SBS - The best value in QMS software

Do we have to document all corrections and corrective actions in ISO 9001 10.2.2 ?

Jen Kirley

Quality and Auditing Expert
Staff member
Admin
#11
Thanks Somashekar
In your answer
"Some will be fixed with a correction. This will be recorded as a part of the action to address the finding. This will close out. "
In this point .
In the case of simple correction, and this is a nonconformity with very low impact, ok, why to keep a record of the changes if is very very minor?
While a correction or corrective action with more impact, in this case, yes, to keep records, e.g. fishbone, action plans, effectiveness.
If someone ask you records about this ncs, you say there are only records of high impact nonconformities, whats your opinion?

Thanks Jim
According to your comments, my responses, after the yours,

  1. Nonconformity is identified and documented-- ok, they are in the audit report
  2. Nonconformity is reviewed in order to determine the extent of the correction/corrective action necessary; --- Ok, is reviewed in a meeting
  3. and is decided if apply correction or corrective actions, by using a spreadsheet to have an evidence of the revision, showing the ncs, and in an additional column to describe the action plan, also is used for the follow-up.
  4. Actions taken are documented and retained.-- in my case I have a special format to address correction and corrective actions, into it, I describe the problem what is the correction, date , responsible and closeout.
2 questions, in this last point, 1- Why to keep records of changes/modifications to whatever document if ncs are of very low importance?I think is enough to keep them in the audit report, and if someone asks you about records of changes , you may say, no records, only records of changes
are maintained for ncs with medium or high impact, dont you think like this?
and question 2- where you say "Actions taken" will also be a record, the spreadsheet I use for the follow-up, which is used to describe the actions taken to solve the ncs?
Thanks
Does your document control procedure include maintaining some type of history of changes to documents? If so, this practice should continue when the changes are made as part of corrective action.

10.2.2 is clear in its statement that documented information is to be retained as evidence of
a) nature of the nonconformities and and subsequent actions taken, and
b) the results of any corrective action

This requirement does not allow for no records retained, but also does not prescribe the type of record to be retained. A spreadsheet can work. I would not use this NC spreadsheet as a record of document change, however; I would do document changes according to existing process.
 
Elsmar Forum Sponsor

qualprod

Trusted Information Resource
#12
It doesn't matter how or when a nonconformity is identified insofar as subsequent actions taken are concerned.
Jim

Thanks for your patience, I think I´m not explaining very well my case, hope you have the time
to help me how to address this issue.
Maybe I´m wasting time in the management of nonconformities according to what you are feeding me back.
I´ll explain.
Lets say in an internal audit, several nonconformities were found, we have an audit report.
some ncs were great problems, e.g. NC 1, (the responsible didn´t perform the supplier evaluation), other nc,
not a big deal, NC 2 (a number of a document into a document was wrong, just need to be corrected).

From here, the next: I use a format called Corrective action request (CAR) , into it I describe each NC, the source, the responsible
, if I´m going to apply just a correction or a corrective action.
If it is a correction , case 2, Into the report I define the task of modifying the document, also include the responsible and due date, once the document with the nonconformity is corrected, I complete the nonconformity report, the responsibles sign off the CAR and is closed out.

if it needs a corrective action, I also use the CAR , I use ishikawa, do the analysis, define action plans with responsibles and due dates, once
action plans were finished, we ensure corrective action was effective.
If was effective, we close out the CAR, signing it off , we keep the CARs in a special folder in the internal network in pdf format.

Now talking about the term "documenting" whichis to have records of actions taken.

In the case 2 , I find useful to use the CAR, because into it is shown the corrective action number, contains the full analysis,
the responsibles, also the report is used for the follow-up of the corrective action, additionally the corrective action number is included in the Master list of Corrective Actions, in addition to the nonconformity report, into it will define action plans to create a document, to create a special report, etc. , so , they are also records.
So, in this case of CARs are the records of the nc,s found in the audit report additionally the tasks into the corrective action are records.

But in the case of just corrections, I think is a waste of time filling out the CAR, if I decide that for that nc, what I have to do is a
simple correction of a document , then, my record could be the evidences of revision and approval of that document, If I´m requested records about that nc, I can show the evidences of the approval of the document. or some other correction....BUT no to show the CAR
because was not needed, the NC didn´t deserve to fill out the CAR.
If I fill out the CAR for the nc´s type case 2 (not critical) I may be wasting time and efforts, the only benefit I see
maybe it is that I may have data of ncs. for analysis in an easy way, because If at some time I need to know how many corrections
and corrective actions have been performed, with my master list I can determine it quickly.

Hope I explained well, please feed me back.
 

skb76

Involved In Discussions
#13
all

as you mentioned , (and some answering earlier form this post ...)
Internal Audit (x need to fix minor or major)

p/s refer to the attached file (my guess your NC/CAR record will be professional rather than this attach file!)

my opinion;

if you want keep simplify, y wont keep it a single document/form) ...

based on the attached file ... in case like your nc2 (just 'fill few words') to 'close' the nc/car

(any feedback form others...)

thanks in advance!
 

Attachments

qualprod

Trusted Information Resource
#14
all

as you mentioned , (and some answering earlier form this post ...)
Internal Audit (x need to fix minor or major)

p/s refer to the attached file (my guess your NC/CAR record will be professional rather than this attach file!)

my opinion;

if you want keep simplify, y wont keep it a single document/form) ...

based on the attached file ... in case like your nc2 (just 'fill few words') to 'close' the nc/car

(any feedback form others...)

thanks in advance!
Thanks skb76
The form you shared is similar to the one I use, and us used for correction bc and corrective actions
My point is , for ncs (non critical, just corrections)don't want to fill out the form, just do the correction, thus , Saving time.
What is your opinion?
Thanks
 

Jim Wynne

Staff member
Admin
#15
But in the case of just corrections, I think is a waste of time filling out the CAR, if I decide that for that nc, what I have to do is a
simple correction of a document , then, my record could be the evidences of revision and approval of that document, If I´m requested records about that nc, I can show the evidences of the approval of the document. or some other correction....BUT no to show the CAR
because was not needed, the NC didn´t deserve to fill out the CAR.
How would you associate the correction with a particular NC report?
 

Kronos147

Trusted Information Resource
#16
some ncs were great problems, e.g. NC 1, (the responsible didn´t perform the supplier evaluation), other nc,
not a big deal, NC 2 (a number of a document into a document was wrong, just need to be corrected).
My point is , for ncs (non critical, just corrections)don't want to fill out the form, just do the correction, thus , Saving time.
What is your opinion?
Thanks
It's a slippery slope, IMO.

What are critical vs. non-critical?

If they are not logged, how do you recognize patters or recurrence?
 

John Broomfield

Staff member
Super Moderator
#17
Recording every error/process nonconformity strikes me as overkill...

...but it may reduce the detail in documented procedures to an absolute minimum.
 

Crusader

Trusted Information Resource
#18
I agree. every error does not require a CAR. My auditor recently did not agree totally. It blew his mind when we said that we determine when it's necessary and when it is not.
 

Jen Kirley

Quality and Auditing Expert
Staff member
Admin
#19
I agree. every error does not require a CAR. My auditor recently did not agree totally. It blew his mind when we said that we determine when it's necessary and when it is not.
I would be very interested in how you do that. Based on risk? The standard wants corrective actions for nonconforming outputs. When is an error not a nonconforming output?
 
Thread starter Similar threads Forum Replies Date
J How to document Corrections made to a Medical Device History File ISO 13485:2016 - Medical Device Quality Management Systems 1
J Requirement for Signature on Document Document Control Systems, Procedures, Forms and Templates 4
J Document Control Metrics Document Control Systems, Procedures, Forms and Templates 3
A Document Review and Document Approval --- 2 Signatures needed acc. §820.40? 21 CFR Part 820 - US FDA Quality System Regulations (QSR) 3
Sidney Vianna Interesting Discussion Should ISO 9004 be changed from a guidance document to a requirements standard? ISO 9000, ISO 9001, and ISO 9004 Quality Management Systems Standards 7
I Document Control Software Document Control Systems, Procedures, Forms and Templates 2
K 25-year lifetime of medical device - document storage period EU Medical Device Regulations 1
J UDI - Where to document it? EU Medical Device Regulations 8
T Controlling Expandable Forms in Paper-Based Document Control System Document Control Systems, Procedures, Forms and Templates 10
S Changing revision status of a reviewed document Manufacturing and Related Processes 4
shimonv Document Control Procedure Header Content Document Control Systems, Procedures, Forms and Templates 3
A Document release vs its related training. Which should come first? ISO 13485:2016 - Medical Device Quality Management Systems 18
Q Document ownerships Document Control Systems, Procedures, Forms and Templates 14
E Document Change Request forms (or no forms)? ISO 13485:2016 - Medical Device Quality Management Systems 9
O Any info on release date of FDA “Computer Software Assurance for Manufacturing and Quality System Software” document? 21 CFR Part 820 - US FDA Quality System Regulations (QSR) 0
B Document Approval Matrix Benchmarking Document Control Systems, Procedures, Forms and Templates 3
J Document Approval Signature Order Document Control Systems, Procedures, Forms and Templates 10
L How to add exemption or statement to control of document procedure? ISO 13485:2016 - Medical Device Quality Management Systems 5
M What is the proper way to document measurements Measurement Uncertainty (MU) 1
P Equipment 21 CFR 820.70(g) - User Requirements Document for Off the shelf equipment 21 CFR Part 820 - US FDA Quality System Regulations (QSR) 7
B Do IFU designs have to be document controlled under ISO 13485? Document Control Systems, Procedures, Forms and Templates 2
C Certificate of Conformance Form - COC for each customer a controlled document? ISO 9000, ISO 9001, and ISO 9004 Quality Management Systems Standards 2
A Document "Correspondence IATF 16949 vs ISO13485" available? IATF 16949 - Automotive Quality Systems Standard 0
R Document Retention - Discard hard-copies after scanning? ISO 13485:2016 - Medical Device Quality Management Systems 2
P Mylar plot suppliers in accordance with D6-51991 document AS9100, IAQG, NADCAP and Aerospace related Standards and Requirements 4
A Document Change Notice vs complete System re-write Manufacturing and Related Processes 4
Q Document approval through SharePoint (without signature) Records and Data - Quality, Legal and Other Evidence 4
S What is considered a "core algorithm"? (From an FDA guidance document) Medical Information Technology, Medical Software and Health Informatics 4
U Document Approval - Software company ISO 9000, ISO 9001, and ISO 9004 Quality Management Systems Standards 3
O Please, help with document on ISO/ TS 17758 and (IDF 87: 1979). Thank you. Manufacturing and Related Processes 1
K Proper document of SMPS used in infant warmer for IEC 60601-1 testing IEC 60601 - Medical Electrical Equipment Safety Standards Series 1
I Nitpicking on document released dates ISO 9000, ISO 9001, and ISO 9004 Quality Management Systems Standards 2
I Document Control on Log Files ISO 9000, ISO 9001, and ISO 9004 Quality Management Systems Standards 6
Q Refusal to Document Complaints Customer Complaints 39
Q Tracking Procedure Revisions (Document Control) Document Control Systems, Procedures, Forms and Templates 9
C Document Control Stamps - Does anyone still stamp their documents? Document Control Systems, Procedures, Forms and Templates 24
I Master Document Access - ISO 9001:2015 clause 7.5.3 Document Control Systems, Procedures, Forms and Templates 5
I Can a document (form) approval record be separate? ISO 9000, ISO 9001, and ISO 9004 Quality Management Systems Standards 6
I Control of Documentation Distribution - Document Control ISO 9000, ISO 9001, and ISO 9004 Quality Management Systems Standards 2
T Advice needed - Environmental MS - unwritten but customer requests policy document ISO 14001:2015 Specific Discussions 5
T Control of downloaded document copies by employees Document Control Systems, Procedures, Forms and Templates 3
T Document control ISO 13485:2016 ISO 13485:2016 - Medical Device Quality Management Systems 5
I Is highlighting on a printed document considered a change? ISO 9000, ISO 9001, and ISO 9004 Quality Management Systems Standards 4
C QMS Document Management Software Recommendations Quality Assurance and Compliance Software Tools and Solutions 14
E Part 11 Compliance, Excel living documents (i.e. document master list, equipment list, approved supplier list) Pharmaceuticals (21 CFR Part 210, 21 CFR Part 211 and related Regulations) 3
Sidney Vianna Informational New IAQG Document - AS9100 Clarifications of Intent AS9100, IAQG, NADCAP and Aerospace related Standards and Requirements 3
S How to determine & document Organizational Knowledge of a company Document Control Systems, Procedures, Forms and Templates 4
D Are medical device companies required to document every change made to their website? Document Control Systems, Procedures, Forms and Templates 2
M Informational IMDRF draft document – Principles and Practices for Medical Device Cybersecurity Medical Device and FDA Regulations and Standards News 0
M Nonconformity for missing form number on the job description document Nonconformance and Corrective Action 1

Similar threads

Top Bottom