Control numbers for records

[Tyler C]

Hey everyone,

I have a question about control numbers for records, and it may be a stupid question so bare with me. Something my auditor said triggered this question, and I couldn't find anything in the standard, nor any other thread here.

So, I will just ask. Do record's need control numbers?

My auditor told me, for example, the control number of a form controls the structure of the form, not the info on it, and the info on it becomes a record. Since most forms become records, is the control number of the form then the control number of the record? Or, is it still the control number of the form only, and the record doesn't have a control number? If the control number of the form does become the control number of the record, is it okay to be the same number, or does the fact that it is now a record constitute a new control number?

This seems like it should be a clear, easy answer, but I cannot figure it out. Any help would be greatly appreciated.

 

[Marc]

I think there is a definition issue here. Forms are typically controlled documents. Thus, most forms have a number or other identifying aspect. It could be the name of the form its self. Then again, typically forms need revision control (remember, prior to having data entered it is essentially a document).

This is different than a record which is a form which has been completed. The form number will be different than the record number. Think of it this way - Some restaurants give the wait staff a pad of order blanks. Most have a sequential number on each slip in the pad so at the end of the shift/day they can reconcile each order taken. That said, I rarely eat out, but I do watch a lot of old movies, so I really don't know how they handle this stuff these days. I'm sure it depends upon how automated/electronic the restaurant is.

So - I *assume* that by "control" number the auditor was meaning the form should have revision control and that the form number and revision level should be printed on the form. Each record its self would have the form number and revision as well as an additional number to identify the specific record.

 

[Ninja]

Take a look through this forum regarding control of forms as well.....there is a lively debate on that one as well....

fwiw, we do not "document control" records at all...we retain them. Most forms are also not controlled, though some are...

 

[Marc]

Agreed, but we come to definitions. I agree "document control" isn't typically applied to records. Then again, the term "document" is a wide brush. A record can be classified as a type of document. We just normally don't think of it that way.

E.g. from Google:

noun

doc·u·ment: document; plural noun: documents
ˈdäkyəmənt/

1. A piece of written, printed, or electronic matter that provides information or evidence or that serves as an official record.

Synonyms: official paper, legal paper, certificate, deed, contract, legal agreement;​

Many industries require control of records and the more regulated the industry, the more significant control of records becomes (also see "traceability"). A company may "retain" records, but as I have pointed out in highly regulated industries record retention and traceability of various records is often a legal and/or regulatory requirement.

The same is true of forms - What form(s) are or are not controlled depends upon the industry and the product.

That is why we discuss these issues here and try to get as much information from the original poster as we can so that we can address their specific scenario. Making wood screws for general use, for example, a company will have a significant leeway in what documents are controlled, what records are retained and such. Aerospace, drugs, medical devices and food are examples of industries in which legal and regulatory requirements for what documents have to be controlled, what records have to be not only retained (not to mention their retention time), but also "controlled" (traceability) come into play.

 

[Tyler C]

Excellent discussion. I don't feel so stupid for asking the question anymore. On my forms, I do have the revision history along with the rev level and control number, but I don't have a system for a new control # on records once the form is complete. That is my main concern, we will have blank forms and completed records with the same exact control number and rev level.

I do also agree with Ninja that it almost seems silly to control records because a record shouldn't be edited. Once it is filled out and complete, that is the record. So, there won't be any future revisions on the completed record, just the blank form document.

But, after looking back at the standard, it seems records shall be controlled just as documents are (this is why I need help, I just keep talking myself in circles...).

 

[QAMTY]

We manage this issue in this way:
The form has its document name, e.g for-plant-001, when we change something on the form ,we update the revision,e.g.to 01.
When this form is filled up, it becomes in a record, suppose you use it twice a day to check an equipment in a plant,in the morning and at night,well you take such form,and is filled up,and when you save/store it,it is save like this, for-plant-01 morning checking,and the other, for-plan-Night checking, that way both are identified.
You can use any method for the numbering.

 

[Marc]

... I do also agree with Ninja that it almost seems silly to control records because a record shouldn't be edited. Once it is filled out and complete, that is the record. So, there won't be any future revisions on the completed record, just the blank form document...

In an ideal world.

First, again, it depends upon the importance of the record(s) as well as statutory, regulatory, and/or legal aspects of the business/industry/product.

Second, and most importantly, people do change records. Sometimes it is minor changes on insignificant records. An example - Written time cards. Other times it is to cover up activities (another example). If you remember the Value-Jet crash, it was determined that oxygen generators were incorrectly labeled and after the cause was determined the people who were supposed to have checked them went back and falsified (changed) their entries. This was determined by forensic analysis of the records.

Another very common aspect is incomplete records which are completed "after the fact" with what is often false information.

And, sometimes a problem of one kind or another is identified and a record is legitimately changed. When I worked in DoD and regulated industries there was the "One Line Through" rule, where a change to a record was allowed providing no entry was made illegible ("One Line Through") and that the change was initialed and dated by the person making the change. I have been in many companies where "white-out" was prohibited on the premises - Period.

After about 30 years of working with various businesses in quite a few different industries I have seen so many changed (and in many cases incomplete) records, for so many different reasons, sometimes benign, sometimes dangerous, that I would never assume a record is always completed and that's it - That it never changes. Whether it is significant or not depends upon the specific scenario. In some companies, even telephone call records are considered important enough to keep.

Just my

 

[hogheavenfarm]

We do not 'redesignate' any form numbers, we just file them for traceability. My GIT-001 form (General Inspection and Test) is a calibration form for calipers. It has a number (GIT-001) and a revision date and level. Thats all it will ever have, even when filled out and retained as a record, it is just filed with the appropriate instrument number. Job records(forms) are filed in the job numbers, and so on. No need to over complicate it.

 

[Kronos147]

As I re-write procedures for our AS9100 Rev. D transition, I added a statement to our "Control of Documented Information" procedure that it is the format, not the content, that we control.

Yes, and we retain the completed documented information as evidence of conformance.

 

[Tyler C]

Excellent points Marc. I hadn't thought of that, but now I do realize that there are times records are changed. I guess I was living in an ideal world like you said.

I do like the strikethrough and initial process. We use this method as well for things like the time cards and it works sufficiently.

Thank you everyone for your input. I have buckled down and just included the control numbers for our records because that is what our record control procedure says. You have all given me great insight for the next revision though!