Can you use pencil to sign documents, fill out forms, etc?

[Bev D]

Warning: Rant


"using pencil will lead to an automatic finding" is the crux of the issue.
Too many people get caught up in the 'tyranny of the trivial'. Almost all records don't require the 'pen only' level of safeguarding a signature or a data record. But too many Bureaucrats can't distinguish bewteen the important and the unimportant, except that the unimportant is easy to 'control' thru blind adherance to a rule. An auditor who tells you this is giving you a great big red flag that he will concentrate only on the trivial - he and the controls necessarry to satisfy his illogical needs will suck the life out of your organization and sour your leadership from supporting anything that even associates with your 'QMS'.

...not that I've had any expereince with this or anything.

 

[Sidney Vianna]

As most, I think that consultants and auditors who make these all encompassing statements should have their competence seriously questioned. I myself have expressed twice (in my 10 years at The Cove) the stupidity of certain myths out there such as the one subject of this thread.

Having said that, in certain sectors, regulatory requirements do prohibit the use of regular pencil in certain types of records. For example, paragraphs 266 a and b of the FAA ORDER 8130.2F, change # 5 on Airworthiness Certification of Aircraft and Related Products, which stipulates:

a. This chapter describes the requirements for completion and processing of the various forms and certificates used for airworthiness certification. Information entered on these documents should be typewritten when possible. The use of pencil, erasures, strikeovers, etc., on airworthiness forms other than applications and Form 8050-72 is not permitted. Application forms may be corrected by the applicant or the FAA, provided the person making the changes initials beside the area of correction.

b. The signature of the ASI or designee on any FAA certificate or form must be made in permanent ink on the original and required copies. When the reverse side of the certificate is used, the statement “See Reverse Side” must be typed on the face of the certificate. Below the last line of information on a certificate, type the word “END” in the center of the page

 

[Wes Bucey]

As most, I think that consultants and auditors who make these all encompassing statements should have their competence seriously questioned. I myself have expressed twice (in my 10 years at The Cove) the stupidity of certain myths out there such as the one subject of this thread.

Having said that, in certain sectors, regulatory requirements do prohibit the use of regular pencil in certain types of records. For example, paragraphs 266 a and b of the FAA ORDER 8130.2F, change # 5 on Airworthiness Certification of Aircraft and Related Products, which stipulates:

Absolutely, Sidney. Most of us agree that strictures like those listed in your citations are acceptable because they are part of a written Standard or Regulation. We also seem to have majority concurrence that an auditee or student has the right [responsibility?] to question any statement made by auditor or "consultant" (that title is ridiculous for the character in OP's original comment if the OP is accurately reporting the event!) by simply asking for the written citation corroborating the auditor/consultant's statement/dictate/nonconformance report.

Alas, I have seen some of these pompous poseurs get all defensive and say bull feces like, "Who are you to question me!?"

Deming was right, FEAR still controls many organizations and woe unto the guy who points out the emperor's new clothes are nonexistent. Sadly, unlike the fable, the rest of the folks in a FEAR-ridden organization do not laugh at the naked idiot, but run for cover.

 

[Jim Wynne]

Absolutely, Sidney. Most of us agree that strictures like those listed in your citations are acceptable because they are part of a written Standard or Regulation. We also seem to have majority concurrence that an auditee or student has the right [responsibility?] to question any statement made by auditor or "consultant" (that title is ridiculous for the character in OP's original comment if the OP is accurately reporting the event!) by simply asking for the written citation corroborating the auditor/consultant's statement/dictate/nonconformance report.

Asking for the text won't help, because it's not the text that's at issue, it's the interpretation of it, or extrapolation of it beyond reasonable bounds.

Alas, I have seen some of these pompous poseurs get all defensive and say bull feces like, "Who are you to question me!?"

Although there's nothing in evidence to indicate that the person the OP refers to is pompous, a poseur, not deserving of the august title of "consultant," a creep, etc., etc., I've learned from experience that it's not a good idea to take someone to task in front of a group as it appears the OP did. Questioning a contention is fine, but if there's disagreement it should be discussed calmly one-on-one so that the person who is allegedly wrong isn't forced into a defensive position. Even at that, it might be to no avail, because as I've also learned, ideas that aren't rationally formed can't be refuted rationally.

 

[Wes Bucey]

Asking for the text won't help, because it's not the text that's at issue, it's the interpretation of it, or extrapolation of it beyond reasonable bounds.


Although there's nothing in evidence to indicate that the person the OP refers to is pompous, a poseur, not deserving of the august title of "consultant," a creep, etc., etc., I've learned from experience that it's not a good idea to take someone to task in front of a group as it appears the OP did. Questioning a contention is fine, but if there's disagreement it should be discussed calmly one-on-one so that the person who is allegedly wrong isn't forced into a defensive position. Even at that, it might be to no avail, because as I've also learned, ideas that aren't rationally formed can't be refuted rationally.

Yep. Very true that negotiations rarely go smoothly when one side opines openly about the competency/validity of the other side. I did not intend an interpretation of MY remarks to mean "burn bridges" - simply to confirm one's suspicions about the "fantasy" interpretation of the mission creep. Once those suspicions are confirmed (no rational basis for the interpretation), one opposing the mission creep can choose to escalate the issue to someone at a higher pay grade OR find cover and hide.

I further agree with the statement

Even at that, it might be to no avail, because as I've also learned, ideas that aren't rationally formed can't be refuted rationally.

Often, the folks creating mission creep have no rational excuse for the view. I think many readers are familiar with the excuses, "That's what I was taught." OR "We've always done it this way." with no "original source" available for comparison. The only solution for dealing with an irrational person is to get someone of higher authority (keep searching until you find a rational one) to deliver the "my way or the highway!" ultimatum. Without that authority it is simply

 

[lianayada]

My company's internal documentation specifies ink only, however, once I had someone fill in a form in pencil. I made a photocopy of it, stamped it "COPY", noted "Original was filled out in pencil and was destroyed", and tossed the original. That took care of anyone erasing it in the future.

These days I would scan it, retain the e-file, and toss the original. No one would ever know that pencil was used in the first place.

 

[Antonio Vieira]

I don't see why not...
Even in University I was allowed to make lots of exams (mainly mathematics) using a pencil.

 

[Ramrethan]

I guess it is a free country, so why make a big deal, but personally I would not use pencil..think before you ink...I guess..

 

[Junior Woodchuck]

Asking for the text won't help, because it's not the text that's at issue, it's the interpretation of it, or extrapolation of it beyond reasonable bounds.


Although there's nothing in evidence to indicate that the person the OP refers to is pompous, a poseur, not deserving of the august title of "consultant," a creep, etc., etc., I've learned from experience that it's not a good idea to take someone to task in front of a group as it appears the OP did. Questioning a contention is fine, but if there's disagreement it should be discussed calmly one-on-one so that the person who is allegedly wrong isn't forced into a defensive position.

Okay, these are all good points and I thank everyone for participating in this discussion. I do want address the two points brought up here.

1) I think I stated earlier that the question was actually part of a quiz the consultant gave our staff to see if they understood his presentation of the standards. So, I can get the exact question. I'll do that this week. It was formed as a T/F question, pretty straightforward.
2) I actually like the consultant, despite this disagreement. It was good to have someone visit our company and try to convince our management to adopt good ideas. The company needs this kind of advice and I'm usually alone in asking for certain changes. I'm sorry if I sounded like I thought he was terrible...he's not...but on this one point, I believe he was wrong and I believe he gave our management team the wrong idea. I tried to stop and point that out immediately, because it was a class...a question on a quiz...and in my experience it's better to correct mistakes immediately while everyone's still there and the topic is on the table. Remember, the purpose of this quiz and presentation was education on the standards. If you can't have a frank discussion about the correctness of statements made, you shouldn't be in a classroom environment.

 

[Junior Woodchuck]

It doesn't matter. If they are legible, identifiable & retrievable you can record data with finger-paint if you want as long as your procedures, customers or regulatory/statutory requirements don't state otherwise.

Smart....no, but there is "technically" no violation. Though I would ?? the organization that used finger-paint as a recording media....unless it was preschool.

This is exactly what I meant. I would not call using pencil smart, or a good practice, but nothing in our company policies prohibits pencil and we're not in any industry that has regulations regarding pencil. The discussion was strictly limited to the ISO 9001 standards. I asked for that clarification from him twice. Then when he said 4.2.4 was the clause that prohibited pencil use, I disagreed.