Product Identification and Traceability

A really interesting sub clause.  Finally I hear you read.  Well it is super interesting if it is part of your contractual agreements.  If not, it will be just another ho hum.  The standard wants you to consider the following.  And when I say consider, I mean have a response in a quality manual, have operational procedures if they are applicable or at least have a review point, say annually in management review or as part of planning for realisation reviews. 

So here goes.  7.5.3 Identification and traceability; where appropriate, my company name identifies the product by suitable means throughout product realisation.  My company name identifies the product status with respect to monitoring and measurement requirements.  Where traceability is a requirement, my company name controls and records the unique identification of the product.

I know, I know.  Too easy.  Well as always it is a bit ‘horses for courses’. Nowhere does it say you have to have a procedure.  It doesn’t even need to have a process.  It doesn’t even need to have records (unless of course you do require traceability)!  So why is it even mentioned at all?  I don’t know, but let’s have a crack. 

Identification can be by name, number, location, colour, picture, barcode, any unique qualifier that stops inadvertent misidentification.  The same rules apply for the status of a product or service.  Can it be readily examined and determined if it pass, fail, hold, concession, reject, etc.

The only really tricky paragraph is that ‘when it is a requirement’, you need to keep records of components, testing, use-by, delivery and even recycling for life cycle requirements.  If there is a need for this, there is much review, much operational controlling, much complexity which at the end of the day will be determined by your risk exposure of the product or services.