (also an ambiguous term, here we mean DESTRUCTION.)

The problem of literal translation of English words is that some folks who write are just clueless about "connotation" versus "denotation." I have often scratched my head over word usage in various Standards.

(This is pretty much why most folks say "I talked with Mary." instead of, "I had intercourse with Mary.")

[DAHSR]

Originally Posted by Wes Bucey

I think you may be a bit over-concerned about the ambiguous term "disposition."
As used in the Standard, the writers used a legitimate term to mean two things (out of 4 possible meanings for "disposition" - I blanked the non-pertinent ones):

1. Arrangement, positioning, or distribution: <CITE>a cheerful disposition of colors and textures; a convoy oriented into a north-south disposition.</CITE>
2. A final settlement: <CITE>disposition of the deceased's property.</CITE>

So, part of "disposition" is the task of sorting, storing, transmitting, retrieving, modifying, retention, AND "DISPOSAL" (also an ambiguous term, here we mean DESTRUCTION.)

The problem of literal translation of English words is that some folks who write are just clueless about "connotation" versus "denotation." I have often scratched my head over word usage in various Standards.

(This is pretty much why most folks say "I talked with Mary." instead of, "I had intercourse with Mary.")

Thank you Wes. I realize I may be over-concerened about the word "disposition". I am trying to answer a corrective action from an AS9100 audit where the observed nonconformity is "the procedure doesn't include the manner of disposition". Shall I interpret "disposition" as "disposal" or "destruction" in this situation and specify the method of disposal?

Sincerely,
Doug

[Wes Bucey]

Originally Posted by DAHSR

Thank you Wes. I realize I may be over-concerened about the word "disposition". I am trying to answer a corrective action from an AS9100 audit where the observed nonconformity is "the procedure doesn't include the manner of disposition". Shall I interpret "disposition" as "disposal" or "destruction" in this situation and specify the method of disposal?

Sincerely,
Doug

I don't have a clue what is in the writer's mind. Ask for a clarification. If they mean ONLY "destruction when documents or products have reached the end of their useful life" - then tell them what you do about that.

Think of this as a cross-examination. DO NOT ALLOW ANYONE TO GET AWAY WITH SLOPPY LANGUAGE AND THEN HOLD YOU ACCOUNTABLE FOR THEIR INABILITY TO MAKE THEMSELVES UNDERSTOOD! Keep asking THEM questions until you are absolutely satisfied you understand what they mean.

[Claes Gefvenberg]

Originally Posted by DAHSR

Shall I interpret "disposition" as "disposal" or "destruction" in this situation and specify the method of disposal?

Sincerely,
Doug

Like Wes I interpret this to mean disposal (but I could be wrong - It has happened before) If it is disposal we are talking about I suggest a look in the following threads:

Identification of Quality Records (9K:2K - 4.2.4) - How?
Trigger Point - Determining When We Can Dispose of Quality Records

/Claes

Originally Posted by Wes Bucey

DO NOT ALLOW ANYONE TO GET AWAY WITH SLOPPY LANGUAGE AND THEN HOLD YOU ACCOUNTABLE FOR THEIR INABILITY TO MAKE THEMSELVES UNDERSTOOD! Keep asking THEM questions until you are absolutely satisfied you understand what they mean.