Professional Documents
Culture Documents
3 The Newsletter of the Measurement Quality Division, American Society for Quality September 2007
Chair
Dilip A. Shah
E = mc3 Solutions
197 Great Oaks Trail #130
Wadsworth, Ohio 44281-8215
Voice (330) 328-4400 / Fax
(330) 336-3974
E-mail: emc3solu@aol.com,
dashah@aol.com
Chair-elect
Craig (Woody) Niemann
1489 Pheasant Run Dr.
Newark, OH 43055-8046
Voice (740) 788-5034
E-mail:
Craig.Niemann@afmetcal.af.mil
Secretary
Christopher L. Grachanen
Manager, Houston Metrology
Group HP
P. O. Box 692000 MS070110
Houston, TX 77269-2000
Voice (281) 518-8486 / Fax
(281) 518-7275
E-mail:
Chris.Grachanen@hp.com
Treasurer
Jay L. Bucher
Bucherview Metrology Services
6700 Royal View Dr.
De Forest, WI 53532-2775
Voice (608) 277-2522 / Fax
(608) 846-4269
E-mail: yokota-69@charter.net
Vol. 21, No. 3 The Newsletter of the Measurement Quality Division, American Society for Quality September 2007
MQD Page 4
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CHAIR-ELECT’S COLUMN
By Craig A. Niemann, SMSgt, USAF
As the new Chair-Elect for the Measurement Quality Division, I feel it appropriate
for me to introduce myself. I’m Craig “Woody” Niemann and I began my career in
metrology in 1989 at Lowry Air Force Base, as many other people in the division
have done. Even though I went through 9 months of technical school training to be a
Precision Measurement Equipment Laboratory (PMEL) apprentice, I still don’t think
I had a true appreciation for the vast impact metrology has on every walk of life.
However, with the help of some outstanding trainers, one of which is the former chair
of the MQD I soon developed a deeper understanding and appreciation of the impor-
tance metrology plays in the world.
Here I am 18 years and a few assignments later and feel honored to serve as an Air Force Metrology
Laboratory Assessor. I function as part of a team that conducts assessments on all 77 USAF calibration
laboratories and the Air Force Primary Standards Laboratory, co-located with our team in Heath, Ohio.
The main question I get in my travels is “I thought the USAF did not have any more military PMEL’s”.
It’s true that there was an initiative being looked at to outsource the entire USAF metrology program in
the late 1990’s, but it was decided that this was not the best decision for the USAF and the effort was
halted. What remains is a workforce, that in my opinion combines the best of what every group has to
offer, active-duty, contractor and government civil service. I have performed evaluations on all the dif-
ferent types of laboratories and each workforce brings something different to the table and all are ex-
tremely professional and a pleasure to work with.
I sincerely look forward to working with everyone in MQD over the next few years. I have been ex-
tremely impressed with everyone I have met so far. I would especially like to thank Rick Roberson and
Jay Bucher for nominating me as Chair-Elect. Without their encouragement, I don’t think I would have
decided to volunteer for this position. If anyone has any feedback for me or additional questions about
the status of metrology in the USAF, feel free to contact me at the email address below.
The American Society for Quality (ASQ) Measurement Quality Division (MQD) is please to relate that
the Certified Calibration Technician (CCT) exam can be proctored on military bases having education
offices that are authorized to administer Dantes tests (ASQ’s other certification exams may also be proc-
tored) . The steps to apply for taking an exam are as follows:
1. Active military personnel, government employees and civilian contractors interested in taking the
CCT exam should first verify that their education office is authorized to administer Dantes tests.
2. (After verifying Step # 2) personnel should obtain the following contact information
3. Contact information and exam application (see below) should be sent to Betty File
bfile@asq.org her phone number is 414-272-8575 ext 7748 (exam fee should also be sent at this
time).
ASQ will contact the person that will be proctoring the exam and provide instructions and the exam.
http://www.asq.org/certification/calibration-technician/index.html
http://www.asq.org/certification/calibration-technician/apply.html
http://www.asq.org/store/training-certification/
Note: If you are an active member of the U.S or Canadian military, you are eligible for a discounted
exam fee. You must submit a copy of your military ID when you apply. ID cards should be faxed to
414-298-2500. Your application will be placed on hold until a copy of your ID card is received.
Vol. 21, No. 3 The Newsletter of the Measurement Quality Division, American Society for Quality September 2007
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Jay
x Deadline for article submittal for the next issue of The Standard is 15 Aug 2007.
x ASQ headquarters has a new Division Accountant, Bobbie Mulhall.
x Jay is working on his replacement for his MQD Treasury position which comes to term next year.
x Jay questioned who will be the MQD chair elect for 2008-2009. Discussions followed with no firm
candidate identified.
x MQD Financial Summary: As of July 31st, 2007, we had $77,614.52 in our Money Market account
and $58,347.49 in checking (All MQD and CCT coins have been paid for).
Jay to follow up with ASQ headquarters about the mailing of CCT coins … Update: Coins were mailed
out USPS on 27 July 2007 per Leta Thrasher, ASQ Administrator.
Dilip
x ASQ’s World Wide Conference abstract submittal deadline is 01 Aug 2007. Dilip and Graeme
Payne have submitted their abstracts.
x The MQD session track for the 2008 Measurement Science Conference (MSC) has been confirmed.
The 2008 MSC will be held on 10-14 March.
x A CCT Prep course will be offered at the 2008 MSC on Monday and Tuesday of the conference
with the CCT exam being given on Wednesday. Dilip will be teaching the CCT Prep course for free.
The offering of the CCT Prep course and CCT exam is a piloted program which if successful will be
offered at next year’s NCSLI national conference. ASQ’s CQT and CQI exams will also be offered at
MSC (no prep courses for CQT and CQI will be offered at the 2008 MSC).
x The 2007 MQD / Inspection Conference has been cancelled due to lack of presenters (conference
was tentatively scheduled for the end of Sept. 2007).
Nominated Norm Belecki for the 2007 Max J. Unis award. A vote was taken which unanimously passed.
Presentation of the award will be either at the 2008 MSC or the 2008 CPEM conference.
Chris
x Update on the CCT program (CCT alumni is now 811 strong).
x Chris confirmed ‘ear marking’ approx. $25k for updating the CCT Body of Knowledge (BOK).
ASQ requires all certification BOK’s to be updated every 5 years. The ‘ear marked’ funds will be used
to pay a contractor to construct an on-line survey, disseminate the survey to participants, compile survey
responses and summarize results.
x Jay accepted championing the CCT program per ASQ’s certification program secession planning
requirements.
Update on activities with the US Dept. of Labor and the Office of Personnel Management (OPM) re-
garding Metrology job descriptions.
(Continued on page 8)
Vol. 21, No. 3 The Newsletter of the Measurement Quality Division, American Society for Quality September 2007
MQD Page 8
Jay
1. Need to complete and submit MSC co-sponsorship Letter of Memorandum; update—completed at
NCSLI on Tuesday, August 1st, given to Woody Niemann.
2. Richard Roberson and Woody need access to MQD’s Share Point; update—link, logins and pass-
words sent out August 4th.
Jay to coordinate Quality Progress’s Measure For Measure column (different authors will be responsible
for writing articles and submitting them in a timely manner); next three editions have author’s commit-
ted.
Dilip
1. Contact Carol Singer of Cal Lab Magazine to promote the CCT Prep course and CCT exam that will
be offered at MSC.
Research past recipients of MQD’s Max J. Unis award for posting to the MQD website
Chris
1. Develop an activity roadmap for updating the CCT BOK which is scheduled to begin in early 2008.
Provide a copy of the US Air Force letter which mentioned the CCT program as an US Air Force sanc-
tioned program for posting to MQD’s Share Point.
Woody
1. Research the possibility of offering the CCT exam on military bases (education offices).
Research how CCT exam fee is reimbursed by the US Air Force for personnel taking the exam.
Graeme
1. Send MQD historical documents and records to Jay.
Research getting a ‘mobile friendly’ MQD display booth.
GENERAL DISCUSSIONS
x Several MQD officers participated in NCSLI conference education sessions (Education Outreach
Panel and CCT Program Update) as well as attending several NCSLI Metrology education committee
meetings.
x Three copies of the Metrology Handbook were signed by authors present at the conference and
given to NCSLI personnel for door prizes.
Many inquires regarding MQD and the CCT program were answered for conference attendees visiting
the MQD booth (Chris, Dilip, Graeme, Jay and Woody covered booth duties). Traffic at the MQD booth
was good. Conference attendee comments regarding MQD and the CCT program were generally favor-
able.
Respectfully Submitted,
Christopher L. Grachanen
ASQ MQD Secretary
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MQD Page 11
ȱyourȱcalibrationȱprogramȱȱȬȱȱ
Gaveȱyouȱconsistentlyȱaccurateȱresults?ȱ
MetȱISOȱstandardsȱorȱFDAȱrequirements?ȱ
HadȱaȱtraceabilityȱpaperȬtrail?ȱ
TrackedȱoutȬofȬtoleranceȱconditions?ȱ
Hadȱaȱpaperlessȱrecordȱsystem?ȱ
Wasȱproactiveȱinsteadȱofȱreactive?ȱ
Theȱsolution…ȱ
aȱQualityȱCalibrationȱSystemȱ
In-house calibration programs for biotech
and pharmaceutical companies, meeting all
ISO standards and QSR requirements.
Toȱfindȱoutȱmoreȱvisit:ȱ
www.BucherviewȬ
Metrology.comȱ
JayȱL.ȱBucher,ȱASQȱCCTȱ
(608)ȱ846Ȭ6968ȱ
Vol. 21, No. 3 The Newsletter of the Measurement Quality Division, American Society for Quality September 2007
MQD Page 12
The culmination of APLAC’s celebration of its 15th Anniversary will be at its General Assembly and
associated meetings from 2- 7 December, in Kuala Lumpur, Malaysia.
APLAC’s membership consists of organizations in the Asia Pacific region responsible for accrediting
calibration, testing and inspection facilities, and reference material producers.
APLAC now boasts the successful establishment of a fully operational Mutual Recognition Arrange-
ment (MRA) linking 26 accreditation bodies in 17 economies across the Asia - Pacific region. The
economies are: Australia; Canada; Peoples Republic of China; Hong Kong, China; India; Indonesia; Ja-
pan; Republic of Korea; Malaysia; Mexico; New Zealand; The Philippines; Singapore; Chinese Taipei;
Thailand; United States of America; Vietnam.
In the US, four accreditation bodies are signatories to the APLAC MRA. These are Assured Calibration
Laboratory Accreditation Select Services (ACLASS) (for testing and calibration), American Association
for Laboratory Accreditation (A2LA) (for testing, calibration and inspection), International Accredita-
tion Service (IAS) (for testing, calibration and inspection) and the National Voluntary Laboratory Ac-
creditation Program (NVLAP) (for testing and calibration).
Mutual recognition means that each MRA signatory accepts the accreditations granted by the other sig-
natories as equivalent to its own. This facilitates endorsed test, measurement and inspection reports from
the exporting economy to be accepted in the importing economy, avoiding the need for re-testing, re-
calibration or re-inspection, thus saving time and money. Regulators worldwide increasingly use ac-
creditation (and the APLAC MRA network) as evidence of competence to carry out testing, measure-
ment and inspection for mandatory purposes. APLAC is recognized by Asia Pacific Economic Coopera-
tion (APEC) member economies as a Specialist Regional Body (SRB).
APLAC's principal objectives are to foster the development of competent laboratories inspection bodies
and reference material producers in member economies, to harmonize accreditation practices in the re-
gion and with other regions, and to facilitate mutual recognition of test, measurement and inspection
reports through the APLAC Mutual Recognition Arrangement.
MEDIA RELEASE
ILAC Celebrates 30 Years
(International Laboratory Accreditation Cooperation 1977-2007)
ILAC is the international cooperation of laboratory and inspection accreditation bodies which this year
celebrates its 30th anniversary. One of the primary aims of ILAC is the removal of technical barriers to
trade.
Imagine you are importing toys from another country. The toys have been tested in that country by a
laboratory which says it meets international safety standards. But how do you convince your authorities
that the tests –and results – are genuine?
That dilemma was a major impediment to international trade 30 years ago, but today, thanks to a handful
of pioneers, things have changed for the better.
The ability of authorities to trust technical standards and procedures from different countries reaches an
important milestone this year - with the International Laboratory Accreditation Cooperation (ILAC)
celebrating 30 years of helping the world's economies overcome technical barriers to trade.
ILAC’s evolution was prompted by the Tokyo round of international trade negotiations under the Gen-
eral Agreement on Tariffs and Trade (GATT). The outcome was the GATT Standards Code, an agree-
ment between a number of the member states encouraging recognition of the equivalence of different
standards, and the variety of testing and accreditation regimes.
ILAC’s Chair, Daniel Pierre said: “The first conference on International Laboratory Accreditation, was
convened in Copenhagen in 1977 by Mr Per Lund Thoft of the Ministry of Trade, Denmark with the
support of Dr Howard Forman of the US Department of Commerce. Twenty countries from around the
world, the EEC Commission and ISO accepted their invitation.”
The conference gave countries that already had, or were planning accreditation schemes an opportunity
to compare notes and experiences. The delegations with practical experience were The National Testing
Board of Denmark (1977), NVLAP US Department of Commerce (1976), BSI's System of the Registra-
tion of Test House, UK (1977) NATA - Australia (1947) and TELARC - New Zealand (1973).
“The outcome of that first ILAC conference was the idea that mutual recognition agreements between
accreditation bodies meant any laboratory, anywhere could have their test results recognised as reliable.
ILAC from its inception has worked to create an international framework to support international trade
through the removal of technical barriers. This is now recognised through the ILAC Mutual Recognition
Arrangement (MRA). Fifty eight signatories, representing 46 economies have now signed the ILAC Mu-
tual Recognition Arrangement, enhancing the acceptance of products and services across national bor-
ders,” Mr Pierre said.
Submitted by:
Phil Smith American Association for Laboratory Accreditation (A2LA)
Phone: 301 644 3204 Email: smedellin@A2LA.org Web: www.A2LA.org
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This year’s NCSL International conference was held at the Riverfront Convention Center in St. Paul,
MN during July 29 – August 2, 2007.
The overall attendance was about 1,100 attendees and 565 tutorial attendees which is a record for the
conference tutorials.
The Measurement Quality Division had a booth display at the conference which was manned by the
usual team of Graeme Payne (Immediate MQD Past Chair) and Dilip Shah (MQD Past Chair). However,
this year, we also had Jay Bucher (MQD Treasurer), Chris Grachanen (MQD Secretary) and Craig
(Woody) Niemann (MQD Chair-Elect) attending and they also contributed to booth duties. Interest in
the ASQ CCT examination continues to be strong and draws a lot of traffic to the booth. This year was
no exception.
L-R: Dilip Shah, Chris Grachanen, Jay Bucher, Craig (Woody) Niemann, Graeme Payne
All of the MQD team members mentioned were involved in various NCSLI activities either as present-
ers and/or Committee/Panel Members.
(Continued on page 17)
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MQD Page 17
This year, 7 of the 8 co-authors of The Metrology Handbook were present at the conference. This made
it possible to autograph three (3) copies of The Metrology Handbook and donate them as door prizes at
the end of the conference.
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The MQD general meeting was conducted on Monday July 30, 2007 during the NCSLI. Teleconferenc-
ing was available for participants to join in this meeting. The minutes of the meeting are printed else-
where in this newsletter.
First, let’s discuss the characteristic of a good check standard. As the name implies, a check standard is
used as a means to check (monitor) a process, usually within a manufacturing and / or measurement sce-
nario. Check standards are not standards in the traditional sense as normally associated with calibration
standards but rather are artifacts whose measurement attributes are defined and stable over time. Check
standards are selected based on their suitability for a particular process in order to determine perform-
ance aspects of the process i.e. if dimensional (length) accuracy is a critical aspect of a measurement
process, a check standard would normally be selected with a length similar to the length of the units be-
(Continued on page 19)
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So how does measuring a check standard on a regular basis save time in regards to VNA calibration
prior to performing s-parameter measurement? The following scenario depicts a four port VNA used to
perform differential and common mode measurement but also is applicable for two port and other multi-
port VNAs. Before performing s-parameter measurements with a VNA it must first be calibrated to es-
tablish its inherent performance attributes in terms of directivity, port isolation, transmission loss, etc.
Calibration is normally performed using a calibration kit comprised of artifacts with known attributes. A
typical SOLT (Short – Open – Load – Thru) calibration kit will have short, open, thru and 50 ohm termi-
nation artifacts with both male and female connectors. The attributes of these calibration kit artifacts in
terms of propagation delay, phase, etc. is well established and can be uploaded to a VNA so that its in-
herent performance can be determined relative to these known attributes. Calibration of a VNA involves
physically connecting calibration kit artifacts on each port (Short, Open, Load) or connecting ports to-
gether (Thru) and making a measurement. A typical calibration scheme for a SOLT calibration kit is
depicted in Figure 1.
Fig. 1
Based on the frequency range and the number of points to be measured throughout that range measure-
ment time can be in the 10s of seconds for each port and thru connection. In addition each measurement
requires the calibration kit artifact be connected and properly torqued. It can easily be seen that calibrat-
ing a VNA using manual calibration artifacts can be a lengthy process. This is the opportunity where
using check standards can save time. Once a VNA has been calibrated, a check standard with suitable
attributes can be measured by the VNA and the results of the measurement archived for comparison pur-
poses. Evaluation of subsequent measurements of the check standard can be used to verify a VNA’s per-
formance attributes are sufficiently stable so that re-calibration may not be necessary. Figure 2 depicts
sequential transmission loss measurements of a check standard with the VNA calibration having been
performed prior to the first iteration (16 May).
Vol. 21, No. 3 The Newsletter of the Measurement Quality Division, American Society for Quality September 2007
MQD Page 20
Fig. 2
Notice that the seven measurement iterations over the course of nine days measured nearly identical val-
ues for the check standard’s transmission loss from 10MHz to 10GHz. So rather than performing a
lengthy calibration of a VNA using a manual calibration kit, a check standard may be quickly measured
to determine if the VNA’s calibration has drifted to the point where re-calibration is warranted. Of
course one must perform the evaluation based on the requirements of the measurement application the
VNA will be used in and the relative stability attribute(s) of the check standard. In addition to a real pos-
sibility of saving time by foregoing a VNA calibration it is an added benefit that comparison of sequen-
tial check standard measurements can provide that ‘warm fuzzy’ before making measurements with the
VNA.
It is acknowledged that automated calibration kits can substantially reduce VNA calibration time but are
currently not available for higher frequency ranges and are applicable to coaxial environments (Using a
VNA in a micro-probing environment typically involves using calibration substrates in order to calibrate
to the tips of the probes. The use of a check standard as described above is especially applicable in a mi-
cro-probing environment where VNA calibration times can be substantially more than for a coaxial en-
vironment). It must be duly noted that check standards are not a substitute for calibration standards when
calibration is necessary (traceablity of measurements is established by performing calibrations using
calibration standards which are traceable to higher order standards).
The use of check standards has the potential to save time in terms of the need to re-calibrate a VNA.
Proper evaluation of one’s measurement application and check standard measurement history is critical
when utilizing this time saving technique.
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Vol. 21, No. 3 The Newsletter of the Measurement Quality Division, American Society for Quality September 2007
A Quality Calibration System
Speaker/Author:
Speaker/Author:JayJayL.
L.Bucher
Bucher
Bucherview Metrology
Promega Services, LLC
Corporation
6700
5445 Royal
East View
Cheryl Dr., DeMadison,
Parkway, Forest, WI
WI53532
53711
Phone: (608)Phone: (608)
277-2522 846-6968
; FAX: (608) 277-2516
Email: Email:
Jay.Bucher@Bucherview-Metrology.com
jay.bucher@promega.com
Abstract
Whether a company is trying for registration to ISO 9000 standards, or accreditation to ISO
17025, or trying to make a good, valid, repeatable measurement – they will need to have a
system of some sort, and it is just as easy to implement a quality system as opposed to a non-
quality system. But what is a quality system? The basic premise and foundation of a good quality
calibration system is to "Say what you do, do what you say, record what you did, check the
results, and act on the difference". Within this quality system are the basics for any calibration or
metrology function: calibration procedures, traceability, uncertainty, calibration records,
environmental controls, out-of-tolerance procedures, etc. How much importance is placed on
each of these areas is usually determined by who your customer is, and what requirements,
standards, or guidelines your calibration program must meet. To this end, a quality calibration
system in its basic form can set the foundation for your policies and procedures.
1. The Requirements
The first area to be discussed is some of the requirements that call for a quality system, records,
calibration, etc. Generally speaking, the hardest requirements are regulations provided by the
FDA (commonly called cGMPs).
The United States Food and Drug Administration (FDA), an agency that protects the health of
the American people, is one of the most successful and proudest creations of the American
democracy. The FDA's origins go back to the start of the 20th century, when revelations about
filth in the Chicago stockyards shocked the nation into awareness that, in an industrial economy,
protection against unsafe products is beyond any individual's means. The U.S. Congress
responded to Upton Sinclair's best-selling The Jungle by passing the Food and Drugs Act of
1906 that prohibited interstate commerce in misbranded and adulterated food and drugs.
Enforcement of the law was entrusted to the U.S. Department of Agriculture's Bureau of
Chemistry, which later became the FDA.
The Act was the first of more than 200 laws that constitute one of the world's most
comprehensive and effective networks of public health and consumer protections. Here are a few
of the congressional milestones:
x The Federal Food, Drug, and Cosmetic Act of 1938 was passed following the death of 107
persons, mostly children, who took a legally marketed poisonous Elixir of Sulfanilamide.
The FD&C Act completely overhauled the public health system. Among other provisions,
x The Medical Device Amendments of 1976 followed a U.S. Senate finding that faulty
medical devices had caused 10,000 injuries, including 731 deaths. The law applied safety
and effectiveness safeguards to new devices.
Today, the FDA regulates $1 trillion worth of products a year (Feb 2002). It ensures the safety of
all food except for meat, poultry and some egg products; ensures the safety and effectiveness of
all drugs, biological products (including blood, vaccines and tissues for transplantation), medical
devices, and animal drugs and feed; and makes sure that cosmetics and medical and consumer
products that emit radiation do no harm.[1]
Before going into what the current standards and regulations actually state here is a reminder
from times past about measurement practices, and how important they really are.
Immersion in water makes the straight seem bent; but reason, thus confused by false
appearance, is beautifully restored by measuring, numbering and weighing; these drive
vague notions of greater or less or more or heavier right out of the minds of the surveyor,
the computer, and the clerk of the scales. Surely it is the better part of thought that relies
on measurement and calculation. (Plato – The Republic)
There shall be standard measures of wine, beer and corn…throughout the whole of our
kingdom, and a standard width of dyed russet and cloth; and there shall be standard
weights also. (Clause 35, Magna Carta, 1215. Magna Carta (Latin for "Great Charter",
literally "Great Paper"), also called Magna Carta Libertatum ("Great Charter of
Freedoms"), was an English charter originally issued in 1215. Magna Carta is the most
significant early influence on the long historical process that led to the rule of
constitutional law today. Magna Carta was originally created because of disagreements
between the Pope, King John and his English barons about the rights of the King. Magna
Carta required the king to renounce certain rights, respect certain legal procedures and
accept that the will of the king could be bound by law. There are a number of popular
misconceptions about Magna Carta, such as that it was the first document to limit the
power of an English king by law (it was not the first, and was partly based on the Charter
of Liberties); that it in practice limited the power of the king (it mostly did not in the
Middle Ages); and that it is a single static document (it is a variety of documents referred
to under a common name). Magna Carta was renewed throughout the Middle Ages, and
further during the Tudor and Stuart periods, and the 17th and 18th centuries. By the early
19th century most clauses had been repealed from English law. The influence of Magna
Carta outside England can be seen in the United States Constitution and Bill of Rights.
Indeed just about every common law country with a constitution has been influenced by
When you can measure what you are speaking about, and express it in numbers, you
know something about it; but when you cannot express it in numbers, your knowledge is
of a meager and unsatisfactory kind. It may be the beginning of knowledge, but you have
scarcely, in your thoughts, advanced to the stage of science. (William Thomson, 1st
Baron Kelvin, GCVO, OM, PC, PRS (26 June 1824–17 December 1907; A.K.A. Lord
Kelvin).[2]
All of the following Code of Federal Regulations (CFR) can be searched for and located at:
http://www.access.gpo.gov/nara/cfr/cfr-table-search.html#page1. Underscore emphasis has
been added. [3]
FDA Regulations
The FDA is the federal agency responsible for ensuring that foods are safe, wholesome and
sanitary; human and veterinary drugs, biological products, and medical devices are safe and
effective; cosmetics are safe; and electronic products that emit radiation are safe. FDA also
ensures that these products are honestly, accurately and informatively represented to the
public.
According to the CGMP regulations, equipment must be qualified, calibrated, cleaned, and
maintained to prevent contamination and mix-ups (§§ 211.63, 211.67, 211.68). Note that the
CGMP regulations require a higher standard for calibration and maintenance than most
generic quality system models. The CGMP regulations place as much emphasis on process
equipment as on testing equipment (§ 211.42(b)), while most quality systems focus only on
testing equipment.
2. The Basics
One should keep in mind that calibration is a process (procedures, records, analysis,
communication when test equipment is out of tolerance, etc.), not an event. Each calibration is an
action that takes place once for that particular item, but it continues to be repeated time and time
again. The data can be used for many functions, to include: calibration interval analysis,
alert/action procedures, statistical analysis, to see if processes are or are not functioning properly,
and limited calibrations to name just a few. This is all part of a mind set by calibration
practitioners from technicians to supervisors to management. It’s a critical and necessary process
that could make the difference between life and death, profit and bankruptcy, and good or bad
products.
The basic premise and foundation of a quality calibration system is to "Say what you do, do what
you say, record what you did, check the results, and act on the difference". Let’s break these
down into simple terms that will be discussed in great detail in the following chapters.
"Say what you do" means write in detail how to do your job. This includes calibration
procedures, standard operating procedures (SOPs), protocols, work instruction, and/or work
cards. Companies use different names for their procedures, but the bottom line is that they must
"Do what you say" means follow the documented procedures or instructions every time you
calibrate, or perform a function that follows specific written instructions. The requirements for
following written procedures is spelled out every where you look. It only makes sense that if you
are required to have written procedures, then you must follow them. Why is this so important?
Simply put, if repeatable, reliable, and traceable calibrations are to be performed, the calibration
must be performed the same each and every time. This can only happen when a specific set of
instructions are followed. Deviation from those instructions does not allow for repeatable
calibrations.
In order to compare historical data on a piece of test equipment, one must be able to compare
apples to apples and oranges to oranges. Not apples to oranges. If different standards were used
(having different tolerances – different standards may be used for identical calibrations, but
during substitution of standards, their specifications must be equal, or better than those of the
substituted standard(s); that had lesser tolerances, the resulting readings could not be compared.
"Record what you did" means that you must record the results of your measurements and
adjustments, including what your standard(s) read or indicated both before and after any
adjustments might be made. This is also spelled out in different regulations.
"Check the results" means make certain the test equipment meets the tolerances, accuracies, or
upper/lower limits specified in your procedures or instructions. Depending on your industry, you
may only have to ensure that test equipment meets a set of tolerances or specifications. However,
the vast majority of requirements in the calibration community specify that the data be collected
and stored. This requirement has many advantages over just ensuring a tolerance is met. Data
retrieval for comparison, statistical analysis, or to be used for calibration interval analysis can not
be met if the data is not available. Just to say that a tolerance was met is no longer the preferred
way of performing calibrations.
"Act on the difference" means if the test equipment is out of tolerance, does not meet the
specified accuracies, or exceeds the upper/lower test limits written in your procedures, you’re
required to inform the user/owner of the equipment because they may have to re-evaluate
manufactured goods, change a process, or recall a product. The worse case scenario is that
previously calibrated equipment that used that particular standard must be recalled and
recalibrated, along with any products that used any of the suspect test equipment. This could
become costly and very time consuming if procedures are not in place for reverse traceability.
"Say what you do, do what you say, record what you did, check the results, and act on the
difference" form the foundation for a quality calibration system. However, one must build on that
foundation to ensure it works properly. Part of any system is the function used to update your
procedures, records and quality system. Documentation control is critical to having the correct,
up-to-date procedure in place, when it is needed; and a calibration technician who is trained on
that procedure, and any changes or modifications to it. All of this requires controls,
documentation, and training. Where does it say this?
One of the most important parts of a quality system should be the document control procedures.
How do you control who makes changes, how new documents and/or changes to old documents
get posted, and when are the users notified or made aware that changes have been made? There
are software packages available that can assist in controlling an organization’s document system,
but a small business may not be able to afford those packages. Here’s a brief overview of what
can be done with the resources an organization may already be using.
Each of your controlled documents (procedures, records, certificates, etc.) should have a unique
identification (many systems use a number often known as a control number) as well as a
revision number. A master list with all this information should be available for anyone to see
what the current documents are within their quality system. This list should also include the
revision date of the document. It needs to be updated every time changes are made and approved
for your documents. A simple spreadsheet or word processor document can fulfill this
requirement, as long as it is updated and maintained. And, it has to be available to the technicians
who use the various procedures, records and certificates. This isn’t a difficult problem in a small
group where only a few people work with the various documents. But if an organization has two
or three shifts, different locations, or off-site calibration responsibilities, the opportunity for
using out of date or incorrect documents could easily become a problem. Notification of changes
and training, when applicable, should be documented as a form of keeping everyone informed
and up-to-date. Part of an organization’s training program should include when and how to
inform and train its staff of changes to their documents. Some organizations ensure training
and/or notification of changes has occurred before they allow the latest revisions to be posted. In
some systems, the new revision must be posted in order for the user to have access to the
documents. Another approach would be to maintain all of your quality documentation
electronically via an intranet. In this process any printed documents would be invalid. This
process insures only the “latest and greatest” procedures are available to all that they pertain to.
Whichever way an organization’s system works, it is vital that everyone involved be informed
and trained when changes are made, and that only the latest revisions are available for their use.
As a minimum, an organization’s master list should have, for each of its controlled documents: a
unique identification, document name, revision or edition number, and revision date. In addition
it is helpful to include the name of the approver or approval authority, and something stating that
only the revisions listed should be used. Archiving a copy of previous revisions can have
benefits, but must be in a location where they cannot be readily accessed for use by staff. Some
systems use black lines in their borders to indicate where changes have been made; others
It matters little what name is given to this part of your quality calibration system. Calibration
procedure, Standard Operating Procedure (SOP), protocol, work instructions, work cards, or any
number of other monikers. The bottom line is they are used to tell a person how to calibrate a
particular piece of test equipment.
There should be three parts to this system. The first part is the procedure itself. How it is written
and what it contains. The second part is the control system used to ensure that changes, updates,
and modifications to the calibration procedure are implemented. It is not good enough to have
the procedures if there is no way to continuously improve it. Nothing is written in stone, and
most certainly not calibration procedures. Changes are made every day to the standards used,
updates from the manufacturer, new modifications to old items, and many other reasons to
continuously improve your procedures. There must be a process in place to make the changes,
update the written procedures that the calibration technicians use, and to inform and train them
on the improvements and/or changes. Also, when errors are found, the procedure needs to be
changed, too.
The third part is the most critical. The calibration procedure must be used each and every time a
calibration is performed. This is important enough to repeat: The calibration procedure must
be used each and every time a calibration is performed. Every standard and regulation calls
for the use of calibration procedures. They do not say that they have to be made available, but
that they will be used.
This is where the real world collides with the standards and regulations. Everyone who has
performed numerous calibrations on a particular piece or type of test equipment over many years
will be thinking to themselves: “I’ve done this a million times – why do I need to look at the
same old procedure?” Is it possible the procedure has changed? Is it possible the standards used
have changed? Is it possible the item being calibrated has changed? They are all possibilities. But
the question in most calibration technician’s minds is this…If I know what I am doing, why do I
have to re-read a procedure that I know by heart?
Humans are creatures of habit. They get into a groove and don’t want to make changes. This is
part of why it is critical to ensure that every time a change is made to a calibration procedure, it
is documented, and every calibration technician is trained on what the change is, and how to
correctly perform the new procedure.
A calibration procedure is only as good as what’s written on its pages, and the calibration
technician who follows them. In order to have repeatable, reliable, accurate measurements with
test equipment, each item must be calibrated the same way. This can only be accomplished by
using, and following validated calibration procedures each and every time a calibration is
performed.
All quality systems that address calibration require written instructions for the calibration of test
equipment. Under the quality system, this is the "Say what you do" portion, which means you
need to write down in detail how to do your job (this includes calibration procedures, SOPs,
protocols, work instruction, work cards, etc.) Why do you need to follow formal instructions or
procedures? Simple…in order to get consistent results from a calibration, you must be able to
follow step-by-step instructions each and every time you perform those calibrations.
The following is paraphrased from three different sources focusing on written calibration
procedures: ISO 10012:2003, Measurement management systems – Requirements for
measurement processes and measuring equipment; NCSL International’s RP-6, Calibration
Control Systems for the Biomedical and Pharmaceutical Industry; and ANSI/ASQ M1-1996,
American National Standard for Calibration Systems. Another source is NCSL International’s,
RP-3, Calibration Procedures.
ISO 10012:2003, chapter 6.2.1 states: “Measurement management system procedures shall be
documented to the extent necessary and validated to ensure the proper implementation, their
consistency of application, and the validity of measurement results. New procedures or changes
NCSLI RP-6 states in chapter 5.9 Calibration Procedures, starting on page 10: “Documentation
should be provided containing sufficient information for the calibration of measurement
equipment.” The Requirements in 5.9.1 are:
And chapter 5.9.3, Identification states: “For reference purposes, a system should be established
for identifying calibration procedures.”
And finally, M1-1996, chapter 4.9 states: “Documented procedures, of sufficient detail to ensure
that calibrations are performed with repeatable accuracy, shall be utilized for the calibration of
all ensembles.” That explains it all in one sentence. (This standard describes a calibration system
as an “ensemble”.)
Now that you know what the standards require for calibration procedures, where do you go from
here? Some companies use Original Equipment Manufacturer (OEM) procedures that are in their
service manuals as a starting point. Please keep in mind that a lot of the service manuals have
procedures for adjusting the IM&TE as well as (or instead of!) the calibration (performance
verification) process. Also, some OEM procedures are vague and lack specific requirements
needed to insure a good calibration, such as equipment requirements, environmental conditions
With regard to adjusting IM&TE, there are several schools of thought on the issue. On one end
of the spectrum, some (particularly government regulatory agencies) require that an instrument
be adjusted at every calibration, whether or not it is actually required. At the other end of the
spectrum, some hold that any adjustment is tampering with the natural system (from Deming)
and what should be done is simply record the values and make corrections to measurements.
An intermediate position is to adjust the instrument only if (a) the measurement is outside the
specification limits; or (b) if the measurement is inside but near the specification limits, where
“near” is defined by the uncertainty of the calibration standards; or (c) if a documented history of
the values of the measured parameter shows that the measurement trend is likely to take it out of
specification before the next calibration due date. [5]
One might think of record keeping as a three-pronged approach: the calibration record
(electronic or hard copy), the calibration label (which has the date calibrated, next due date,
name of calibration technician, and a unique identification number of the test equipment), and
the calibration software record (let’s call it CAMS – Calibration Automated Management
System). Each is required in a quality calibration system, and performs a critical function by
itself.
Give full accounting of how to use Adobe Acrobat Professional software to make electronic
records and how they meet 21CFR part 11 requirements as well as anything that ISO might have.
Explain how either Standard or Pro must be used to fill in the form in order to keep the form and
data electronically, other wise they can be filled in using Reader, and printed for filing as a hard
copy.
Here’s a short list of where you can find specific requirements for documenting your calibrations
through the use of records.
By following the guidance in section 5.6, Records, of the National Conference of Standards
Laboratories (NCSL) International’s RP-6, Calibration Control Systems for the Biomedical and
Pharmaceutical Industry, you can decide what is needed for your particular business
requirements. There are four basic areas that need to be covered on every form: identification,
location, calibration history, and traceability documentation. Here is a brief explanation of how a
company could fill these requirements.
Identification: Use a five digit system, where a unique number is assigned to every piece of test
equipment that you support, using a chemical and abrasive resistant bar code label, attached
where it can be easily read on the unit. This 'Metrology ID number' matches the number used in
CAMS, software for tracking, data collection, and historical record keeping.
Location: List the location of each item in CAMS by its room number and the department to
which it is assigned. Since your technicians may go to each laboratory or room to calibrate
and/or repair each piece of test equipment, the criticality of easily finding each item can not be
over emphasized. It has been found that a waste of manpower is spent in searching for test
equipment that has been moved to a new location, and notification is not given so that you can
update our database. Having the location in your database also allows for easy sorting by area as
the need arises, such as when doing like items that are coming due for calibration during a
specific time period. This equates to working smarter, not longer.
Calibration history: Record on each form when the unit was last calibrated, the new calibration
date, and when it will next be due calibration. Show what the working or reference standard read,
as well as the 'As Found', and when needed, 'As Left' readings of the test instrument. The
standards used are identified by their ID number, range and tolerances, and when they are next
due for calibration. Use check boxes to indicate if the test instrument passed or failed its
calibration. Identify the calibration procedure used for that particular calibration. And last but not
least, have a place for the calibration technician to sign and date the form.
When test equipment is found to be out of tolerance during calibration (or when it comes in for
repair or adjustment, and an “as found” calibration is performed and an out of tolerance
condition is recorded), your quality calibration program must have a system in place for
notification, recall, root cause analysis, etc.
Within your quality system, does it make a difference how far out of tolerance the test equipment
is before anyone gets notified? What documentation is involved, and who is responsible for
starting the process? How is test equipment recalled? Who determines if product must be
recalled? A lot of questions, and for most calibration departments, not enough answers.
Here are some examples from the federal regulations on requirements when test equipment is
found to be out of tolerance:
As clearly written in the federal regulations, whenever something is found to be out of tolerance,
it will be recorded, and any remedial action shall also be recorded. As a minimum, the “as
found” reading from the test instrument, as well as what the working or reference standard read,
along with the “as left” reading, after the test instrument was repaired and/or adjusted.
Any additional information that an organization keeps, in what format it is retained, and how the
record is archived is up to their management. [7]
Over the years, I’ve seen quality systems referred to in many forms and variations. For me, this
is the easiest and most accurate way to think of a quality system used for calibration in any
References