Nonconformance disposition history: what to inventory before a quality platform migration

Short answer

Before a quality platform migration, inventory the full chain behind each nonconformance disposition: the nonconformance report with its inspection evidence, the material review board or engineering review, any customer concession, the rework instruction and the re-inspection result. Note which system holds each link, how many years exist, who administers it, whether it migrates, stays read-only or is retired, and the date legacy access ends. Then introduce the quality director and the executive who can authorize a data discussion.

Visual briefFull-size diagram
Six nonconformance record classes sorted into three bins for a QMS migration: open NCRs and CAPAs migrate, closed NCRs, inspection reports and MRB minutes stay read-only and need an end date, old closed CAPAs are retired, and rework travelers are not yet decided.
Illustrative cutover sort. Every record class lands in one of three bins, and the read-only bin needs a date.

What a nonconformance disposition actually decides

It decides what happens to product that failed a requirement: use as is, rework, repair, scrap or return to the supplier. The decision is only half the record; the other half is who was allowed to make it and on what evidence.

ISO's quality vocabulary defines a concession as permission to use or release product that does not meet specified requirements, generally within specified limits. ISO 9001 auditing guidance has auditors check that release under concession was approved by a relevant authority and, where applicable, by the customer. So a well-kept disposition file carries a built-in label: a named authority approved a specific action against a specific deviation. That label is exactly what a migration that keeps only the final status field throws away.

For medical device makers, FDA's Quality Management System Regulation took effect on February 2, 2026 and incorporates ISO 13485:2016 by reference, which can be the reason a device company is moving or restructuring its QMS; the QMSR transition consultant guide covers that trigger. This page is general information, not regulatory advice.

Sort every record class into one of three bins (Illustrative)

Cutover forces a decision for every record class: migrate it, leave it read-only in the legacy system, or retire it. Writing those decisions down is the inventory. Here is a fictional example for a 350-person contract manufacturer of machined and coated housings.

Record classLegacy systemYears coveredAdministered byCutover decision
Nonconformance reportsLegacy QMS2013 to nowQuality engineeringOpen NCRs migrate; closed stay read-only
Inspection reports and measurementsInspection software and MES2015 to nowQuality inspection leadStay read-only
MRB minutes and engineering reviewsLegacy QMS attachments2013 to nowQuality directorStay read-only
Deviation and concession requestsLegacy QMS and email2016 to nowQuality director and customer quality contactsEmail part not in scope
Rework travelersMES2017 to nowManufacturing engineeringNot decided
Linked CAPAsLegacy QMS2014 to nowQuality directorOpen CAPAs migrate; closed retired after 5 years

A row marked "not decided" or "not in scope" is the first question to raise. A row marked "read-only" needs the date that access ends, taken from the contract.

Metadata worksheet for the quality director

Use this as a metadata-only worksheet:

  • Record classes: NCRs, inspection reports, MRB minutes, deviation and concession requests, rework travelers, re-inspection results, linked CAPAs.
  • Time coverage: the year the current QMS went live, and whether earlier NCRs exist in spreadsheets, paper or an older system.
  • Volume: roughly how many NCRs a year, and roughly what share went to MRB rather than a standing disposition.
  • Migration scope: which record classes the new platform will import, which stay in the legacy system and which are archived.
  • Access deadline: the date the legacy license, hosting or read-only access ends, taken from the contract, not from memory.
  • Customer restrictions: whether quality agreements limit reuse of records that cite a customer's drawing or specification.

Root-cause work often sits beside dispositions; root cause analysis records explains why those linked records matter.

Loose ends: concessions in email and customer-owned material

Concessions are often negotiated by email with the customer's quality contact, and only the outcome is typed into the QMS. If the company is changing email platforms at the same time, the same discipline applies to mailbox history; see an email platform migration. Records that cite customer drawings may be restricted by the customer's terms; the customer drawings ownership explainer covers the usual position for contract manufacturers.

Do not recommend keeping data longer than the company's own procedures and authority allow, and do not collect exports, screenshots or logins. Preservation is a decision for the quality director, IT and counsel.

Who to ask, and does the company qualify?

The quality director knows coverage: which systems, which years, what migrates. Authority to discuss licensing usually sits with the CEO, COO or general counsel; finding the right decision-maker helps map that.

The introduced company needs 50+ full-time employees at peak (contractors excluded), a documented operating history, rights to license the records, and an authorized contact. Companies in the U.S., Canada and the EU qualify, as do companies in the UK, Australia, New Zealand, India, Singapore, South Africa, Latin America, the UAE and Saudi Arabia when at least 90% of the data is in English. What stays unknown until SourceX reviews it: buyer interest in disposition histories, the rights review result for customer-cited material, the de-identification needed, and whether an offer follows. Partners sign the Channel Partner Agreement before submitting introductions. Other sectors are on the industries hub.

Go deeper on nonconformance disposition

Next step

Refer a company. Earn up to $100,000. Default reward: 25% of Actual Supplier Payout, capped at $100,000 cumulatively per referred company. Eligibility and payment conditions apply, and a signed Schedule A or addendum can differ. A lead, meeting or signature alone does not trigger payment.

If a client is about to migrate its QMS and years of disposition decisions sit behind the cutover, register as a partner, check the company against who qualifies, and read the program terms before you send the brief.

  1. Step 1Share your linkSend your personal link to a company you know.
  2. Step 2Company appliesThe company applies itself at /apply.
  3. Step 3Company signs and is paidThe company signs, delivers its data and is paid by SourceX under its agreement.
  4. Step 4You get your rewardYour 25% of the actual supplier payout. A reward becomes payable after SourceX has paid the referred company under its signed agreement and the payout conditions in the program terms are met, including finance approval and your tax and payment details.

Common questions

Is a 'use as is' disposition less useful than a rework record?

Not necessarily. A use-as-is decision with an engineering justification and, where needed, a customer concession shows reasoning under a real constraint. A bare status field with no justification is what limits value, whichever disposition was chosen.

Do customer-owned drawings block a licensing discussion?

They can narrow it. Contract manufacturers often hold nonconformance records that cite a customer's drawing or specification, and the customer may restrict how that material is used. SourceX's rights review decides what can be licensed, excluded or de-identified.

Should a company postpone its QMS migration to keep the history?

No. The migration runs on the company's own schedule. The partner's point is narrower: the cutover is the moment someone already has to decide what old records move, stay read-only or are retired, so it is a natural time to map them.

Sources

  1. committee.iso.org/files/live/sites/tc176sc1/files/Terms in TC …
  2. committee.iso.org/files/live/sites/tc176/files/PDF APG New Dis…
  3. fda.gov/medical-devices/postmarket-requirements-devi…
  4. refer.sourcex.si/terms

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