27 replies to this topic

[smyers]

What is the official stance of using white out (office/plant)? Is just the liquid verision prohibited? what about the tape dispensing version? We are a packaging manufacturer.

[SpursGirl]

I ban the use of any correction method (icluding white out tape) in all locations office and plant. I have also seen the use of small pieces of blank white labels stuck over mistakes - also banned.

 

Any mistake is to be crossed through with one line and initialled by the person making the correction - this is stated in my records and documents policy.

 

In my experience if you have correction fluid/tape in the offices it inevitably ends up on the factory floor. Better to have a total ban than to try and manage use in some areas.

 

S

[Setanta]

Totally in agreement with SpursGirl.  If you work with governmental organizations, USDA, FDA, etc, they will advise you against it.  They must be able to read the error.

[Snookie]

White out is an absolute no-no. Very often regulators consider your trying to hide something and the penalty can be worse than the mistake.   

[ShannonH]

The guidelines for Module 2 of the SQF code state 2.2.2 Records- "On paper-based records, the use of correction fluid to address corrections is not recommended.  A line through the inaccurate recording, with accurate recording and initials of the monitor is recommended."

 

Not prohibited, but certainly not liked!

[Slab]

Do they still make correction fluid? I know that when I first started at my current job it was a common practice to keep correction tape in receiving and the packaging area for tally sheets (along with paperclips and staplers  ), but I quickly did away with that with my jack-booted-correction-tape-dispenser-crushing-gestapo like tactics (yes, I am that QA Manager). I even had to ban the use of pencils and ink of any other color than blue and black for controlled documents.

 

Our policy for corrections is strictly a single strike-through and initials.  

Edited by Slab, 18 August 2014 - 06:53 PM.

[fgjuadi]

No white out!  I've allowed it in office areas if the office area is locked & physically separated from production - my poor accountants !  But if they can get to the office, they can get to white out. 

 

 

 I even had to ban the use of pencils and ink of any other color than blue and black for controlled documents.

 

Our policy for corrections is strictly a single strike-through and initials.  

 

We only allow  glitter pens and black paper  here, because we're all about high contrast & Lisa Frank. 

[Ragga]

The thing with white out is that, people don't like it on official documents as it appears to hide things. Scribbling and "overwriting" is also frowned upon.

 

All records in a FSMS should be considered as official and proper error correction rules should apply. In the case a problem happens it is beneficial for the companies records to appear totally transparent so the evidence provided for a complaint investigation or insurance claim etc.is not doubted by other parties.

 

The number of refresher training documents i've conducted on production and management staff on proper error correction you would not believe and it is still not resolvable, though it has improved somewhat.

[MCIAN]

White outs, pencils and other colored pens (non-black and blue) are not allowed in our entire plant including offices. 

We have guidelines on how to do proper error correction.

 

Regards.

 

[GMO]

Absolutely not. Think about it, if you use white out / tippex etc, you can't necessarily see what was changed. Just a single line through a mistake and an initial to authorise it. Think of your paperwork as legal documents (which they are). White out looks like you're making stuff up.

[Snookie]

The guidelines for Module 2 of the SQF code state 2.2.2 Records- "On paper-based records, the use of correction fluid to address corrections is not recommended.  A line through the inaccurate recording, with accurate recording and initials of the monitor is recommended."

 

Not prohibited, but certainly not liked!

 

You try telling that to the USDA or the FDA......

 

Many years ago....well before my time as I am certainly not old enough to have personally seen this (that's my story and I am sticking to it) it was clearly spelled out in the CFR, (Code of Federal Regulations), it has since been changed and is more inferred, but is no less considered to be required.  They most likely won't shut you down, but they will definitely admonish you for it. 

[Slab]

 

We only allow  glitter pens and black paper  here, because we're all about high contrast & Lisa Frank. 

 

I would seriously have a death-dealing stroke, then haunt the Lisa Frank perp from beyond the grave like that cat-boy in The Grudge 

 

You try telling that to the USDA or the FDA......

 

 

 

Exactly.  Just don't do it boys and girls. I would just as soon put an employee in the soup line at the local shelter than take a non-conformance for record keeping.

[dormant account]

No white out!  I've allowed it in office areas if the office area is locked & physically separated from production - my poor accountants !  But if they can get to the office, they can get to white out. 

 

 

 

We only allow  glitter pens and black paper  here, because we're all about high contrast & Lisa Frank. 

Thank you for this fabulous response  regarding black paper and glitter pens, it made me laugh, and we all need to laugh at the end of the day.

[Snookie]

Thank you for this fabulous response  regarding black paper and glitter pens, it made me laugh, and we all need to laugh at the end of the day.

 

Its also a great way to start the day.....to go through the day......

[Mr. Incognito]

What is the official stance of using white out (office/plant)? Is just the liquid verision prohibited? what about the tape dispensing version? We are a packaging manufacturer.

 

Your policy for white out of any type should be this:

 

Pick up white out,

Walk outside of plant,

Throw in dumpster.

[Jus'me]

It is one of the basics of GMP's for correction of documents, a single line through it with initials, (I usually add the date of the correction for good measure  ), no white out/ no total obliteration, must be able to see what was corrected.  It's a struggle to get people to conform,, I'm always noting "not following proper GMP" on my document audits, we've trained, we've given tests, but people still revert back, but you have to stick to it and be vigilant.  but definitely a "no-no" to use any type of white out or correction tape. Be ready for a fight though, people LOVE their white out!

[Sean Mitchell]

White out (like variation) is evil!

 

We too have official documentation policies that prohibit the use of liquid or tape correction. Simple cross through correction, with initial and date (if room). It is a struggle to get conformance, but we have tried to have some fun with it in our training (I bet there's two words never uttered before in the same sentence...). We have used pop quizzes with funny/obviously ridiculous answer options to get i) folks to laugh and ii) point out how basic and easy it is.  

 

As with everything else, it requires some repetition to get it to stick, but we've seen a significant improvement in our documentation practices.

[RG3]

I think SpursGirl hit it on the dot and SQF does spell it out word for word as mentioned by Shannon.

[fcchoi]

strictly prohibited, mark it out and rewrite with initials, tq.

[PetBone]

I have always been under the impression that both white out (of any kind) and scribbled out responses on paperwork are not acceptable practices. Rather they should be treated similar to how you would correct a mistake on a check, 1 single cross out line with initials and then the correct response written next to the mistake.

[Chris @ Safefood 360°]

I think it has been well established by the vast majority of responses you received that aside from being a legal no-no, the use of white out will give your auditors a poor impression of your overall record/documentation system. 

 

The people that are filling out these records are human and they are bound to make a mistake. Any corrections made must always be done in an authorized and controlled manner (one line/initial). 

 

If a BRC or SQF auditor see records with white out them, you can pretty much bank on getting what could have been a very avoidable non-conformance. 

 

By the way, if you make it a rule that "the use of white out is strictly prohibited" you can pretty much bank on the fact that people are going to want to break that rule for a good while. Once again, they are human after all.....

 

-Chris 

Edited by Chris Domenico, 23 September 2014 - 03:58 PM.

[QA_123]

Is there a written FDA (or any other) rule that states one line and initial mistakes?  

[pHruit]

No idea about FDA, but from BRC IG:

Any alterations to records need to be justified and authorised. A suitable procedure must be in place to manage any mistakes that are made (e.g. neatly crossing through the ‘inaccurate’ information, noting the reason for the error and giving the initials of the person making the change). Note that the use of correction fluid is not acceptable as this makes the initial information illegible.

 

Obviously this suggests single line and initials, but doesn't quite go so far as to outright mandate it as the only acceptable approach, although I'm not sure how else you'd readily accomplish the requirement to leave the original information legible, identify that it is incorrect, and show that the correction is intentional and authorised

[Marshenko]

While there is nothing explicitly that says "one line and initial mistakes" I would suggest that the two bolded statements in 21 CFR 117 in conjunction with accepted industry best practices would apply.

 

Sec. 117.305 General requirements applying to records.

Records must:

 

(a) Be kept as original records, true copies (such as photocopies, pictures, scanned copies, microfilm, microfiche, or other accurate reproductions of the original records), or electronic records;

(b) Contain the actual values and observations obtained during monitoring and, as appropriate, during verification activities;

© Be accurate, indelible, and legible;

(d) Be created concurrently with performance of the activity documented;

(e) Be as detailed as necessary to provide history of work performed; and

(f) Include:

(1) Information adequate to identify the plant or facility (e.g., the name, and when necessary, the location of the plant or facility);

(2) The date and, when appropriate, the time of the activity documented;

(3) The signature or initials of the person performing the activity; and

[larissaj]

I used to work QA in a huge bakery, and we would gather documents or the production workers would turn them in, while reviewing we would find that people had white out or use the white sticker method. We would be quick to check that station and take the white out or the stickers and give them a warning and after a few times people then learned that these things were a no no. We even had to say that white out wasn't allowed in the personal lockers and would do locker checks and write employees there as well.

 

As for colored pens, I am that QA manager that has many color pens for notes. I have purple, green, highlighters of all shades, purple sharpies, list goes on. For anything professional thought, strictly black or blue ink.