QMS Documentation: Don’t Get Trapped by Your Words

Conditional words or phrases can keep you from painting yourself into a corner

Published: Wednesday, June 18, 2014 - 10:45

Sometimes interpreting ISO 9001 or API Q1/API Q2 requirements seems to force us to agree to things we won’t be able to do, or to sustain for more than a few months, let alone days. So how do we write our policies and procedures to explain our approach while avoiding being boxed in by our own words?

There are a handful of words or phrases you can use, as necessary, when you don’t want your procedures to be overly proscriptive. Call these “conditional” words or phrases (some might call it “hedging”). These words, when inserted into your procedures, may help you comply with the requirements of quality management system standards without backing yourself into a corner.

Leave maneuvering room in procedures or work instructions

Here are some useful words to include in your procedures or work instructions:

As applicable
This is a phrase that can pretty much get you out of doing anything you aren’t absolutely required to do—although it can also get you in trouble if you don’t use it appropriately. Remember, these words and phrases allow you room to maneuver in a procedure, not let you off the hook if you are clueless about when something is applicable, or if your own employees can’t tell when something applies.

Example: “When a new inquiry is received, the sales representative shall fill out the New Inquiry Request form and complete all fields as applicable.”

Reason: Some fields may not be applicable for the inquiry.

As deemed appropriate
This three-word combination is the next-best phrase after “as applicable.” The difference here is that you are giving somebody the authority to do something as he sees fit. Therefore, you may only want to use it when you feel the employee knows how to distinguish “appropriate” from “not appropriate.”

Example: “Upon completion of a weld for a specific material grade, the welder shall fill out the welding log as deemed appropriate.”

Reason: The welder may not need to fill out the log for all materials, maybe only for some.

As deemed feasible
This is often used when instructions must be followed but may not be possible to comply with in all cases.

Example: “Project managers shall seek a completed survey from a company person upon completion of a drilling job as deemed feasible.”

Reason: If the company person is nowhere to be found, this may not be feasible.

As deemed necessary
This phrase allows you to place significant responsibility on the person carrying out the instructions. I prefer to use it for supervisory roles and up, but I’m sure you can give anybody the power to decide what is necessary.

Example: “When document control updates a document, the updated document shall be forwarded to the process owners as well as other stakeholders as deemed necessary.”

Reason: Depending on what document is being changed, and the type of change, nobody else’s approval may be necessary besides the process owner.

Including but not limited to
This is a nice phrase that helps you create a list of things to do, but allows you to expand your options in case you forgot an item, or if it is impossible to think of all scenarios for the list.

Example: “The purchasing buyer shall review the purchase order for the following items, including but not limited to: date, part number, revision, cost, delivery date, and quantity.”

Reason: Some people may also review ship via, ship to, etc.

Or designee
If you want something to be done by a specific employee, but you don’t want to tie your hands, adding the words “or designee” will pretty much save you every time. So if this person is unavailable, or went on vacation, or the boss did the work, this word will ensure you are not the victim of your own words.

Example: “The well test engineer, or designee, shall conduct a design review meeting upon completion of the first phase of the well design.”

Reason: It could be the engineering manager who conducts the meeting.

When required
This phrase is good but must definitely be used with extreme caution because the same words imply that there is a notion of when something is required, and when it is not required. And as we all know very well, a requirement can’t be taken lightly. Requirements are the foundation of ISO 9001 and API Q1 and Q2.

Example: “When required, a response to the corrective action must be submitted to the auditor for his or her review and approval.”

Reason: An observation may not need approval from the auditor, but a nonconformity will.

In general
This phrase is great when there isn’t a set way to perform a certain task. You want to give employees some guidance, but you acknowledge there is more than one way to complete the task, and you are OK with that.

Example: “Parts are procured from approved suppliers. In general, three quotes are sought from suppliers.”

Reason: We may seek one quote, or we may seek five; three is simply the average number.

When practical
This is a good phrase that allows you to call out for something to be done, but only if it is practical to do.

Example: “Nonconforming parts must be labeled with a red tag that includes the date, quantity, and defect. The nonconforming parts may also be placed in a bin when practical.”

Reason: If the parts are gigantic, then it may not be practical, so you won’t have to put them in a bin.

Words for job descriptions

Here are some good words to use within your job descriptions:

In lieu of
This phrase is often used to substitute experience for education, or vice versa. If your job descriptions have separate sections for education and experience, then you can use the phrase in both sections, but be careful to ensure that something is actually required, and that you are not lowering the standard to nothing. Also, if you have job descriptions that are divided into levels, such as Field Operator Level 1, Field Operator Level 2, and Field Operator Level 3, then I absolutely recommend not using this word because the level structure of your job descriptions provides the details of what is absolutely needed to move from one job level to another.

Example: Job description for a CNC programmer

Education: Two-year associate’s degree in CNC programming or machining. Experience may be accepted in lieu of education.
Experience: Five years of experience as a CNC programmer

Reason: If the candidate has no associate’s degree but 10 years of experience, that will make him eligible for the position.

Including but not limited to
This is the same phrase used in procedures and work instructions, but for job descriptions it is often used to list the responsibilities of the position. And since we can’t always list every possible responsibility or task we may assign somebody, this phrase makes for a nice “catch all” responsibility.

Example: Responsibilities for the maintenance mechanic include but are not limited to:

• Conducting preventive maintenance as per established preventive maintenance program
• Assisting with machine repairs
• Ordering maintenance supplies
• Other duties may apply

Reason: The responsibilities are listed, but there could be more.

Is highly desirable
This is a phrase used when describing education and skills in the job descriptions that you would want the candidate to have, but it won’t be a show stopper if they don’t.

Example: Job description for a supply-chain manager

Education:
• Bachelor’s degree in supply chain management, international business, or finance
• MBA is highly desirable

Reason: If the candidate has an MBA, she will definitely stand out.

A plus
Similar to the “is highly desirable” phrase, this one is also used when stipulating education and skills in job descriptions. In this case it should be clear to candidates that if they possess this quality, they may be chosen over other candidates who don’t.

Example: Job description for a sales representative

Education:
• Bachelor’s degree in business administration
• MBA a plus

Reason: If the candidate has an MBA, he will definitely stand out.

Preferred
Just like the two words above, this word helps you describe those education and skills that you really preferred the candidate to have and that may be a show stopper if they don’t.

Example: Job description for a shipping and receiving foreman

Experience:
• Experience in receiving, warehouse, packaging, and shipping
• Experience in a distribution factory preferred

Reason: We prefer candidates with distribution experience, although we may consider others.

Should we try to wiggle out of everything?

Those who know me know that I truly live by the ISO principles, and I practice what I preach. In fact, I’m the driver at our firm who ensures we all adhere to our quality management system. So I’m not advocating trying to get out of doing anything. However, as a business owner and consultant I have to be realistic, and the truth is the world is not perfect, and neither are we. Furthermore, ensuring that your procedures provide firm guidance and some flexibility is essential for adhering to sustaining your own management system.

About The Author

Miriam Boudreaux

Miriam Boudreaux is the CEO and founder of Mireaux Management Solutions, a technology and consulting firm headquartered in Houston, Texas. Mireaux’s products and services encompass international standards ISO and API consulting, training, auditing, document control and implementation of Web QMS software platform. Mireaux’s 6,500 square foot headquarters, located in the northwest area of Houston, houses their main offices as well as their state-of-the art training center. Mireaux itself is certified to ISO 9001:2015 and ISO 27001:2013. To get in touch with Miriam Boudreaux, please contact her at info@mireauxms.com.