Q: During a recent audit, I discovered that my supplier was using correction fluid and scrubbing out the training records of its employees with no control over the documents. I said that would be a major finding, but they state that there is nothing in ISO/ANSI/ASQ 9001:2008 Quality management systems–Requirements specifically telling them that they can’t correct records on the fly without any control. Can you clarify this practice for me? I can’t find anything definitive in the standard.
A: This is an interesting question. Sometimes, people complicate standards rather than recognize them for the friendly guides they can be. It is true, as written in clause 6.2.2 of ISO 9001:2008, that records for education, training, skills and experience need to be maintained per clause 4.2.2. However, the standard does not designate a specific process for this.
Clause 4.2.4 expresses a requirement to establish a documented procedure, and also states that the records should be legible. While the practice of using correction fluid or scrubbing out training records is probably not the best and most professional way of handling things, it’s not a cause for a finding of nonconformance.
Records which have a direct affect on customer products would definitely need better controls. However, I think in this case, you might find it wise to work with the supplier to find a better way of recording employee training. The records must remain legible, readily identifiable and retrievable. If that is what they are doing and product quality is not affected, there should be no major finding. A recommendation for continual improvement would be appropriate.
I hope this helps.
Voting member of the U.S. TAG to ISO/TC 176
ASQ Senior Member, CQT, CQI
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