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I'm always open to different ways to meet the requirements of the standard, but I'm struggling with how production records can be apporpriately used as records of education, training, skills, and experience. Can you elaborate?
Now, with that said..... In order for production records to be useful, they HAVE to be individual production records. Or as a minimum, able to be broken down by person. Aggregate records are okay, but only if there are no devations.
Hope that helps.