Paperwork Corrections & Completeness

Good Morning :cheezy: 

I am hoping you all might be able to direct me towards any codes and or regulations that speak to a couple current issues I am trying to get people to buy in on.

• The use of white-out on documents. I know this should not be allowed but is there anything that backs up this practice with law (so to speak)?
• The use of quotation marks. Same questions as above.

I am scouring the internet as we speak but sometimes yall are much quicker with information from previous experience than trying to dig it up on google. :headhurts: 

I know in Canada our newest Food Safety Book (from the feds) specifically states that whiteout is not to be used, that a single line through an error is what is acceptable. I would push it as industry best practice to the higher ups.

Under SQF 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."

Same 2.2.2 it says sign

The employees responsible for monitoring critical food safety and quality points (CCPs, CQPs) in the process are required to sign the record indicating the entry and the date it was made (or electronically authorize the entry). In addition, the supplier is required to ensure that staff responsible for verifying food safety and quality records sign and date each record they review as part of their verification activities (refer 2.5.4). These responsibilities and actions must be documented in the procedure.

http://www.ifsqn.com...rds/#entry79622

I am still looking through the Establishment and Maintenance of Records on the FDA website.

We received a minor non-conformance in a audit, because the auditor found ditto marks, pencil & white-out (being used in the office on shipping documents) and corrections not being corrected properly.  I would enforce the no white out and a single line through the mistake

SQF states in 2.2.2.2:

All records shall be legible and suitably authorized by those undertaking monitoring activities that demonstrate inspections, analyses and other essential activities have been completed.

Our understnading is that all documentation be clear and legible. Any corrections that have been covered with White Out or obscured by scribbling out might indicate hiding or changing of documentation. We require a single line drawn through the error, initialed by the writer and a correction made, leaving the original info visible. In addition, we would consider White Out an unapproved chemical if it were present and used in a production area.

In addition to pleasing auditors, please consider that your documents must be able to support your defense or offense, whichever the case may be, should your company ever be involved with any type of litigation or there is a question from the government.
 
I suggest you develop a guideline for what is expected of the employees when documenting on your company's records and have the employees sign and date when they are trained on them.

Some basic guidelines for Recordkeeping might be:

• Falsification of any type is unacceptable and will not be tolerated.  Any employee found to have falsified documentation or supported the falsification of documentation will be subject to immediate termination upon completion of investigation.
• Use ink pens in plain black or blue ink only.  Pencils, erasures, erasable ink and/or White Out are not to be used.
• Write full date with month, day and year.
• Fill out all requested information.  Do not leave blanks nor use ditto marks or anything that represents ditto marks.
• Data is to be documented at the time of the event and times are to be "real", meaning what the clock says when you are documenting is the time that you record.
• To make a correction on documents: *Draw a single line through the error (error still needs to be readable).  *Document the correct information.  *Record your initials/signature and the date that you are making the correction.  (Note: If you document is time related then you may require the employee to also record the time the correction was made.)