Absence of Inspection Status Labels on Skids of Paint Pails

J

joshubob

The guide of my company is preparing for the third party audit, he got into a heated argument with the warehouse clerk over the absence of inspection status labels on skids of paint pails being stored on the racks. The warehouse clerk claims labeling is not necessary because the racks are a designated area for the paint pails to be kept until inspected and approved by the inspection department.Will the third party auditor will raise any NCR if the inspection status labels are absent?
 

Jen Kirley

Quality and Auditing Expert
Leader
Admin
Re: inspection status labels

Good day joshubob,

This is a good question and the answer is a maddening "It depends." To begin to arrive to an answer, I have some questions.

What standard do you certify to? Requirements vary.

In what manner is the storage area identified?

In what manner is the segregation accomplished?

Does your customer require anything specific in this subject?

What does your quality manual/procedure say?
 
J

joshubob

Re: inspection status labels

Hello Jenny,
Answers for your questions
What standard do you certify to? Requirements vary.Ans :ISO 9001:2008

In what manner is the storage area identified? Ans : High rack storage areas with ID points

In what manner is the segregation accomplished? Ans : Hazardous & non-hazardous

Does your customer require anything specific in this subject? .......

What does your quality manual/procedure say? Nothing mentioned regarding this
 

Jen Kirley

Quality and Auditing Expert
Leader
Admin
OK thank you for these clarifications. Here goes our trek into the land of "It depends:"

1) 7.5.3 states the organization shall identify the product status by suitable means throughout Product Realization.

The clause goes further in stating "Where traceability is a requirement, the organization shall control the unique identification of the product and maintain records." This clause relies on the need to identify product status having been stated by someone; since ISO 9001:2008 does not specifically prescribe the requirement, logically the requirement's specification should come from you or your customer.

2) 7.5.4 refers to customer supplied property. I failed to ask if this paint is supplied by the customer for your processing. If it is, this clause says we will safeguard that property, which means identify and verify and protect. "Identify" arguably means status as well as identity.

3) 7.5.5 refers to preservation, and it specifies identification as well as handling and storage & protection.

These traceability clauses strongly infer that product and its status is controlled and identifiable. That doesn't mean we have to put it in a vault and prop a flashing billboard by the stuff; we should do that which is appropriate for our processes. Systems that have a barcode stuck to each item and a computer software application that tracks each item's identity and status will arguably not need to be otherwise identified if that barcode must be scanned when introducing the material into the production stream.

What I am trying to say is that means of identification vary, and the standard gives us some freedom to define what that identification is to be, based on the process flow and control plan.

The means to identify then become the subject. If this material was routinely (and as defined by written procedure) set aside in a clearly marked and wholly segregated place (some people use a locked "cage") and the process flow plainly showed its movement to a "ready to use" status included being physically moved to another specified location, one might argue that individual markings are not needed. The argument becomes one of overall identification schemes and reliable, procedurally set control.

So, having established that identification is required, what we're dealing with is details: how you have developed and maintained a system that is defensible by design and empirical results (no accidental introduction of inadequate material that, as it turns out, should have been in evaluation status).

Does this make sense? I'm afraid my response was awfully wordy.
 
V

vanputten

I believe (not 100% sure) that is is acceptable within ISO 9001 to indicate product status by position (location.) Some automotive customers require product status by position and label.
 

somashekar

Leader
Admin
The warehouse clerk claims labeling is not necessary because the racks are a designated area for the paint pails to be kept until inspected and approved by the inspection department.
The warehouse clerk is perhaps right, per the 7.5.3 requirement.
You have been given a great handholding by Jennifer who is so much helpful always.
Now how are they designated area ?
Do you have a board, a hanging placard, the designated area clearly marked out (preferably cordoned) for this, which says "awaiting inspection" ?
This meets your requirement and the skid identification is not necessary though it can be one of the method of identification. If that skid is moved out for an other use, then a problem of wrong identification is unknowingly created.
 
J

joshubob

Mr.Shekar,
Thanks for your reply. the area is clearly marked for this but it does not say awaiting inspection.I too agree skid identification not necessary.
 

somashekar

Leader
Admin
Mr.Shekar,
Thanks for your reply. the area is clearly marked for this but it does not say awaiting inspection.I too agree skid identification not necessary.
I used that word "awaiting inspection" because there is a need to identify the product status with respect to monitoring and measurement requirements.
 
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