Q. We only log test results for equipment that passes our testing. We do not log the test results of equipment that fails since it goes directly to our dismantling area to be broken down and sent to a downstream vendor for recycling. Are we required to log the testing records of failed equipment destined for end-of-life recycling?
A. The language under Provision 6 uses the word “effective” (...verify the accuracy of test methods and testing equipment and maintain records of effective testing methods, equipment and results as appropriate).
This means the effectiveness of your testing process and record keeping is open to some subjectivity by the auditor. If every test record is a pass, it may raise questions about whether the results are just copied and pasted, and whether the testing was actually performed. If you were using an automated testing software, for example, it would record both pass and fail records. To demonstrate the credibility of your process, it would be wise to maintain failure records as well as success records.