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> We are a US toilet seat manufacturer who is preparing for the French
> Marque NF240 certification. A quality consultant advised us to retain
> permanently records of materials that we scrap as a result of quality
> checks. In reading the two sections related to retention of records 2.5.4used the word "permanent" and
> 2.11 says a "suitable period of time". I realize there are probably few
> seat manufacturers out there but I hope there is someone who has experienced
> the frustration of interpreting what permanent means and would be willing to
> share it.
>
> 2.5.4 Records of checks and tests
>
> The manufacturer must draw up and keep permanently records that prove that
> the products have undergone checks and/or tests according to the defined
> acceptance criteria (see 2.11).
>
> 2.11 Records relating to the quality of the finished product
>
> The manufacturer must update the appropriate records of checks and tests
> to prove compliance with the specified requirements. Records relating to the
> quality of the finished product must be legible and identifiable vis-à-vis
> the relevant product. Records relating to quality, which justify compliance
> with the specified requirements must be kept for a suitable period and be
> available on request.
>
My qualified response would be that any manufactured product has a warranty
period, and also that models do go out of date and are periodically
replaced.
If I had to respond to "suitable period of time" I would suggest that would
include the last date of manufacture (or sale) of any given model plus the
assigned warranty period. Once that has been achieved, the item is no
longer available and there is no outstanding warranty on it, and if it were
to fail in use, there would seem to be limited liability.
I have a problem with this circular reference though, why would 2.11 say
suitable period of time, then 2.5.4 (which comes earlier in the schedule)
say "see 2.11" and assign a period of permanent retention?
Do sections 2.5 and 2.11 cover different areas/aspects of your business ,
such as one beig "Safety" and one being "manufacturing" or "QA"?
Larry
--
Larry Medina
Danville, CA
RIM Professional since 1972
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