Auditor States "Shall have Procedure for Disposition of Records"

[Joe Cruse]

Re: Auditor States 'shall have procedure for disposition of records"

We went through a bit of this a while back also. The concern was that we might have records on file that were past the retention time of the "quality record". It was also noted that the owner might want to keep the record when its retention time as a "quality record" was up. An auditor suggested moving them to a new file, if they were not going to dispose of them. They would then be an "archive record" and no longer subject to the qms or the standard.

Not a bad idea, but the auditor wanted us to go through and physically move records out to new file cabinets marked out for "archive" files.

Instead, I email all document owners (small company) on a quarterly basis and remind them to look at their file records for documents that are now past the stated retention times. If the owner no longer needs them, dispose of in the most convenient fashion available (usually means toss 'em in one of the furnaces). If the owner wishes to keep them, then they are no longer considered as part of the qms.

The auditor has been through this one twice now, and had no issues with it.

 

[Holly21cn - 2009]

Dear all,

I do need some advice about the disposition of record. We do have defined the disposition of record in procedure but auditor need us to provide the evidence of dispositon. It means that we have to make a record of disposition to state that we have disposed the record. Urgently need your advice.


Thanks a lot.

Holly

 

[AndyN]

It means that we have to make a record of disposition to state that we have disposed the record. Urgently need your advice.


Thanks a lot.

Holly

Buy a trash can, put the auditors name on it and fill it with records! Keep them just for him

Alternatively:

He's nuts, tell him to get a life, it's not a requirement and if he continues to pursue this kind of silliness, you'll ban him from your business and ask for a different auditor - seriously!

Andy

 

[Holly21cn - 2009]

Andy,

Thanks a lot! I fully agree with you and I do think the auditor missed the spirit of ISO standard. The same auditor puts me in aonther situation that we can't fight back and thus recieve a nonconfomity.

We define in our document control procedure" Except the controlled document issued in our intranet, any other softcopy document or any hardcopy document without the stamp of “CONTROLLED COPY” is considered as uncontrolled document. The uncontrolled document is for reference only, can’t be final authority. " Auditor challenge that if we can ensure the user not to use the "uncontrolled" copy for final reference and we said we couldn't. So a nonconformity is issued to us for we can not ensure the user not to use the "uncontrolled" copy for final reference. I have no word.......

Need your advice and we are requested to fill in the CAR.

Thanks a lot .

Holly

 

[Sidney Vianna]

I do need some advice about the disposition of record. Holly

Sorry Holly, but I think you need advice on how to dispose of your auditor, instead....

 

[Wes Bucey]

Dear all,

I do need some advice about the disposition of record. We do have defined the disposition of record in procedure but auditor need us to provide the evidence of dispositon. It means that we have to make a record of disposition to state that we have disposed the record. Urgently need your advice.


Thanks a lot.

Holly

We've discussed the need for an understanding that "disposition" does NOT mean "disposal" or "destruction."

If your auditor means "disposition" (meaning how you manage your documents for retention AND disposal), then you owe him a "process" for how you make decisions about retention and disposal PLUS records (for as long as they are retained) about the actions taken to do those things.

Disposal or destruction records could be as simple as a log, with a brief description of the destroyed documents and an initialed affidavit of the destruction. In fact, the Federal Aviation Administration (FAA) demands such proof of the destruction of nonconforming material to assure it does not find its way into an aircraft by "backdoor" means.

 

[Sidney Vianna]

Auditor challenge that if we can ensure the user not to use the "uncontrolled" copy for final reference and we said we couldn't. So a nonconformity is issued to us for we can not ensure the user not to use the "uncontrolled" copy for final reference. I have no word.......

Need your advice and we are requested to fill in the CAR.

There is a presumption of innocence, until you are PROVEN guilty. The burden is on the auditor to find EVIDENCE of an OBSOLETE or INADEQUATE REVISION document BEING USED. S/he CAN NOT give you a non-conformity for a hypothetical scenario with no evidence of that happening. Can you "ensure" that someone would not use a gauge with an expired calibration date? Could you ensure that an operator would not operate a machine outside of validate parameters? NO! Unless s/he has OBJECTIVE EVIDENCE of a requirement being violated, s/he can NOT WRITE you up. It is that simple! You must NOT, I repeat, you shall NOT accept this non-conformity.

BTW, why do people rely on stamps to "designate" controlled documents? Another archaic, prehistoric, legacy garbage of antiquated dysfunctional quality systems that just consumes resources without adding any value to the process...Please think out of the "stamps" box

 

[Randy]

Evidence of disposition?

Show the dips&it an empty folder or file cabinet.

A pile of shredded paper might be "evidence" as well.

 

[Wes Bucey]

There is a presumption of innocence, until you are PROVEN guilty. The burden is on the auditor to find EVIDENCE of an OBSOLETE or INADEQUATE REVISION document BEING USED. S/he CAN NOT give you a non-conformity for a hypothetical scenario with no evidence of that happening. This auditor of yours is quite something....

BTW, why do people rely on stamps to "designate" controlled documents? Another archaic, prehistoric, legacy garbage of antiquated dysfunctional quality systems that just consumes resources without adding any value to the process...Please think out of the "stamps" box

The idea about thinking out of the box is a valuable addition to this discourse.

I think it is important to always use the yardstick "How will this action benefit me, my organization, my employees, my customers, and my suppliers?" BEFORE thinking about Standards and auditors.

 

[DI Foundry - 2010]

Holly - You have every right to appeal the finding/non-conformity, this auditor is giving opinions not facts/requirements of the standard. I agree with others to request this auditor does not audit your facility again.