10 replies to this topic

[Cathy]

Is white-out ever acceptavble to use?

If a company uses white out for truck loading plans that very frequently change throughout the day and these changes are not likely to impact food safety or quality or traceability …but then when the final decisions are made and a truck is loaded they make a Xerox copy of the final plan and this becomes the record – might this be accepted?

The white out marks would be visible on the copy…but the copy would be signed and dated as the final record and all else is considered work in progress in a very fast paced environment. The originals with the white out would be thrown away …

These folks are really struggling…they cannot use dry erase boards, they can’t afford anything complex…the cards they write on are too small to make ‘proper’ corrections multiple times per day…..

Has anyone ever had an exclusion from the rule that allowed the controlled use of white out?

[Simon]

You've convinced me Cathy. I would say if there is reasoning behind a decision then you can explain ‘why’ or ‘why not’ clearly and that is very important. Its part of risk assessment and at the end of the day you've got to run a business. Oh and don’t forget to document your reasoning.

[Cathy]

You've convinced me Cathy. I would say if there is reasoning behind a decision then you can explain ‘why’ or ‘why not’ clearly and that is very important. Its part of risk assessment and at the end of the day you've got to run a business. Oh and don’t forget to document your reasoning.

Ok - glad to hear that Simon! - but I wonder if a cetification body will accept this. So many auditors are trained that white out simply cannot be used. A copy of a record might not be as legal as the original. I have concerns and I want to make this work - if possible. Perhaps the key is the difference between a plan - and a record?

[Simon]

The question is will it ever need to be legal and stand up in a court of law. You said it did no affect food safety. You are allowed to argue with auditors you know.

What does it say in the standard about the use of correction fluid?

[Cathy]

The code - under record completion and maintenance says - any alterations shall be authorized and justification recorded. I thought we might write up a procedure that shows who is authorized to change the plans and why. This would address it in a generic way and not each record. I'd like to argue this - and hope to win it but I am doing my homework first!

[Simon]

Like you said earlier Cathy when exactly does a WIP document become a record.

Let's see what the other members have to say.

[D-D]

I'm no expert but I think if you write up a risk assessment that documents there is no risk to product safety or quality then I don't see why you cannot do this. (Although note 3.7.3.2 of the Interpretation Guide says 'use of correction fluid is not acceptable'...).

I work for a company making very low risk ingredients and BRC clearly considers companies making ready meals etc. I am therefore going down the road of risk assessment to show certain things in the 'proper food' environment do not apply to us and will have to debate all of that with the auditor when the day comes. I think it is unrealistic to have a one size fits all.

In this case maybe another approach could be to put your loading plans on an uncontrolled document (e.g. a Post-It!) and then fill out the record at the end of the day when the plan is finalised....?

[Allsafe]

Is white-out ever acceptavble to use?

If a company uses white out for truck loading plans that very frequently change throughout the day and these changes are not likely to impact food safety or quality or traceability …but then when the final decisions are made and a truck is loaded they make a Xerox copy of the final plan and this becomes the record – might this be accepted?

The white out marks would be visible on the copy…but the copy would be signed and dated as the final record and all else is considered work in progress in a very fast paced environment. The originals with the white out would be thrown away …

These folks are really struggling…they cannot use dry erase boards, they can’t afford anything complex…the cards they write on are too small to make ‘proper’ corrections multiple times per day…..

Has anyone ever had an exclusion from the rule that allowed the controlled use of white out?

If there really is no alternative:
1. fully document the procedure.
2. document a risk assessment for the use of correction fluid and necessary controls e.g.
3. restrict and control quantity in use, where stored and identify authorised users of the material.
Good luck

[Cathy]

Thank you for the replies! We will be working with the certification body to discuss this and see how it works out. We are also considering scanning the final card - since a scanned file will be dated and cannot be changed in the computer - this would should a good final record of the events.

[Anne Z]

Hi Cathy,

I think scanning the document is a good system. But remember you can always alert the date of a document. It only takes some time.... and computer knowledge.
Or maybe when you sign the final document (the copy) use a red or different colour pen. Then it's easy to see the copy has been autorised. Like Allsafe said write a good detailed procedure that all other 'documents' which are not signed are no official documents.

Good Luck

Anne

[Charles.C]

Dear Cathy,

If, as i suspect you also fear, the edited in-progress document eventually looks like a sorry mess, i wud almost guarantee you will hv auditor problems. Such things are welded into their operating mode.
I guess it depends how complex the changes are but is it possible to use a small, impressively numbered / named (cheap) notebook with (signed) chronologically updated results and final copying of ultimate data to an appropriate form. I hv used such methods with no subsequent auditor problems for QA operatives working / recording in wet and mucky environments.

Rgds / Charles.C