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Implementation guide, Platform

How to control documents under ISO/IEC 17025

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PureField
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Under ISO/IEC 17025, document control means every document is approved by authorised personnel before issue, reviewed periodically and clearly marked with its current revision, and obsolete revisions stay out of use (§8.3). In practice it is a cycle: draft, review, approval, effective date, reading by staff, withdrawal of the previous revision. Each step records who signed and when.

What does ISO/IEC 17025 require for document control?

Clause 8.3.2 lists six requirements: documents are approved for adequacy by authorised personnel before issue, reviewed periodically and updated as necessary, changes and the current revision status are identified, relevant versions are available at points of use, documents are uniquely identified, and the unintended use of obsolete documents is prevented. They apply to external documents such as standards as much as to the documents the laboratory writes itself (§8.3.1).

§8.3.2RequirementWhat it looks like in the lab
aApproval by authorised personnel before issueThe approver's name and signature date sit on the revision record
bPeriodic review, updated as necessaryEvery document has a next review date
cChanges and current revision identifiedRevision number, change summary and effective date
dRelevant versions at points of useThe analyst reaches the revision in force at the bench
eUnique identificationDocument code and revision number on every page
fUnintended use of obsolete documents preventedWithdrawn revisions are marked and printed copies collected

Records are the subject of §8.4. The laboratory keeps legible records that show it meets the requirements, and controls their identification, storage, protection, back-up, archiving, retrieval, retention time and disposal. The distinction is simple: a document says how the work is done and gets new revisions over time; a record shows that the work was done. A blank form is a document; a completed form, a training record and an approval signature are records.

Which documents need to be controlled?

Every document that affects laboratory activities is controlled, whether the laboratory wrote it or received it from outside. The usual types:

  • Quality manual: The quality policy, objectives and the structure of the management system.
  • Procedure: Who runs a process and in what order (sample receipt, CAPA, internal audit).
  • Instruction: The bench steps of a single task (instrument use, sample preparation, cleaning).
  • Form: A template that becomes a record once filled in (sample receipt form, temperature log).
  • Method: A method the laboratory developed, or an in-house method written to apply a standard method.
  • External document: Standards, regulations, manufacturer manuals and reference documents cited in methods.

Settle the code structure for each type at the start (for example PR-004 for a procedure, FR-018 for a form). A document keeps one code for its whole life; the revision number goes up by one with each new revision.

How does a document's revision cycle work?

Every revision passes through four states: draft, approval, in force and withdrawn. A document has only one revision in force at a time.

StateWhat happensWho
DraftThe text is written or updated and a change summary is enteredPreparer
ApprovalThe revision is reviewed and approved; the submitted text is frozenReviewer, approver
In forceThe revision applies from a given date and goes out to the people who must read itDocument owner
WithdrawnWhen a new revision comes into force, the old one is withdrawn and stays marked in the archiveDocument owner

A typical case: the sample reception instruction needs a new acceptance criterion for the cold chain. The quality manager opens the Rev.04 draft, an analyst writes the text and enters "Cold chain acceptance criterion added" as the change summary. If the review finds a mistake, the revision goes back to draft with a reason, is corrected and submitted again. On the day Rev.04 comes into force, Rev.03 is withdrawn.

Fill in the change summary on every revision; it is how a reader sees what changed (§8.3.2 c).

Who signs what in the approval flow?

In the approval flow the preparer writes the text, the reviewer checks it, and the approver decides that the document is fit for purpose and releases it. Clause 8.3.2 a only asks for approval by authorised personnel; giving the three roles to different people means at least two people have read the text.

  • Preparer: The person who knows the work. A test instruction is often prepared by the analyst who runs the test, together with the section head.
  • Reviewer: Reads the text for technical and quality points. There can be one step or several: first the section head, then the quality manager.
  • Approver: The authorised person who releases the document, often the laboratory manager or the quality manager.

The flow can differ by document type. A form may need only the quality manager's approval; a test instruction is prepared by an analyst and the section head, reviewed by quality and approved by the branch manager. Write down which type goes through which flow in the quality manual or the document control procedure.

The segregation of duties rule is short: one person signs only one step of a revision, and the approver is always someone other than the person who wrote or edited the text. When you change a flow, finish the revisions already in approval under the flow they were submitted with, so every signature stays tied to the rule it was given under.

What is the difference between a controlled and an uncontrolled copy?

A controlled copy is one whose location the laboratory knows and which it updates when the revision changes; an uncontrolled copy is no longer tracked once it is printed or downloaded. An uncontrolled copy is for information: check it against the revision in force before you use it.

In a paper system, controlled copies are numbered and entered on a distribution list; when a new revision arrives, the old copies are collected and struck off the list. In an electronic system the controlled copy is the revision in force in the system. Every printed or downloaded copy is uncontrolled and says so on the page: who printed it, when, and that the current revision must be checked before use.

Putting the document code, revision number and page number (for example 3 / 7) on every page shows which document a loose page belongs to (§8.3.2 e). An assessor may compare the instruction at the bench with the revision in the system; Rev.02 at the bench and Rev.03 in the system can be written up as a finding against §8.3.2 d and f.

Why keep a read-and-understood record?

A read-and-understood record shows that a new revision has reached the people who will apply it. ISO/IEC 17025 leaves the form of this record to the laboratory; §6.2 asks for competent staff and records of their competence, and §8.3.2 d asks for relevant documents at points of use. When an instruction changes, this record is the simplest evidence that the analyst knows the new step.

  • Decide who must read by role, job title or name: the analysts who run a test read its instruction; everyone with a task in a process reads its procedure.
  • Give the task a deadline (for example 14 days) and have the quality manager follow up overdue reads.
  • Have each person confirm with their own signature; that is where the evidence gets its value.
  • Keep reading records with training records; an assessor can look at both in the competence file.

How do you check that external documents are current?

You check external documents by looking at the publisher's catalogue at set intervals and recording each check with its date, result and the person who made it. For standard methods, the laboratory uses the latest valid version unless that is not appropriate or possible (§7.2.1.3), so it needs to notice when a new edition of a standard cited in a method is published.

  • Keep a list of standards: standard number, edition year, publisher (such as ISO, CEN or a national standards body) and the methods that use it.
  • Set a check interval for each standard (for example 12 months) and show the next check date on the list.
  • Record the result of every check: current, new edition available or withdrawn. For a new edition, note which edition was published.
  • If a new edition has been published, plan the move: read the changes, decide whether the method needs to be verified again and update the internal documents it affects.
  • Use the same list for regulations and manufacturer manuals.

How do you run a periodic review?

In a periodic review the document owner compares the text with current practice and records one of two outcomes: no change needed, or a new revision will be opened. The laboratory sets the interval and writes it in its procedure (§8.3.2 b); a change in regulations, a new instrument or an assessment finding can bring a review forward.

Questions to ask in the review:

  • Does the text describe how the work is done today? Are the instruments, screens and responsibilities the same?
  • Are the standards and documents it cites still in force?
  • Do recent CAPAs, complaints or internal audit findings touch this document?
  • Is a form missing a field, or carrying one nobody fills in any more?

Even when no change is needed, record the review with its date and outcome; that record is what shows it took place.

Which document control findings are common in assessments?

Common findings appear where documents are used and where their records fall short.

FindingExampleClause
Old revision at the point of useA withdrawn operating instruction next to the instrument§8.3.2 d, f
Approval not evidentA procedure with no approval signature or date, a form corrected by hand and never approved§8.3.2 a
Overdue reviewA procedure past its review date, or a review that was never recorded§8.3.2 b
Changes not identifiedAn empty change summary; nobody can tell what changed§8.3.2 c
Copy not identifiedA photocopy with no code or revision number on its pages§8.3.2 e
Standard not checked for currencyA method cites an old edition, and the move to the new one was never assessed§7.2.1.3, §8.3.1
New revision not readThe instruction changed, and the analyst has missed the new step§6.2

What these findings share is evidence: who did it, when and with which revision should be answerable from the record.

How does document control work in PureField LIMS?

In PureField LIMS every document belongs to a category, and the category's approval flow sets who prepares a revision, which review steps it passes and who approves it. The rules are enforced in the database; segregation of duties is checked again at every signature.

StepIn PureField LIMS
Category and flowEach document type has a default category (quality manual, procedure, instruction, form, method, external document), and the laboratory adds its own. A flow has named preparers, up to 5 review steps in order and one approval step. Who may sign each step is set by job title, role or permission
Flow changesEvery change to a flow is saved as a new version with a reason and an e-signature; earlier versions are kept. A submitted revision continues under the flow version it was submitted with
Segregation of dutiesOne person signs only one step of a revision. The approver is always someone other than the person who wrote, edited or submitted it; with independent review switched on for the category, the same applies to reviewers
TextThe text is written in the app on a paper view, as it will print with the laboratory's header and footer; a finished PDF can also be uploaded. On submission a controlled PDF is generated from the text and bound to it, and the approver signs the PDF's SHA-256 digest
ComparisonTwo revisions written in the app compare inline or side by side, with added and deleted text in colour
In forceA revision comes into force at once or on a scheduled date; the previous revision is withdrawn automatically
Read and understoodEveryone named by role, job title or name gets a 14-day task; each person confirms with their own e-signature, and the record joins their training history
CopiesEvery page of the controlled PDF carries the document number, revision, page and copy note. A printed copy carries an uncontrolled-copy note with the name of the person who printed it and the time
External documentsPublisher, standard number and check interval are entered. A person records each currency check with its result (current, new version available, withdrawn), and the next check date follows from it
Periodic reviewA document whose review date is near or past is flagged in the list and its owner is notified; if no change is needed, the outcome is recorded
RelationsA document links to another document, a standard, a method or an ISO/IEC 17025 clause; a document linked to a clause is listed on that clause's page of the 17025 compliance map

The revision history shows each revision on a timeline, with who did what, when and why; text saves and signatures go into the audit trail. If the AI assistant is switched on for your laboratory, Ask the assistant on a document in force adds that document to your question; the assistant reads the revision in force and answers with code, revision and page.

At the bottom of a document's page, project cards linked to it are listed under Cards linked to this record (project management in the laboratory).

Evidence

ISO/IEC 17025 (2017 edition)
General requirements for the competence of testing and calibration laboratories. Document control is in §8.3, control of records in §8.4 and use of the latest valid version of a method in §7.2.1.3. Source: iso.org

To see the approval flow and read-and-understood tasks in a sample laboratory, request a PureField LIMS account.

Frequently asked questions

What is the difference between a document and a record?

A document says how work is done and gets new revisions over time (§8.3). A record shows that the work was done (§8.4): a completed form, a training record, an approval signature. A blank form is a document; once filled in, it is a record.

How should the approver be chosen?

Clause 8.3.2 a asks for approval by authorised personnel. Define approval authority by document type in the quality manual or the document control procedure, and give approval to someone who did not write the text. In PureField LIMS the approver is always someone other than the person who wrote, edited or submitted the revision.

Can printed instructions be used at the bench?

Yes, as long as the copy shows which revision it is and whether it is controlled. Enter controlled printed copies on a distribution list and collect them when a new revision comes in. Check an uncontrolled copy against the revision in force in the system before using it.

How often should standards be checked for currency?

The laboratory sets the interval and writes it in its document control procedure. What matters is that each check is recorded with its date, result and the person who made it. In PureField LIMS the interval is set for each external document, from 1 to 60 months, 12 by default.

Who gives the read-and-understood confirmation?

The person who read the document, in their own name. In PureField LIMS the task runs for 14 days; the reader sees the code and revision number of what they read and the SHA-256 digest of the PDF, and signs with their password. The confirmation joins their training history as a read-and-understood record with an e-signature.