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#1 fgjuadi

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Posted 26 August 2014 - 01:02 PM

Hi!

 

I just got an email from a co-man customer who requested a documentation audit, floor audit, and HACCP/Process SOPs. In the same email, the customer casually noted they would "add or subtract CCPs as needed", and asked for a list of QCCPs  :uhm: (I've learned a lot here, and I'm familiar with oPRPs, CPs, CCPs, and QCPs, but never a QCCP).

  

 

They have a prestigious name and it would be great for our business....but I don't understand how to justify adding CCPs if the HACCP team doesn't see it as a risk, and I'm not interested in taking away control on a risk the team has identified.  Is there an approach to documentation for this?  I can't imagine a note on the HACCP review - "Removed CP, customer thought it was unnecessary."  "Added QCCP and RTCP at step 29 and TFMVZP at step 7".   I understand wanting to do business with someone with a metal detector, and I've had auditors & consultants give advice about modifying the HACCP program, which our HACCP team reviews, but I've never given control of it from the HACCP team to the customer before.

 

 


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#2 SQF1188

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Posted 26 August 2014 - 02:23 PM

This is what an auditor would call a "political CCP". Even though your risk assessment doesn't see it as a risk (i.e. physical contamination for metal) many customers want some sort of metal detection or another CCP or QCP (Quality Control Point). We were also required in the packaging industry by a very prestigious customer to have at least one CCP in our HACCP Plan but we really don't have a true CCP since our product is very low risk and our risk analysis doesn't show any high severity concerns.

 

 

As far as them taking away CCPs I would make them aware that the CCPs you have in place already have gone through a risk analysis and your team feels the need to have it there. I can't see a customer wanting to take away a CCP if you've deemed it a critical step in your process.

 

 

With documenting and making it clear in a reassessment log why you may have added a CCP/changed your plan, customer agreements are a perfectly acceptable reason for a change to your plan. ("Metal detection as a CCP was added per customer agreement")

 

 

Overall I'd make it very clear that you're most familiar with your process and have no issue adding a customer required CCP but that it is your plan and your goal is to produce the safest product possible and taking controls out from the food safety plan could potentially risk your product.


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#3 Mike Green

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Posted 26 August 2014 - 02:44 PM

Hi!

 

I just got an email from a co-man customer who requested a documentation audit, floor audit, and HACCP/Process SOPs. In the same email, the customer casually noted they would "add or subtract CCPs as needed", and asked for a list of QCCPs  :uhm: (I've learned a lot here, and I'm familiar with oPRPs, CPs, CCPs, and QCPs, but never a QCCP).

  

 

They have a prestigious name and it would be great for our business....but I don't understand how to justify adding CCPs if the HACCP team doesn't see it as a risk, and I'm not interested in taking away control on a risk the team has identified.  Is there an approach to documentation for this?  I can't imagine a note on the HACCP review - "Removed CP, customer thought it was unnecessary."  "Added QCCP and RTCP at step 29 and TFMVZP at step 7".   I understand wanting to do business with someone with a metal detector, and I've had auditors & consultants give advice about modifying the HACCP program, which our HACCP team reviews, but I've never given control of it from the HACCP team to the customer before.

 

QCCP's presumably are identified in your QACCP (QUAZZUP) plan :roflmao: -(not sure they have any place in you HACCP one!)- I can understand why they need to know what steps you consider to be critical to a quality product--but never heard them called QCCP's before!

 

There is a particular company in the UK-that once almost re-wrote the whole HACCP plan of a company I know who was going to be a new sub-contractor-but they usually at least visited before making changes ....rather than doing it via email! 

 

 

 I always told them to be philosophical about it....& remember the golden rule...He who has the gold makes the rules!

 

Mike


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I may sound like a complete idiot...but actually there are a couple of bits missing

#4 Ekivlen

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Posted 26 August 2014 - 03:06 PM

Overall I'd make it very clear that you're most familiar with your process and have no issue adding a customer required CCP but that it is your plan and your goal is to produce the safest product possible and taking controls out from the food safety plan could potentially risk your product.

I couldn't agree more. 

Unless this customer is going to take sole ownership of the facility, I would not surrender that control. I would "take their advice and consider it at our next HACCP meeting," but to immediately say "OK" wouldn't be advisable. Am I reading this correctly that the customer is requesting this before the audit has even taken place? Their argument holds no merit. Come, sit down, talk to me, learn the process, ask some questions, and then we'll endeavor HACCP revisions. Until then, I'd dig my heels in (Sounds really emphatic, but just as a principle). I generally find that when one change is made in haste, it causes nothing but a snowball effect.

 

I recently had a NYS Agriculture and Markets audit and had to deal with foot stomping that certain stages "need" to be CCP's. Mind you, this was approximately three minutes into the audit. We hadn't set foot on the floor. Eventually, common sense prevailed and the hazards were understood as controlled through pre-requisite programs. Easy-peasy. .

 

Your HACCP plan is just that, YOUR HACCP plan. In the end, with your customer, if YOU determine that it is a CCP, then make the adjustment. If the shoe fits, wear it. 


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#5 Snookie

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Posted 26 August 2014 - 04:09 PM

Sounds like someone who likes to throw their weight around. 

 

Overall I'd make it very clear that you're most familiar with your process and have no issue adding a customer required CCP but that it is your plan and your goal is to produce the safest product possible and taking controls out from the food safety plan could potentially risk your product.

 

I would be careful about agreeing up front to an unknown customer required CCP.  I have inherited some pretty stupid customer required CCP's that were a pain in the nether regions. 

 

I couldn't agree more. 

Unless this customer is going to take sole ownership of the facility, I would not surrender that control. I would "take their advice and consider it at our next HACCP meeting," but to immediately say "OK" wouldn't be advisable. Am I reading this correctly that the customer is requesting this before the audit has even taken place? Their argument holds no merit. Come, sit down, talk to me, learn the process, ask some questions, and then we'll endeavor HACCP revisions. Until then, I'd dig my heels in (Sounds really emphatic, but just as a principle). I generally find that when one change is made in haste, it causes nothing but a snowball effect.

 

I recently had a NYS Agriculture and Markets audit and had to deal with foot stomping that certain stages "need" to be CCP's. Mind you, this was approximately three minutes into the audit. We hadn't set foot on the floor. Eventually, common sense prevailed and the hazards were understood as controlled through pre-requisite programs. Easy-peasy. .

 

Your HACCP plan is just that, YOUR HACCP plan. In the end, with your customer, if YOU determine that it is a CCP, then make the adjustment. If the shoe fits, wear it. 

 

I would agree. 

 

You have gone through many audits through many recognized organizations (if I recall correctly) and your plans have been deemed correct and good.  It would be inappropriate to accept the changes of someone sitting behind a desk who has never seen your facility.  Your QCCP's (that just makes me want to gag) are built into your overall quality plan. 


Edited by Snookie, 26 August 2014 - 04:13 PM.

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#6 fgjuadi

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Posted 27 August 2014 - 11:12 AM

Thanks - they haven't seen the facility yet!  I think I was put off by their cavalier attitude towards it.  But any good QA Manager would rather hear "Our HACCP team has to review that" than "Okay, new QCCP!". Sales will be angered (as they are whenever it's not an automatic "yes").  Obviously we'll end up complying unless they want something insane.  I'm worried they'll want something we can't physically do (squeeze acceptable ranges).  I had to run an "Am I Crazy?" check by y'all.  As I mentioned, they are super prestigious, and they have invested a lot of capital in our equipment already - they purchased specific tooling that cost more than my salary and had it modified for our machines  to package on bar!  Through emails with the mechanic! I'm hesitant to do anything that will throw it off track, and at the same time I want to quash any issues the second I see them. 

 

 

 I always told them to be philosophical about it....& remember the golden rule...He who has the gold makes the rules!

 

Mike

I should print this out and put it next to my desk.

 

This is what an auditor would call a "political CCP".

 

With documenting and making it clear in a reassessment log why you may have added a CCP/changed your plan, customer agreements are a perfectly acceptable reason for a change to your plan. ("Metal detection as a CCP was added per customer agreement")

 

That's a good way of phrasing it...better than mine :gleam:

 

If I find out what a QCCP is I'll let y'all know


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#7 Mr. Incognito

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Posted 27 August 2014 - 11:42 AM

I would respond back about the CCP in this manner - "While we are delighted to be working with you Critical Control Points are something we take extremely seriously and we can't have any added to our system without a full risk analysis performed by our food safety team..." or something like that.

 

QCP are something I had to deal with in SQF Level 3 and I'd assume that the genius that is screwing with your system has probably read the SQF L3 code.  In SQF level 3 you have to have a Food Quality Management System as well as a Food safety management system in which you determine what steps are critical for food quality and have CP's and CCP's for quality basically.  In SQF L3 if your product is out of spec and you ship it you can lose your certification.


Edited by Mr. Incognito, 27 August 2014 - 11:46 AM.

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#8 Mr. Incognito

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Posted 27 August 2014 - 11:45 AM

 

 

Your HACCP plan is just that, YOUR HACCP plan. In the end, with your customer, if YOU determine that it is a CCP, then make the adjustment. If the shoe fits, wear it. 

 

It's easy to say things like that but unless your the ONLY manufacturer that can make their product they can just pick up and walk away.  Depending on how much that copacker makes up your volume that can close a facility.  I've worked in a factory where ~85% of the weekly volume was for one copacker... I'll say, for the most part, we did as we were told.


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#9 cazyncymru

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Posted 27 August 2014 - 02:44 PM

Before we all jump the gun, let them see your HACCP in all its technicolour visio glory!

 

Then, IF they ask you to add a CCP, ask for their justification as to why something should be a CCP. It may be that they have had an issue with a previous co-packer (hence why their moving to you) over a specific issue, and they want to ensure it doesn't happen again. And if they can justify it, then all well and good, but they need to visit you at this point so that they can be 100% sure its the way they envisage it.

 

IF they ask you to remove a CCP, then you can argue that its there on the bequest of another (nameless) customer.

 

Deep breath Mag, its all just a game.

 

I once had a retailer who insisted that date code checks be a CCP, on PREPRINTED  lids! Go Figure!

 

Caz x


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#10 Ekivlen

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Posted 27 August 2014 - 06:29 PM

It's easy to say things like that but unless your the ONLY manufacturer that can make their product they can just pick up and walk away.  Depending on how much that copacker makes up your volume that can close a facility.  I've worked in a factory where ~85% of the weekly volume was for one copacker... I'll say, for the most part, we did as we were told.

We can agree to disagree. I've also worked in facilities that product lines were ~85% of the weekly volume, but NONE of their execs had a clue about food safety. The R&D chef used to love to toss back inaccurate statistics, misguided directions, and generally just try to incite me. Long story short, he had no clue. No matter how big, if the co-packer hasn't put the time/energy into learning your process/facility/PRP's/regulations, then they have no say in telling you what to include in your HACCP plan. Money and volume of business shouldn't determine the safety of your food, right? At the end of the day, if I'm trumped on substance, I'll lick my wounds and concede. Call me stubborn, but my stubborn side comes out when I'm being bullied into something that will eventually create more work for me, confuse my staff, and end up not working in the long run anyway.


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#11 Mr. Incognito

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Posted 27 August 2014 - 06:48 PM

Different circumstances... The company we copacked for knew about food safety, as they operated their own facilities, and had a member of their staff in our facility.

 

However no matter how much they do or do not know about food safety if the majority of what you make every week is their product and they pull out then instead of new CP sheets being handed out there may be pink slips.


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#12 Ekivlen

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Posted 27 August 2014 - 07:04 PM

Different circumstances... The company we copacked for knew about food safety, as they operated their own facilities, and had a member of their staff in our facility.

 

However no matter how much they do or do not know about food safety if the majority of what you make every week is their product and they pull out then instead of new CP sheets being handed out there may be pink slips

Like you've said: Different circumstances - sounds like very different. 

In my case, they'd be handing out pink slips for missing PO deadlines because of non-compliances. I'd rather do what I can to make our operation work smoothly.


Edited by Ekivlen, 27 August 2014 - 07:06 PM.

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#13 fgjuadi

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Posted 15 September 2014 - 08:30 PM

Update:  Just finished up with the customer -

 

They seemed pleasant, smart, and reasonable. I am already monitoring everything they asked for, or it will be easy to monitor.  But they do want to add more than 20 "QCCPs" to the quality plan.

 

Thankfully, they are open to suggestion, and "learning from each other" - so now it's up to us to compromise on it.  I can't manage 25+ __ __ CPs, but maybe I can group them and still make them happy.  I have little doubt we are within limits on all 25 - they remain consistent throughout our process, most parameters are set after calibration (recirculation pump RPM speed anyone?) , and the ranges they gave were very wide. 

 

Maybe temperature as one QCP instead of each stage (for ex, our tempering unit has 5 stages, each at different temperatures)?  I'm not sure it would actually reduce the amount of QCPs, but on paper it would be easier to manage. 

 

They also would like to send out 3 of their own QA for the first "few runs".  I like...the support.... but I'd rather have them rent our equipment out or something.  They're very sensitive to not disturbing our process, but I've never had a customer's QA come out for an entire run, let alone a pack of them! O_O   . (Ed Note:  Is a group of QAs a pack?  Can we call it something cool like a murder or a pride? Or whatever a pack of blood thristy spiders are called? )

 

This will be an exciting project to be sure - they're so high end and well regarded - and I guess this is why.

> 20 QCPs though! My HACCP flow chart only has 20 steps!


Edited by magenta_majors, 15 September 2014 - 08:32 PM.

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#14 Mr. Incognito

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Posted 16 September 2014 - 11:35 AM

Update:  Just finished up with the customer -

 

They seemed pleasant, smart, and reasonable. I am already monitoring everything they asked for, or it will be easy to monitor.  But they do want to add more than 20 "QCCPs" to the quality plan.

 

Thankfully, they are open to suggestion, and "learning from each other" - so now it's up to us to compromise on it.  I can't manage 25+ __ __ CPs, but maybe I can group them and still make them happy.  I have little doubt we are within limits on all 25 - they remain consistent throughout our process, most parameters are set after calibration (recirculation pump RPM speed anyone?) , and the ranges they gave were very wide. 

 

Maybe temperature as one QCP instead of each stage (for ex, our tempering unit has 5 stages, each at different temperatures)?  I'm not sure it would actually reduce the amount of QCPs, but on paper it would be easier to manage. 

 

They also would like to send out 3 of their own QA for the first "few runs".  I like...the support.... but I'd rather have them rent our equipment out or something.  They're very sensitive to not disturbing our process, but I've never had a customer's QA come out for an entire run, let alone a pack of them! O_O   . (Ed Note:  Is a group of QAs a pack?  Can we call it something cool like a murder or a pride? Or whatever a pack of blood thristy spiders are called? )

 

This will be an exciting project to be sure - they're so high end and well regarded - and I guess this is why.

> 20 QCPs though! My HACCP flow chart only has 20 steps!

 

Well that's good.  It can go either way with a customer trying to be a dictator or being collaborative. 

 

You can monitor all of the temps on one sheet but you may need to have HACCP like corrective actions in place if something is out on the Quality Control Points just like a CCP... in SQF level 3 they are treated pretty much the same way.  If a quality parameter is out you are out of control.  If you use different colored paper for your CCPs from your regular paperwork (if you have a/some CCPs) then it might be a good idea to have a separate color of paper for the QCPs.  I like blue... :shades:

 

Good luck!


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#15 Snookie

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Posted 16 September 2014 - 04:35 PM

While I understand the theory to me this analogist to a famous incident where everyone in the cockpit was so busy with the instruments, they crashed the plane.  Sometimes you just have to fly the plane. 


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#16 fgjuadi

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Posted 24 December 2014 - 02:50 PM

Update : This run is scheduled for next week.   We had none communication from them regarding the process itself until yesterday.  The customer sent over an SOP they had written for our process, with a different metal detection process written into the steps.  A process I don't have the wands for, and haven't validated, and isn't included in our HACCP plan.   Then they requested a new battery of testing which we don't do and don't have facilities in house for, but did not give me acceptable ranges, units, limits, or methods for the testing, and they wouldn't provide their guidelines for the testing we do or acknowledge that  

 

So I'm back on the "how rude of them to assume they can change my CCP without asking or notifying us" and  the "awfully presumptuous of them to write an SOP for MY process instead of reviewing the existing SOP" 

 

and it's a real problem because now I'm overly critical of every thing they say and do instead of wanting to collaborate.  I understand in my brain that they are also experts and they know a lot more about the process than I do and I need to learn from them, but GOD, they are so RUDE.    When they visited I asked their QA Director to put on shoe covers before she walked across the mezzanine DIRECTLY OVER OUR PRODUCT and she totally ignored me (okay, she laughed at me like I wasn't serious, so I guess there was some acknowledgement) - and then their chocolatier decided he wanted to taste from our melting tanks and - I swear - in front of me and the QA Director - Stuck his dirty, disgusting tape measurer down into my melting tank and then LICKED IT on my production floor.   At least it was filled with their chocolate, which they think is the best chocolate in the world (I know because they sent several hours insulting our chocolate and insulting chocolate with inclusions, saying that those are candy, not chocolate, and we arent' really a chocolate company which is just about as rude as you can get I think).   I  can't take them seriously now and my animal brain is like "Don't listen to those morons!" but my society brain is like "Respect your elders and the experts they know what they're talking about"   but also "Maybe cuz they've been doing QA for 15 years at the same place they never got continuing education"

 

I hate customers.  


Edited by magenta_majors, 24 December 2014 - 03:00 PM.

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#17 Snookie

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Posted 24 December 2014 - 04:30 PM

Update : This run is scheduled for next week.   We had none communication from them regarding the process itself until yesterday.  The customer sent over an SOP they had written for our process, with a different metal detection process written into the steps.  A process I don't have the wands for, and haven't validated, and isn't included in our HACCP plan.   Then they requested a new battery of testing which we don't do and don't have facilities in house for, but did not give me acceptable ranges, units, limits, or methods for the testing, and they wouldn't provide their guidelines for the testing we do or acknowledge that  

 

So I'm back on the "how rude of them to assume they can change my CCP without asking or notifying us" and  the "awfully presumptuous of them to write an SOP for MY process instead of reviewing the existing SOP" 

 

and it's a real problem because now I'm overly critical of every thing they say and do instead of wanting to collaborate.  I understand in my brain that they are also experts and they know a lot more about the process than I do and I need to learn from them, but GOD, they are so RUDE.    When they visited I asked their QA Director to put on shoe covers before she walked across the mezzanine DIRECTLY OVER OUR PRODUCT and she totally ignored me (okay, she laughed at me like I wasn't serious, so I guess there was some acknowledgement) - and then their chocolatier decided he wanted to taste from our melting tanks and - I swear - in front of me and the QA Director - Stuck his dirty, disgusting tape measurer down into my melting tank and then LICKED IT on my production floor.   At least it was filled with their chocolate, which they think is the best chocolate in the world (I know because they sent several hours insulting our chocolate and insulting chocolate with inclusions, saying that those are candy, not chocolate, and we arent' really a chocolate company which is just about as rude as you can get I think).   I  can't take them seriously now and my animal brain is like "Don't listen to those morons!" but my society brain is like "Respect your elders and the experts they know what they're talking about"   but also "Maybe cuz they've been doing QA for 15 years at the same place they never got continuing education"

 

I hate customers.  

 

I think you're being too nice. 


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#18 RG3

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Posted 24 December 2014 - 05:51 PM

I think we need a whole section of just unedited stuff from Magenta_Majors. I like how this rants go off and at the end of I swear all of them say Edited by Magenta_Majors. I vote for unedited versions of Magenta Majors rants.

 

How can a customer not follow your rules in your facility? One thing I'll try to work on in 2015 is to try harder to hide my facial expressions when I think people are idiots and/or have idiotic thoughts I should say and try to be more collaborative with auditors by letting them think they have great ideas.


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#19 Snookie

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Posted 24 December 2014 - 06:14 PM

I think we need a whole section of just unedited stuff from Magenta_Majors. I like how this rants go off and at the end of I swear all of them say Edited by Magenta_Majors. I vote for unedited versions of Magenta Majors rants.

 

 

I second the motion!!

 

 

How can a customer not follow your rules in your facility? One thing I'll try to work on in 2015 is to try harder to hide my facial expressions when I think people are idiots

 

Yeah I need to work on this one as well. My patience for insanity has gone way down. 


Edited by Snookie, 24 December 2014 - 07:39 PM.

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#20 fgjuadi

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Posted 24 December 2014 - 06:36 PM

 

 

How can a customer not follow your rules in your facility? One thing I'll try to work on in 2015 is to try harder to hide my facial expressions when I think people are idiots and/or have idiotic thoughts I should say and try to be more collaborative with auditors by letting them think they have great ideas.

Sometimes it's so hard...to tell if you're being crazy or unreasonable or on a power trip when you're the only QA!   Sure, I think that's unacceptable, here this customer / expert is saying "that's fine", and the other employees are acting like I'm a mega demon imposing arbitrary rules on them to "bring down the business".     ...sometimes I have to log on and post just to see if someone is going to say "That customer is totally right, you're a pschyo" or if they're going to say

 

 

I think you're being too nice. 

 

It's so hard to judge !  IFSQN is my "I'm not crazy" lifeline.


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#21 Snookie

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Posted 24 December 2014 - 07:42 PM

Sometimes it's so hard...to tell if you're being crazy or unreasonable or on a power trip when you're the only QA!   Sure, I think that's unacceptable, here this customer / expert is saying "that's fine", and the other employees are acting like I'm a mega demon imposing arbitrary rules on them to "bring down the business".     ...sometimes I have to log on and post just to see if someone is going to say "That customer is totally right, you're a pschyo" or if they're going to say

 

 

 

It's so hard to judge !  IFSQN is my "I'm not crazy" lifeline.

 

This is why we all get along so well.  Your not crazy....or at least not about this.  You have to be a bit crazy to do QA in the first place but this place is my sanity, reality check as well.  Hang in there.  Don't let the turkeys get you down.  Ooooh good analogy, especially if your making one tomorrow.  Every time you baste the bird think of them.... :roflmao:  :roflmao:


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#22 cazyncymru

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Posted 24 December 2014 - 10:32 PM

How can a customer not follow your rules in your facility? One thing I'll try to work on in 2015 is to try harder to hide my facial expressions when I think people are idiots and/or have idiotic thoughts I should say and try to be more collaborative with auditors by letting them think they have great ideas.

I have a customer who is the same! Turned up in my factory with false nails and said that at their site they could wear gloves! I smiled sweetly and said "I don't effing care what you do on your site, but on mine you take the effing things off"!!!

Cheeky mare, she's not been back, but I remind my technologist about their standards at EVERY opportunity!!


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#23 Charles.C

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Posted 25 December 2014 - 07:48 AM

Dear Magenta_m.

 

Thks for the continuing, cliff-hanger. I have a few comments / opinions –

 

(1) I’m unfamiliar with chocolateering but, accepting the SQF-required analogy to FS-HACCP, 20 QCCPs is surely nonsense, ie unvalidatable ?

(2) Assuming the answer to (1) is YES, what does that say about (a) the Customer, (b) the Customer’s QA, © SQF, assuming that 20 would in fact be SQF-acceptable.

 

My own answers to (2) would be –

 

(a) Either crass-ignorant or a calculative Menace to competent Producers.

(b) Either willingly-unwillingly, sub-servient / corrupted by (a) or dangerously  manipulative to their own Company, or both.

© Disappointingly unaware of  Food Quality priorities, and particularly in respect to the history of HACCP.

 

Rgds / Charles.C

 

PS – Happy Xmas/NewYear and Best Wishes to the US, FS-Pack. And equally to all our other, we-can’t-do-without-you, posters. Thank you all so much. :doctor::x_biggrin::thumbup:


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Kind Regards,

 

Charles.C


#24 RG3

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Posted 26 December 2014 - 09:10 PM

Do they really have nothing else to do? They might as well own 51% of your company. The owner is probably not sweating it since it doesn't directly affect him. Wait until they want to start to change the process and you would need to bring in capital.


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#25 fgjuadi

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Posted 28 December 2014 - 03:48 PM

Do they really have nothing else to do? They might as well own 51% of your company. The owner is probably not sweating it since it doesn't directly affect him. Wait until they want to start to change the process and you would need to bring in capital.

Ah, well, the customer's owner is paying very close attention!  This is their first project as CEO, so the customer's owner is all. up.  on. it.   But also a n00b.   And a woman :mwah: .  Our owner is also keeping a very close eye because this customer is huge and prestigious.   The customer has already purchased equipment worth more than my salary to put in our factory, and hired an engineer from Germany to come out for a week and install it.  That's the thing!  This really can't fail, so I'm trying very hard to be accepting and welcoming toward them.  Our owner realizes they're rude and they don't really have it together, but couldn't care less, as we are taking their money.    

 

Charles-

1) They're dropped the 20 QCCPs in favor of a new metal detection process. So...hooray?  

2) They're lvl 3 certified :)

 

I always assume incompetence over maleficence,  but here I am at work on a Sunday either way


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