19 replies to this topic

[SpursGirl]

Hi

 

Yesterday I performed an audit of maintenance chemicals in our maintenance workshop to ensure all MSDS sheets were available in advance of our SQF audit next week.

 

The workshop is in the corner of the dry/ambient warehouse which is sectioned off by metal caging where the maintenance guys perform 'dirty' work such as welding and grinding.

 

I could not get hold of a maintenance guy so myself and a QA did a quick inventory of the chemicals to compare aginst our MSDS book. Whilst performing the inventory we noticed that there were a number of oils/lubricants/glues in the numerous tool boxes in the area - we then went through all the toolboxes and noted down any chemicals present which we did not have safety data sheets for so that we could then obtain the sheets for the file. We also found numerous personal items in the toolboxes such as personal pain medication, boxes of snuff and cigarettes which we confiscated to the QA office.

 

The workshop was open when I went to perform the audit - it is required to be locked when not in use - and all the tools and tool boxes were left open and unattended.

 

The maintenance guys have now thrown absolute fits as the toolboxes are apparently 'personal' equipment - they are owned directly by each maintenance person and not by the company - and as such they are claiming that QA have no right to go through the toolboxes or to remove perspnal items from them. It also transpires that these tool boxes regulalry travel between the workshop and the homes of the maintenance guys for personal work. 

 

I did not know that these were personally owned and I have apologised that I did not have the owners present at the time of inspection -however all the toolboxes were unattended at the time and not locked to prevent 'unathorised' access. I also stated that the personal items are not permitted to be stored in the toolboxes as the maintenance cage is still under GMP rules as is the warehouse, and that all chemicals must be registered to ensure safety data sheets are obtained which is a requirement of SQF and OSHA. The maintenance guys are now saying that they will not allow inspections of their tool boxes which they will keep locked, and that as personal items we have no right to request inspection.

 

 My concern is that although these are personal toolboxes they are in our facility in a GMP controlled area  and although there is a dedicated toolbox which is kept in the processing area there are times when tools from the personal toolboxes are used in the factory. The policy is to clean/sanitize all tools going into the factory but it just feels wrong that we have no 'authority' to inspect items in our GMP areas which may comprimise food safety due to the movement of tools between work and home use and the storage of personal items in the toolboxes. Even if we retrain the GMP/Food Safety policies to the maintenance guys how to we check compliance if we are aunable to inspect the toolboxes?

 

Has anyone else faced this kind of issue and how do you manage the situation? I now have 3 very angry maintenance guys and with my SQF audit next week I want to get this resolved ASAP.

 

Many thanks

 

Sarah

 

 

[Mr. Incognito]

First off I've never worked anywhere that didn't have some policy that all items brought into the facility aren't subject to inspection.

 

Your maintenance personnel are trying to blame you that you found that they weren't in compliance.  The fact of the matter is THEY are the ones at fault not you.  You should check to see if you have that in a policy.

[mgourley]

Regardless "ownership" of the tool boxes, tools, etc., they are in your facility and therefore subject to any GMP policy you have in place.

 

They should not have the items you found in their tool boxes, HOWEVER, if they keep them locked, to prevent unauthorized access, an auditor is not likely to ask to root through a tool box.

Anything that is not locked, however, is fair game.

 

Another can of worms is the shuttling back and forth of tool boxes and tools. Unless you have a solid tool cleaning and sanitizing program in place, that just screams non-conformance.

 

Marshall

[jkoratich712]

Previous employer did not provide tools/toolboxes for maintenance, so therefore everything was brought from home. However, they were subject to inspection as long as they were not locked and all GMP's policies had to be followed. They were not permitted to bring any chemical's from home and that was stated in our Chemical Control policy. We defined the maintenance shop/work area as 'part of production' and therefore had to follow all GMP's, including no personal items being allowed in those area's, even in their personal tool boxes.

 

Never had an auditor want a tool box unlocked, but did ask about our policies. We were SQF Level 2.

[SpursGirl]

Thank you for your advice!

 

It is written into our policy that tools must be cleaned and sanitized before taking into the factory and in the GMP rules that no personal items to be stored in any area of the facility including warehouse areas (of which the maintenance cage is part) which I did point out to the maintenance guys.

 

It has now gone all the way to our HR department - as a violation of personal rights! - so we will be rewording the Maintenance Control Policy to make it clear that whilst toolboxes are personal property the expectation is that the maintenance personnel follow the site GMP and sanitations rules and that any chemicals in use must be authorised by the lead engineer and QA Manager. If any maintenance personnel are found in breech of the site rules disciplinary action may be taken - HR like putting that phrase in place! The issue is going to be monitoring for compliance as if we cannot check the toolboxes we don't know what is in them!

 

S

[Mr. Incognito]

Good luck and as the laws in Canada are different than the United States it's hard for me to know where this all will fall.  They need to understand that food safety is paramount in the facility and if they are going to have chemicals that do not have an MSDS and haven't been reviewed by the food safety team (depending on your system) then there is going to be a problem and it's not your problem it's theirs.

[SpursGirl]

Hi Mr I

 

This is actually relating to one of our sites in the US - that being the case what is your view on what I can and cannot put in place.

 

Thanks!

 

S

[Myusername]

uhg maintenance....peed off when things break, peed off when there's nothing to fix...always so angry. They tend to be the same everywhere.

 

The way I see this is like a locker policy, its the companies locker, you may use for your personal items and you may lock it, but its on company ground, if management does an inspection you damn well better unlock the door and let the police doggy take a sniff.

 

Personal rights only go so far, video cameras can't be put in a bathroom, camera's installed in the workplace can't record sound, employees can reasonably refuse unsafe work, you can't inspect a personal vehicle. In my province there is a part of the registered food facility legislation that states food production and storage facilities are not to be used to store personal items e.g. cigarettes in a tool box in a warehouse, they only think their personal rights had been violated.

 

So you were no way in the wrong here. You were doing your job that your company has hired you to do, maintenance broke the rules and they got caught and they are looking for a way to weasel out of it to benefit their likes and wants.

 

If you were me, even if that gate was locked liked it should have been I would have a key for chemical control, food safety, site security, inventory, allergen reasons and more reasons I would invent on the fly and I would have done the same thing if not more dramatically by throwing away anything that wasn't medicine or money. I don't apologize for doing my job which you did.   

 

 I would say retrain on your policies, have HR do their thing and Corrective action, root cause yadda yadda continuous improvement so on so forth. And have the higher ups(owners or managers) explain to these guys if they don't like they rules they can play a different game...somewhere else (management commitment).

 

sorry for the rant, things like this enrage me.

Best of luck :)

 

[Mr. Incognito]

Oh then burn them down.  You can have it in place that any unlocked container is subject to search on the premises and if there is reason to believe that there is contraband then a locked container may be requested to be opened for inspection.  

[fgjuadi]

They have a personal right to get paid to work.  If they want to work, they need clean tools.  

 

I've had maintenance shops which use personal tools.  It's poor policy, but done often to reduce the costs of setting up a maintenance department.  I inspected their tools, and they were always kept locked and clean.

 

Who cares if it's a personal item? All personal items are subject to random search.  We conduct locker inspections and inspections of other areas for food defense compliance.  This has never been a problem with HR - We have a sign by the entrance that clearly states property is subject to search when on the premises (that means parking lot too, one time we kept finding booze in the locker rooms and did a car search).  In the US, if you notify, you're allowed to search *  (*check with your HR Department though, sounds like they're already involved) .   

 

If I were having this problem and feeling evil I'd run my quarterly locker inspection at the same time/

Edited by magenta_majors, 20 January 2015 - 08:17 PM.

[SpursGirl]

Thank you for the advice everyone!

 

My view is exactly the same as those you guys have expressed - which was why I inspected the tool boxes in the first place...they were open, unattended and on company property and as such subject to the company sanitaiton and GMP rules. I expressed my apologies that I inspected the items without the owner being present but felt that the inspection was permitted.

 

The maintenance guys are just an awkward bunch and always are angry at something! HR is now getting the policy in place which clearly states that inspections are authorised however the owners must be present. Maintenance are now refusing to use personal tools and demanding company issued tools. It appears I have created a huge row.

 

Such is the life of a technical manager - we are always the bad guys!!

 

S

[Charles.C]

Dear Spurs Girl,

 

Seems the problem was a well established routine. I'm a little surprised that it had not popped up before. And unfortunately it has all the elements of a classic Engineering manouevre.

 

I presume the maintenance workers you refer to are under someone like a Chief Engineer.

 

Hindsight is a wonderful gift but I would have presented the original problem to their Manager before confiscating any items. If for no other reason than simply maintaining inter-Departmental relationships. However I'm not in Canada / USA so maybe things like chain-of-command are done differently over there ?. Or perhaps the Company Policy precludes such ameliatory procedures.?

 

You are right that the QA is invariably in the middle as far as inspections go, damned if you do...... IMEX it pays to keep the Chief Engineer on the same page with yr requirements since they usually will at least come half-way to assisting, and the rest is then fair game.

 

The best thing IMO is that the problem revealed itself prior to the audit. Gives you time to sort it out.

 

Rgds / Charles.C

 

PS - I should add that I have had occasion to be directly confronted with similar unacceptable transgressions from both sides of the fence so maybe slightly biased towards a conciliatory approach.

[SpursGirl]

Hi Charles,

 

It is written in our GMP policy that if personal items are found in areas where personal items are not permitted these will be removed and held in the QA office where the owner may come and collect them. This is in place as in the past we have found items which when we try to establish ownership suddenly no one is admitting it was their property and we wasted a lot of time tracking down owners of candy and such like. We now remove the items and inform the lead in the area what was removed and the owner is welcome to collect the item from the QA's - at which time we take the opportunity to discuss the GMP rules with them!

 

The reason this particular issue with toolboxes has not been highlighted in the past is that this particular toolbox was the property of a fairly new maintenance person who also happens to be the lead maintenance guy. He is a bit of 'loud' individual and actually was very rude to my QA when he went to collect his 2 tins of snuff from the QA office (which has also been addressed) but he has revved up the rest of his team into near rebellion! HR are now sorting that particular mess out.

 

As you point out this happened in advance of our SQF audit - which was the point of us doing the audit in the first place - so we can ensure we do not get a non con during the real thing!

 

Maintenance guys - dont you just love them?!

Edited by SpursGirl, 20 January 2015 - 10:34 PM.

[Charles.C]

Dear Spurs Girl,

 

I assume a maintenance man is the same as what i call an Engineer, ie someone who maintains all the machinery, compressors, lighting in the factory.

 

IMEX  the GMP Policy is copied to / signed off by the "Chief Engineer" as he is usually an integral member of the HACCP team. I assume this is a globally standard procedure. If so then i agree you were acting within FS rights as long as the Policy action was legally permitted within local labour Laws.

 

It sounds like you have been unfortunate with the Company's choice of  Engineering "liaison". Sorry for that. Most of my experiences have been mutually co-operative although occasionally combative.

 

Many locations do not even possess a HR function so that is maybe another operational factor to unintentionally drive closer internal connections.

 

I also admit to having erupted at times during internal audits but most occasions were in the processing area, eg the discovery of a frying pan/sausages near the seafood-only frying line.

 

Nonetheless, Engineers can also be a welcome sight when you are experiencing a liquid ammonia burst and busily running in the opposite direction.!

 

Rgds / Charles.C

[w.weber]

Hello together,

I feel totally like at my plant. Sometimes is is really hard. Take also a look behind PCs, Screens, cable-tray covers, roof exits, cellar rooms, waste bins... You have a good chance to find much more.  Sometimes I am discussing topics like this with the works council, because they will start to claim or push you in front on the court also, if you are not really carefully. 

But everybody should understand, that the toolboxes may enter production and are therefor a high risk for the product. I am always trying to show this risk during the yearly training session. But sometimes some of the people will not understand. 

 

Yours

Werner

[jamesdlm]

Sounds like the open maintenance shop was also a violation of chemical control (assuming chemicals are stored in the shop) an open shop is open access. 

[JSwenPDX]

Firstly, the phrase should be "Hell hath no fury like a maintenance guy's scorn."

 

Secondly, I think quality assurance people make this misstep all too often: not knowing enough about the day-to-day activities and assuming that company policies were effectively communicated.

 

Not to be too hard on you, because I've stepped in it with production folks, but there is an easy way to get around this.

 

Yes, they have to comply with company policy. Yes, they have furnished these carts themselves. Yes, you can go through them and confiscate personal materials per GMPs. No, you shouldn't do this without prior communication of your reasoning and intent to these individuals. They're already disgruntled because they have to provide their own equipment, which is depreciating without any kind of reimbursement from the company. Oh and now the company is taking their precious nicotine!

 

To correct the situation, bake something delicious. Give it to the maintenance guys.

 

To prevent this in the future, give them clear guidelines of what you will be looking for, a week advanced notice, and make sure their supervisor/manager is completely on the same page with you to present a united front.

 

Good luck digging out of the hole - You'll get through the audit and then you'll have plenty of time to get baking.

 

J

[Snookie]

I am curious how it all came out.  Audit, toolboxes, etc. 

[sbarzee]

So interesting. I didn't realize maintenance personnel were consistently recalcitrant across the board. Good to know we're not alone in our facility. Our plant engineer is so mean and grumpy.

[blanemasa]

Hardest part of our job is dealing with people.

 

First step in improving is awareness.