Specific ISO requirement to fill in all spaces on a move tag?

rstocum

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#1
I have a manager who tells me our registrar auditor will write non-conformances for tags that are not completely filled out. See attached picture. I admit the tag we use is not the best for the application. It is used as a move tag. The heading "Accepted" is unfortunate because it implies verification of conformance, which is not what the tag signifies for us. We are using it only to identify product in containers that are separate from the container that has the traveler in it, and product in storage locations in the shipping department. I am told that entries on the tag must have applicable information written down, or be filled in "N/A" or lined out, they cannot be left blank. This is meant to be an "ISO requirement". I'm not finding that requirement, and I have checked with iso.org to see if there is guidance about that for document control or identification & traceability. I have found nothing yet. Is this one of those things that isn't really a requirement, but auditors who have a bugaboo for it continue to write it up? I have the auditor coming in for the big yearly audit in 5 weeks and I'd hate to be caught up on this. Anyone have any insight?
 

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Golfman25

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#2
No such requirement. And probably a non-value added activity. If the info you have on the tag works for you, then fine, it works for you. A lot of of work around preprinted tags. If your manager really wants to worry about it, you could always get a blank tag and write the 4 pcs. of info on it. Good luck.
 

Sidney Vianna

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#4
Anyone have any insight?
Sure; this is as bogus as NC's for records filled in pencil, rather than pen, CB not being in the approved vendor list, every management position having to have a designated deputy, etc...over the years, countless, valueless types of NC's have been "developed" by auditors that have no idea of what they are doing.

If I were you, I would not lose sleep over this, because, as you inferred, there is no requirement in the standard that forces anyone to fill out each and every field of each and every form available in the system. At the time this type of bogus NC was being written up, auditors attempted to make a case that records were incomplete...
 

Pjservan

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#5
There is no such requirement. The auditor can claim that the tag information is incomplete and how will you know if it was missed or left balnk on purpose. It sounds to me that your are consistently using the 4 fields that you need, if you show that, then you have a solid defense. It needs to make sense to your business. Some I have seen and define the minimal "information" requirement as part of their procedure/work instruction, which is ok but not a must.
 

Marc

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#10
What I have found over the years is when coming across such a form/tag/job ticket/etc. with blank places, it raises a red flag. As long as an auditor can ask an employee when and how they fill out the form/record, and the employee can explain what s/he fills out of the form/record (their responsibilities with respect to the form), and can say how they know what information they are supposed to fill in, it's a non-issue and the auditor will (or should) move on.

Were it me, I would have its use documented somewhere just so it is clear to an auditor and to employees.

It is definitely OK to use a pre-printed form/tag because of costs. But like I say, especially for 'standard' forms/tags, any auditor worth his/her salt is going to have a flag go up when they see one that isn't completed, and ask for an explanation. It's another case of simply being able to explain why specific fields on the form/tag are not filled in. All employees that use such a form/tag (even those which are 'special print' forms/tags) is what information they are responsible for entering. They don't have to know why there are blank spaces, but someone in the organization does have to be ready to explain (typically the form/tag 'owner').

And remember, a tag like this is technically a record, even if it is an interim 'record' and is thrown away at the next step in your system. Such a tag is an indicator of the status of what it is placed on. That is to say, you are using it for a purpose. If it wasn't necessary in your system you wouldn't be using such a tag.
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EDITED for clarity and minor content addition.
 
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