It was simple...We had a procedure (which IS required...but we were TS..don't know about AS) that covered Document Control..there is nothing requiring that it be a process...
The fact that you have to have a Document Control procedure proves this is a process (by definition), not because of the lack of a “shall” within the Standard, as I am assuming your justification for:
there is nothing requiring that it be a process...
If you still don’t believe me, I stated earlier that processes depend on inputs and outputs to deliver intended results…well consider the following example sequence of events:
Document Control inputs: Change Request, Need for New Documents Identified
Document Control process applied: (reviews, gathering signatures, etc.)
Document Control outputs: Approved Change Request Record, Updated Documents, Updated Master List
Notwithstanding the required 6, not all processes have to be documented, but saying that a process you have documented is not a process is simply incorrect.
Brian


