As I understand the last sentence of 18.104.22.168 Measurement Traceability, when measurement equipment is checked for its as received calibration condition and found to be out of calibration, the organization must determine the validity of all of the measurements that may have been adversely affected by that equipment since it was last calibrated and then take appropriate action. Many organizations that can't/don't employ a nifty searchable database, or any other way to enter measuring equipment numbers and how and on what they were used, struggle to implement a cost effective process to provide them with information that will help them determine the validity (and impact) of previous measurements. What's more, they have records to substantiate that they have never received any equipment out-of-cal leading to concerns that keeping time consuming records is a costly response to a low probability risk. In response, an organization states that when measuring equipment is received in an out-of-cal condition, QA searches all NCR's, CA's and customer complaints, from the date the equipment was last calibrated, for evidence of nonconformities directly related to the out-of-cal condition. If any are found, the relationship to that specific equipment is determined and the impact is assessed by engineering, quality, and the customer (if applicable) and appropriate action taken. If none are found, a record is created of the investigation and closed. Do you think this meets the intent of the requirement? Thanks!