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#1 klward23

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Posted 13 June 2014 - 06:05 PM

I having trouble with some production folks getting on board with no staples or paperclips.  They think putting them in the clear sheet protectors when in production will be enough protection.  I had previously never heard of this practice and have only been in facilities where none are allowed period.  We do not have a metal detector or x-ray of anytype.  We currently allow staples and paper clips in the warehouse areas.  So are these clear sheets protectors enough?

 

We are in the process of preparing for our first SQF audit to be complete by the end of 2014.

 

Any help would be appreciated, thanks in advance!



#2 Mr. Incognito

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Posted 13 June 2014 - 06:21 PM

:welcome: to IFSQN

 

Now:

 

collect all of the paperclips and staples and throw them straight into the dumpster.

 

are you talking about using sheet protectors to keep all of the operator's production paperwork together?  I collect all of our paperwork and file it.  I just pick the paperwork up and file it lol. 

 

However!

 

You can get a stapleless stapler.  They punch and crease paper together to keep them from coming apart.  If you use one have them use it in a corner with 1 punch from 1 side and another punch from the other side of the corner (like top and left for top left staple).

 

They work.. they aren't perfect but we use them for some areas like a BOL with the inspection paperwork and the lot testing sheet.

 

like this one: http://www.officesup...65YNu54Fd_D_BwE

 

then get rid of all the staples and paperclips even the ones in shipping and receiving.


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#3 klward23

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Posted 13 June 2014 - 06:32 PM

Thank you for the reply!

 

I started eliminating and throwing things away and that is how this started.  

 

They came up with the idea of sheet protectors for the order sheets that the operators work off of.  My argument back to them was just put them on metal clip boards but apparently they keep multiple orders and the staples keep each order packet together and some orders are more pages than the staple-less paper staplers can go through (think 10-20 pages, and the paper staplers I've found only do 4-8).

 

I obviously am not getting the senior management support on this to back me, so even they are asking for documented 3rd party policies or rules clearly stating no staples in either the SQF code or something from FDA or USDA.

 

As far as the warehouse the product is a finished packaged good at this point, are you are saying still eliminate everything?



#4 Mr. Incognito

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Posted 13 June 2014 - 06:44 PM

yes... yes I am.  Your auditor will say "how do you know people aren't going to take it out of the warehouse and use it in production".

 

Get the stapleless stapler and you'll be a hero.

 

I looked briefly through the SQF code (2 and 11 I'm not sure what module your using) and I didn't see anything directly in there.  What is your product?  I'm fairly sure the auditor will not be happy at all if you have staples and paperclips on the floor with no way to detect if one fell in... trust me it could get bad.

 

If anyone knows a section that this falls into please feel free to copy and paste.


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#5 Mr. Incognito

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Posted 13 June 2014 - 06:50 PM

Also start throwing away any pens and markers that have caps.  You want pens and markers that are clicky.  Blue and black ink is a good policy for documents not red, hot pink, orange, etc.


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#6 klward23

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Posted 13 June 2014 - 06:54 PM

I also was looking in modules 2 and 11 as well and looked through the guidance documents as well to see if it was in there; our main products are spices.  They had a pre-assessment before I started with this company and they weren't directly told anything and nothing is in the report, thus the shock when I said no, none at all.  I have previous experience with BRC and to the best of my memory and looking at other threads looks like they at least use the word staples, so yes if anyone knows where this is mentioned in SQF would be helpful.



#7 klward23

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Posted 13 June 2014 - 06:58 PM

Thanks for the mention of the pens, that was surprisingly easy change for them to get use to as they were for the most part following it already when I started.  Just found the random individuals who had brought there own pen that had a cap but those individuals have since been properly trained and now will be monitored and checked during internal audits.



#8 Pizza&Sandwich

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Posted 13 June 2014 - 07:09 PM

The thing about SQF is that it doesn't tell you what you have to do. It states that you have to prevent contamination via foreign materials, but doesn't tell you what or how. It's all about how you justify that something IS or ISN'T a high risk. For example: We use paperclips & staples in our production rooms, but they are typically 6-10 feet away from the open food products and we have metal detectors. The metal detectors can detect a staple. Therefore I do not see this as a high risk as this most likely would not cause serious harm for the customer and is unlikely to reach the product. Then add in the fact that we do have metal detection after packaging and it becomes a non-issue.

We use 3-ring binders to keep paperwork together. Would this be an option for you? They could separate orders by section dividers.



#9 Snookie

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Posted 13 June 2014 - 07:42 PM

If they are reusing the sheet protectors, make sure they are not getting dirty or ripping as then the plastic has the possibility of becoming a foreign contaminant. 


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#10 fgjuadi

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Posted 13 June 2014 - 07:56 PM

Thank you for the reply!

 

I started eliminating and throwing things away and that is how this started.  

 

They came up with the idea of sheet protectors for the order sheets that the operators work off of.  My argument back to them was just put them on metal clip boards but apparently they keep multiple orders and the staples keep each order packet together and some orders are more pages than the staple-less paper staplers can go through (think 10-20 pages, and the paper staplers I've found only do 4-8).

 

I obviously am not getting the senior management support on this to back me, so even they are asking for documented 3rd party policies or rules clearly stating no staples in either the SQF code or something from FDA or USDA.

 

As far as the warehouse the product is a finished packaged good at this point, are you are saying still eliminate everything?

You could say  "we have no staples on the floor to minimize contamination.  The food saftey team assess the risk, and it is common practice to not have staples in production because the risk of them falling off of paper is so high."  I know AIB have a specific standard that says no staples, but I don't see one in SQF.

 

 

For citing SQF (these are streching the standards to meet your whims, something probably not good to do) -  I'd say it was a temporary fastener or loose metal object.  Both of those are covered in the standards, but apply to equipment, not "stuff".  Maybe your senior management won't read too closely.

 

11.7.5.3
The
use of temporary fasteners such as string, wire or tape to fix or hold equipment shall not be

permitted

 

Or

 

11.7.5.6
Loose metal objects on equipment, equipment covers and overhead structures shall be removed or
tightly fixed so as not to present a hazard.

Edited by magenta_majors, 13 June 2014 - 07:58 PM.

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#11 Mr. Incognito

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Posted 13 June 2014 - 10:18 PM

Yeah SQF isn't always very specific... Best practice is no staples or other fasteners of that nature that's why I suggested the staple-less stapler.


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#12 EmpireFoodSci

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Posted 16 June 2014 - 05:07 AM

A staple-less stapler is definitely the way to go. Even if you allowed them in the warehouse or shipping areas you'd open yourself up for some questions from your auditor. While staples, paperclips, and other like items aren't directly addressed in the SQF standard, if an auditor sees them in product handling or storage areas it would definitely raise a red flag.

 

Also, if you're having some trouble with people getting on board with the idea of no staples, you might want to monitor it during your internal audits, like you mentioned with the pens. 


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#13 Charles.C

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Posted 16 June 2014 - 06:20 AM

Dear All,

 

This thread is rather fascinating in a horror story sort of way. :smile:

 

I seem to recall that SQF run courses to train/qualify the mandatory "Practitioner". I suggest the question of how acceptable SQF regards the use of staples for documentation purposes within the Production arena etc be posed therein.

 

I  predict that the response will unreservedly be No Way.

 

Frankly, IMO, the OP is simply another easy example of a NC within the (Top) Management Committment category.  And hence the solution.

 

Should be an interesting audit. Plus perhaps an audit of the SQF system itself, by default.

 

Rgds / Charles.C


Kind Regards,

 

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#14 cazyncymru

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Posted 16 June 2014 - 08:15 AM

We don't use staplers or paperclips in the factory. In fact, id be hard pushed to find a paperclip in the office (which does annoy me sometimes!)

 

Doesn't stop us having the (odd) complaint of a staple in product. I had one recently (only 1 I've had to be fair) where they found a 6 staples, still attached to each other, and rusted, in our product. But I'm ahead of the game, as part of my metal detector validation, I embedded 1 staple into our product and passed it through the metal detector. and it was picked up. I then left some staples, for the shelf life of our product, in a packet, and it did not rust. I took before and after photos, documented everything,  I also did this with a hair grip, paperclip and a popper from our overalls.

 

You should tell the powers that be, that you have done a risk assessment on foreign body ingress into product, and that the risk from staples was high.

 

Caz x



#15 fgjuadi

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Posted 16 June 2014 - 10:53 AM


 

Frankly, IMO, the OP is simply another easy example of a NC within the (Top) Management Committment category.  And hence the solution.

 

Should be an interesting audit. Plus perhaps an audit of the SQF system itself, by default.

 

Rgds / Charles.C

This is brilliant.

 

This is the best universal answer to everything ever when someone doesn't want to do the right thing, but would an auditor ever bring up that NC for anything but a missing policy document?  I mean, I can't see an auditor walking in and saying "This place looks terrible! Staples everywhere!  Audit over, management not committed"


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#16 Mr. Incognito

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Posted 16 June 2014 - 11:34 AM

Well to be fair I can see management not believing that they can't have them if the standard doesn't state it... however what people have to wrap their head around is that, especially in SQF, you have to embrace the idea and spirit of what the code intends and then look at everything and make a good decision if it's in the spirit of the code.

 

 

Can staples be a foreign material?  Yes.  Can it be mitigated? (Arguably) Yes if you have a metal detector... however at that point it's already been introduced into your product.  Is there a way to ensure it's not introduced into your product? Yes. Remove them all.  How can we remove them all?  Look at options, select one, implement one.

 

It's a constant pull sometimes between management and quality.  It's all dependent on what they want out of their standard.  Does (other) management want a safe food or a piece of paper so they can sell their food?  I mean nobody really wants to make bad food... but if your management team really wants safe food they will be willing to do things that may not exactly be written in the code to ensure that their food is safe.

 

In the end if you can't get them to change it make sure you have it brought up and recorded in the food safety team (or equivalent team's) notes that it was reviewed and that you were against having them in production/storage areas so that they can't try to come back on you if you fail your inspection.  CYA!


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#17 fgjuadi

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Posted 16 June 2014 - 11:53 AM

Well to be fair I can see management not believing that they can't have them if the standard doesn't state it... however what people have to wrap their head around is that, especially in SQF, you have to embrace the idea and spirit of what the code intends and then look at everything and make a good decision if it's in the spirit of the code.

THIS. X 999

 

I can't tell you how many times I've had minor clashes with our management about this.

They ask me what the standard says and I say "The standard is what our food safety/HACCP team decides.  Is control more expensive than a lawsuit?"

 

I have good management so they understand and will usually adapt, but there's always this initial response to ask if it will cause us to fail an audit.  Like if something is a minor ding, they're okay with not changing it because change is hard. What they don't understand is the impact that has on food safety.  If one staple isn't a problem, then you have push pins, then you end up with a little pile of minor non conformists. On their own tiny transgressions, put together, risk to food safety.  People stop looking for risks outside of the standard.  It puts blinders on.

 

There's nothing in the rule book that says a giraffe can't play football (Ed note: I have your baby in me, giraffe)


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