11 replies to this topic

[Elsa_Milwaukee]

During the annual document review I found something appalling...the documentation we use for label verification was found to have several cross out errors and in some instances a missing initial.  I have my first BRC audit in a month and I am scared!

 

I view this as a serious violation of my Food Safety & Quality Management Program!!!

 

How did this happen?

 

We conduct a daily audit every 4 hours BUT we physically verify the information on the product/box is correct, no one looks at packaging's paperwork and they kept it filed (hidden) in the shipping office.  

 

I immediately issued a Corrective Action & Preventative Action:

 

*The two people who were responsible for the paperwork were supervisors, I have demoted them effective today.

*I have modified the daily audit to include physical paperwork checks in addition to the physical inspection of the products

*I now require that all paperwork be turned into my office at the end of each shift so I can review everything daily or at least every other day

 

 

Help me!  Is this going to be good enough, I cant believe this was happening and no one knew about it!  It may seem minor, but it is definitely not!!!

 

Thank you!

[Charles.C]

Hi Elsa,

 

I'm not quite clear as what/where the error actually was.

 

I think you are talking about monitoring/(record)verification of a HACCP labelling CCP.

 

IMEX this would be performed by separate QA Operatives of the HACCP team using a (combined) HACCP system form.

 

I don't quite understand how the production supervisors are involved. Do you mean that  Production's  own data  is not in agreement with that verified on the haccp form ?

 

If so would seem to  indicate 2-3 areas of Corrective Action / RCA.  Are you are wearing both Production / QA hats ?

[Elsa_Milwaukee]

The production supervisors are responsible for filling out the verification paperwork for labels before new product production begins, the paperwork contains cross out errors on almost each one. For example, they wrote over batch numbers, wrote over numbers, etc. In some instances, they are missing their initials which is needed before production could start.

[Charles.C]

Hi Elsa,

 

Thks for comment.

 

So this is routine "QA" (done by Production), not related to haccp plan, eg no allergen related issues on labels ?

 

There is no QA function involved at all ?

 

(IMEX, production are also responsible for setting up the labels but the actual application requires a QA check before implementation)

 

Maybe it depends on what you mean by "paperwork", IMEX the detail on masters for retail labels are required to be officially authorised by customer prior to printing.

[Charles.C]

Hi Elsa,

 

Sorry for all the queries but the reason is that yr corrective action relates to the scope of the deviation/RCA.

 

If the net result is no significant FS consequences i daresay BRc will not be that concerned from a product POV.

 

But whether there is a necessary corrective action for yr haccp control measures, for example regarding verification, depends on the details of yr haccp plan. If this actually is haccp-related. I imagine BRC would have the same interests.

[Elsa_Milwaukee]

There is no negative effects on our HACCP, we have no allergens in the plant.

Like you mentioned with IMEX in your post, that's what they are doing. They set up the labels for boxes and finished product. The supervisors are supposed to check together, which they do but there are so many mistakes on the paperwork I do not feel that I can trust them. They are recording lot numbers for bags and boxes on the same paperwork, I don't feel comfortable in believing there are no mistakes...

[dshapos]

This is a training issue.  Cross-outs, initials, and if needed, a brief explanation somewhere on the front or back of the doc.  You did a corrective action, now you just need to verify it is being followed.  Document that as well and you'll be fine.

[Charles.C]

This is a training issue.  Cross-outs, initials, and if needed, a brief explanation somewhere on the front or back of the doc.  You did a corrective action, now you just need to verify it is being followed.  Document that as well and you'll be fine.

 

RCA ? (this is BRC)

[trubertq]

I agree with dshapos. This is about training, making sure whoever fills paperwork understands that if they make a mistake, they need to cross out once , initial and then fill in an explanation somewhere on the record. 

 

You have discovered the error, and have put a corrective action in place. In my experience, all records should be cross checked daily by QC or supervisors ( for production documents) to make sure they are filled correctly, otherwise stuff like this can go un-noticed for weeks.

 

It isn't a major issue since you have detected it and reacted in a timely manner.

 

Have you got a record keeping SOP? Always useful for these situations, it outlines exactly what you expect from record keepers.

 

Chin up... it will be OK!!

[Wowie]

 

 

It isn't a major issue since you have detected it and reacted in a timely manner.

 

Have you got a record keeping SOP? Always useful for these situations, it outlines exactly what you expect from record keepers.

 

 

 

 

And I agree with this.

 

Also, please don't be scared! You discovered a problem in your FSQM system, documented it, and are correcting it. That is your role; that is what you do. Just because you found the issue after it had occurred for some time does not mean this is a total failure of your system. All of us, during BRC prep or, much, much worse, during the BRC itself have had those "Oh, %&*(" moments when looking over documentation. We've all survived!

 

You said you conduct an audit every 4 hours is THAT a QA function, or production as well? Doing an update to an existing SOP if needed, or creating an SOP is certainly something I would look into. In addition, training for all team member's responsible for documentation that affects the Food Safety or Quality systems would be held immediately. Aside from that, you will be fine. Practice talking through that one for if/when the auditor brings it up. Remember to not talk down about the people who made the error, instead stick to the identified root cause in your investigation and confirm with following up how it has improved. Effective corrective actions and preventative measures are also audited by BRC, so this just gives an extra opportunity for you to display that. 

[Elsa_Milwaukee]

Thank you everyone!  This has really been great advice, it just gets difficult especially with something so simple...YOU ALL ARE GREAT!!!

[Notsewb]

Thank you everyone!  This has really been great advice, it just gets difficult especially with something so simple...YOU ALL ARE GREAT!!!

How did you Audit go?