As Appropriate -and- Shall - The importance of verbiage

[TheOtherMe]

As Appropriate -and- Shall

Subject: Recent audit
Date: Wed, 25 Aug 1999 15:39:34 -0700
From: "D, John"

We recently had a pre-assessment audit for QS-9000. In reviewing our
procedures, Level II documents, the auditor objected to our use of the
words " as appropriate" and "shall" as copying directly from of the QS-9000
3rd edition manual. As an example in the procedure 4.4 Design Control was
the following statement:

The suppliers design activity should be qualified in the following skills as
appropriate:

Geometric Dimensioning and Tolerancing
Quality Function Deployment

and so on.

The auditor felt that using this verbiage did not adequately tell the who,
what or where of the procedure.

The rest of the document he felt was well written.

The question is, did the auditor make the correct judgement on the validity
of that statement? If so, what would be a more appropriate way of wording
that phrase.


Thank you

John D.

 

[TheOtherMe]

I am a believer in taking the ISO or QS (section 1 of QS) text file and 'tailoring it' to a company.

You get rid of every shall. Shall means you will but implies the future. instead of "Company X shall have documented procedures....", word it to say "Company X has documented procedures...."

Where you use "As Appropriate" - well, you have to be carreful. In the 'laundry list' example, you would get rid of the As Appropriate and state the skills the company personnel it is aimed at (design here, of course).

On the other hand your quality manual may carry a statement like: "Company X performs design validation as appropriate for the specific contract requirements. Even here - it's dicy using the words As Appropriate anywhere. You best be ready to explain what is appropriate and what is not and where the distinction (what is appropriate and what is not appropriate) is defined anywhere.

Instead of your "The suppliers design activity should be qualified in the following skills as appropriate:", word it to say: "Company X's design engineering department has personnel qualified in the following skills:" and then list the skills. It's supposed to be your company quality manual so saying "...should..." is really pretty far off the idea, it being your company manual and all that.

The auditor has some points, but then again, a lot has to do with how you explain everything.

 

[barb butrym]

Not only be ready to defend it, but EVERYONE intervierwed "shall" give the same scenarios of when it is appropriate ...must safer to add a little guideance there.

 

[B. Maynard]

How about "If applicable"
That is what I use.

 

[Batman]

I have been told by several QS consultants from a couple of different companies that using "as appropriate" and "if applicable" and statements like that was OK, as long as somewhere else it was stated when it was appropriate or applicable. These are usually found in a Level I generic quality manual.

Example - Level I states XYZ company uses statistical techniques where (or when) appropriate.
Auditor is lead to an area where a work instruction states applying [a form of] SPC to set-up approvals.
In Purchasing, the auditor sees Pareto charts used to prioritize supplier performance issues.

On the other hand, I have seen "as appropriate" written to avoid specifying good practices in procedures. This usually leads to interpretations, and we all know what that means...

 

[Marc]

You best be ready to explain what is appropriate and what is not and where the distinction (what is appropriate and what is not appropriate) is defined...

My point exactly.

 

[Sam]

IMO, Always write in the present or the past tense, define when applicable and appropriate and keep in mind that OQE is the result to satisfy the question.

 

[Marc]

I agree. Proper english is important. The future tense typically isn't appropriate for a company manual or related documents.