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Water potability testing and the meaning of the word "annual"

water annual testing

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Marshenko

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Posted 13 February 2014 - 01:12 PM

Had our annual re-certification audit, ended up pulling 5 minors (quite the improvement in score from 2013 with 1 major and 5 minors).

We got clipped on one thing though, which I am considering appealing, but I wanted opinions on first - our water testing program indicates that we test each drop site annually, and that we also keep on file the annual water report from the city.

 

So, our samples last year were sent out on January 31st, 2013.  Our audit this year just concluded yesterday, and he gave me a minor for not having new annual test results to provide to him (and there was a legit reason - our ISO 17025 certified lab wasn't accepting from the start of the year, and isn't accepting tests for another week as they were making some upgrades to their lab).

 

My question is - is that minor really justified?  Even the "annual" SQF audit provides for a +/- 30 days from date of last audit cushion in order to perform the annual re-certification.  Furthermore, annual really means just "once every year" not "once every 365 days" ...

 

I am wondering if it will be worth it to appeal - getting that minor back would take us from "Good" to "Excellent"

 

Thoughts?


Edited by Marshenko, 13 February 2014 - 01:13 PM.


Setanta

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Posted 13 February 2014 - 02:28 PM

Hmmmm, it seems a bit picky, but perhapsthe auditor was looking for you to have another lab as back up since you knew in advance that the other one was unavailable.

I would count a year as from January 31 2013 to January 31, 2014. You are outside that range.

Does it aversely affect Food Safety? Probably not, but that doesn't always seem to be SQF's focus. A solid paper trail does. (my opinion)

Setanta


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Marshenko

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Posted 13 February 2014 - 02:31 PM

Yeah, I get that point of view, but by that theory I'd have to have it done every January 31st or before, and if done before, then I'd have to base annual on that date, and eventually have to get multiple tests done in a year (if I got it tested on January 1st).

 

Unfortunately finding a lab that is both state certified to do water testing and that is ISO 17025 certified brought up ... one lab.



Setanta

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Posted 13 February 2014 - 02:33 PM

I don't follow why you would need to have multiples in a year, if you had one done by Jan 31, each year?


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Marshenko

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Posted 13 February 2014 - 02:38 PM

We got a point because it wasn't done by January 31st.

 

So lets say I got this year's done on January 10th.  Now I have to have next year's done by January 10th according to your logic.

 

So I get it done on January 2nd (in theory).  Now I have to have the next one done before then... New Year's Day is a holiday, so it would go back to December 31st.

 

Just being ultra nitpicky.  I think I'm just going to send out multiple single samples a year from now on anyway.



Setanta

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Posted 13 February 2014 - 02:43 PM

Or you could, in your SOPs, set a month that it will be done. Each January...
However, the key may be to have it done before the audit... :)


Edited by Setanta, 13 February 2014 - 02:44 PM.

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Marshenko

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Posted 13 February 2014 - 02:50 PM

Well I would have done it in January....



Tony-C

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Posted 13 February 2014 - 02:50 PM

May be picky, do you do your own routine sampling of water as well?

 

Regards,

 

Tony



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Posted 13 February 2014 - 10:27 PM

Well, I would change the wording of your policy to say that the water is tested approximately yearly instead of every 365 days. The same is true of metal detector monitoring, we were saying that we passed our wands through every hour. However, I realised that this only backed us into a corner and was not realisitic because no on was standing at the detector ready to drop a test wand when the clock struck 60 mins. It is essentially a situation where we have to do what we say we are doing. So, why make it so dramatic? Just make it easy on ourselves. That is, instead of saying John Doe shall test the MD once ah hour just say that a member of QA or whatever shall do so approximately once an hour.

 

Best Regards,

Taste Maker

Memphis, TN



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Cheza0021

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Posted 14 February 2014 - 05:53 AM

Oh yeah Marshenko appeal. You will be surprise. It's just a matter of principle. I had an audit by an NSF auditor and we didn't see eye 2 eye from day one. On day two I pause the audit to address an issue with their HQ. Got my points back.



Cheza0021

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Posted 14 February 2014 - 06:05 AM

I agree with some of the other post. He should have told you to stay away from listing exact dates & times because  you box yourself in.



SQFconsultant

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Posted 01 March 2014 - 02:14 AM

Regardless of your explanation for not having the test results, the Auditor was justified. I would suggest that you have your water sampling done on a routine basis. Once a year is not routine and a city water report doesn't cut it.


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