Received a Noncompliance Record

Description of Noncompliance

Today at appoximately 0700 hours after establishment's pre-op but before the start of operations, i observed in the processing room dried meat particles and residue in the bottom housing of the band saw. I also observed the floor and the black rubber floor mat used at the band saw was dirty with pieces of meat product and product residue.

this is the complaint that i got obviously. This is my first NR so i just wanted to make sure that my respond was good.

Management Response

The bottom housing of the band saw and the floor were cleaned, washed and sanitised immidiately. The black rubber floor mat was cleaned, washed and sanitised at the end of the day.

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My concern is that we didn't clean the floor mat immidiately do you guys think that would be a problem. And i can't say i just cleaned it right away because i told the inspector that we didn't.

Description of Noncompliance

Today at appoximately 0700 hours after establishment's pre-op but before the start of operations, i observed in the processing room dried meat particles and residue in the bottom housing of the band saw. I also observed the floor and the black rubber floor mat used at the band saw was dirty with pieces of meat product and product residue.

this is the complaint that i got obviously. This is my first NR so i just wanted to make sure that my respond was good.

Management Response

The bottom housing of the band saw and the floor were cleaned, washed and sanitised immidiately. The black rubber floor mat was cleaned, washed and sanitised at the end of the day.

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My concern is that we didn't clean the floor mat immidiately do you guys think that would be a problem. And i can't say i just cleaned it right away because i told the inspector that we didn't.

Sounds like operator training and increased supervision could be added to your corrective actions.

Regards

Tony

Dear maxspeed,

As Tony indicates, there are a minimum of 2 required responses to such an incident -

1. A satisfactorily demonstrated immediate corrective action(s)
2. An evaluation of the root cause of the incident and a proposal for its corrective action.

(these 2 steps are often present in the typical forms for corrective action).

Yr mentioned comments for 1. should perhaps be supplemented by having had a look at samples of the product associated with the period of the incident so as to eliminate any worries about the delayed corrective action.

Rgds / Charles.C

Just to add to the good advice provided by Tony and Charles, there are three recognized tiers to dealing with nonconformities: Correction, Corrective Action and Preventive Action.
From what you say you.

Management Response

The bottom housing of the band saw and the floor were cleaned, washed and sanitised immediately. The black rubber floor mat was cleaned, washed and sanitised at the end of the day.

This is a correction. You have corrected the nonconformity, problem or unsafe situation by cleaning up the area. Of course this should be done immediately.

On its own this correction is not enough and the auditor will be looking for much more. You need to investigate the cause(s) that led to the occurrence of this situation and put in a corrective action that will stop this problem from occurring again.

For example:

Do you have a cleaning schedule? If so why is not being effective? This could be due to inadequate method, equipment, training or supervision or lack or resources from upper management to allow for cleaning in terms of time etc. or other ‘more important’ work pressures. It could be a combination of the above and more. If you look at all of the potential causes and maybe do a fishbone analysis (see attached) that will help you to indentify all of the significant causes and will then lead you to identifying and putting in place adequate corrective action. This should prevent this problem from ever happening again.

There is a third tier which is not always easy ‘Preventive Action’ this is to learn from other mistakes and spread knowledge, carrying out data analysis, proactive monitoring such as auditing and inspections, maintenance and cleaning plans, education, awareness training, discussing with operators etc. This proactive approach can lead to preventive action that stops something going wrong before it happens. You’ve got to be good to get here, but that is the goal. It is much better and cost-effective to prevent errors than deal with the consequences when they happen. To be frank though most companies are far too busy fixing problems to spend time preventing them. Prevention is a different way of thinking.

For now the auditor would be delighted with a rigorous corrective action.

Regards,
Simon

It would be good to see the complete NR. Be sure before you accept it, that it was written properly. The code should not be for an SSOP but should be a saniation performance standard issue (I think the code is 06DO1). In the long run - this makes a difference in your records. It is also important to note, for your protection, in most NR repsonses (if it is true)that "no product was affected by this incident" or "no product associated with this incident enterred commerce".

The other commentors are very correct - you are required to have preventive measures. Read 9CFR part 416 - the section on corrective action will help you.

Also - the attached ffers some simple, brief advice as well. I hope it helps.

It is also important to note, for your protection, in most NR repsonses (if it is true)that "no product was affected by this incident" or "no product associated with this incident enterred commerce".

Good advice

You guide looks quite good but could do with some work on the margins.

One question - is there no requirement to provide evidence of actions/CA/PA with the response? I would normally provide evidence with my response.

Regards,

Tony

Normally auditors asks about the Corrective and Preventive Action Report for the same,

As already said by Simon, Charles, Tony and Other members, I am highlighting simple method for writing such a report and submitting to clear the non compliance record:

Starts with Division/Department Area --> author --> personnel involved --> date and time occurred --> problem description --> Root cause analysis --> Corrective action (responsibility of corrective action and due date) --> Preventive action (responsibility of preventive action and due date) --> Recommended by --> Verification (date of verification) --> End of the process.

Everyone has different thinking and opinion, the situation and how you handle!

Keep asking us,

For an NR in an FSIS regulated plant, checking the evidence is the job of the local consumer safefty inspector. It is very important for the plant to document well in writing and then the inspector checks to be sure all is well.

The importance of these records can be seen here - an article written, in part, based on information gathered through review of NRs...the below was taken from an email from the American Meat Institute...

"Despite our best efforts, a one-sided article on ground beef safety appeared yesterday on the New York Times' front page. The article, "Woman's Shattered Life Shows Ground Beef Inspection Flaws" was written by investigative reporter Michael Moss and can be accessed by clicking here. http://www.meatami.com/ht/a/GetDocumentAction/i/53831 . This story may appear in other papers that subscribe to the New York Times newswire. It also may appear in other papers owned by the New York Times, including the Boston Globe, International Herald Tribune and others in the list found here: http://en.wikipedia.org/wiki/List_of_assets_owned_by_The_New_York_Times_Company



AMI initially heard about this story in May, when Moss began submitting Freedom of Information Act (FOIA) requests to USDA seeking records related to a number of AMI member companies. ..."

For an NR in an FSIS regulated plant, checking the evidence is the job of the local consumer safefty inspector. It is very important for the plant to document well in writing and then the inspector checks to be sure all is well.

So are you saying that an inspector would not expect to receive evidence of CA with an NR?

Regards,

Tony

Written documentation of corrective action is always required but the visual evidence is different. Photos are typically not attached. Test results sometimes can be used but since the answer to an NR is public information, plants sometimes will refer to addditional information only available at the plant.