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.
Bud Salsbury
ASQ Senior Member, CQT, CQI
Good day,
with all due respect I disagree with your statement ” 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.” ; if somebody uses correction fluid to change something previously written in a training record without making clear his/her identity (which in turn is linked with her/his authorisation to do so) then this may be a serious issue. Imagine a situation where a quality inspector’s course needs to be repeated every six months (otherwise the inspector’s authorisation is suspended) and the date when the last course took place being corrected without any controlled (and transparent) procedure. In addition if we wait to have a quality issue in order to be/feel motivated to correct this situation then we may be faced with a very serious one (besides, the whole concept of preventive action seems to be neglected).
Kind regards
Nikolas Diamantaras
QMS Instructor
ASQ, CMQ/OE