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How to reduce the amount of document verification?

verification validation sqf packaging document

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#1 SQF1188

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Posted 25 February 2015 - 03:08 PM

In our facility we make food packaging for the quick-service restaurant industry. We run multiple types of machines to convert paper to bags, napkins, you name it etc. We are SQF Certified Level 2 as of this last year but are looking at ways to trim some fat from our system and checks by doing risk assessments and writing exemptions to some articles of the code for our sector. We are very low-risk and have all our validation and verification in place. For daily verifications we do a records review and sign off on documents that include our pre-requisites (Pre-ops, Product release, foreign material checks, etc.) This takes up a large amount of time with anywhere from 150+ documents to look at and sign daily.

 

Does anyone else have this large amount of documentation that they verify on a daily basis and go about it any different way? We've considered sampling from the weekly documents and if they are all acceptable to have that as verification. If there are documents found to be unacceptable we'd up the number of documents we reviewed for the following week and do re-training with employees for documentation.

 

We've also considered doing direct observations for verification of completing pre-requisite programs more frequently and not reviewing documents at all. 

 

Both of these concern me because I could see an auditor coming in and finding a lot of mistakes on paperwork and docking us for it or us having missing checks that we didn't even realize we had.

 

Any suggestions?



#2 ChocoTiger

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Posted 25 February 2015 - 05:45 PM

If the daily verification of your records is a requirement for a "Pre-Shipment Review" type program, then you may want to change it.  We have a Passive Release Shipping Release Program, so I review the lab results, hourly checks log sheets, the pre-op sanitation inspection, post-op sanitation inspection and sanitation shift cleaning forms each day.  Product is released for shipment if all of these parameters are acceptable.

 

In our production and sanitation departments, supervisors sign off on paperwork generated in their areas/departments each day.  This puts the verification of daily records, and resolution of missing/incorrect data squarely on them.  You could perform a random weekly verification of the overall paperwork, to verify supervisors/leads and their employees are performing their assigned tasks properly.  In my opinion, you need to review documents in addition to Direct Observation, because you need to verify the information you observed was documented correctly.  (Example: For our CCP, Direct Observation and Recordkeeping Verification need to be done at least once a week). 



#3 jenmarshall

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Posted 05 March 2015 - 05:41 PM

Two things -

1) Do't confuse Sections 2.5.3 and 2.5.4 as the same thing.  Verification Schedule (2.5.3) says that YOU define what you verify, the frequency of verification and whose responsibile. 

Do this based on risk assessment.  Sampling of records as you described above is perfectly acceptable if you have verified records for a year and found a minimum of non-conformances.

 

2) 2.5.4 is focused on the monitoring of pre-requisites, CCP's and CQP's - these methods/frequency should be spelled out if you HACCP/Product Quality plan.  Again, my experience is that this is a risk assessment based on how much product you are willing to put on hold and scrap if you find an issue.  For example, I can decide to only check my metal detector paperwork once a month, but if I find non-conformances and have to recall product, that has a significant business impact both financially and to the reputation of my business.  In my plant we have also integrated several pre-requisite verfications into one activities like our monthly GMP inspection (we check GMP, cleaning schedule verification, chemical inventory, and MSDS availability - all in one shot.)

 

Good luck and I'm confident you can work that list down.  Just make sure you do it with an eye towards risk assessment and you document your justification extensivley.  You should also consider (and document) who participates in the risk assessment discussion - make sure the group is cross functional with your management team included.  The management committment section (2.1.2.3) says that "managment shall ensure adequate resources", so if you're choosing to use your resources on something besides verification you need to make sure they agree with you. 



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#4 Charles.C

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Posted 06 March 2015 - 05:02 AM

Dear SQF,

 

I would have thought 150 forms to scan per day would justify a proper Documentation Section. If you have a budget.

 

Regardless, frequency reduction processes, (assumed to be SQF acceptable in principle), have occasionally been discussed on this forum by ad hoc procedures. The typical route is to initially do 100% for say 1 year. If 'satisfactory" reduce by 50% and repeat for maybe 6 months, "ad slightly infinitum".

 

The "trick" is to present a logical proposal (AKA risk assessment) in respect to the times, scaling factor, and the minimum sampling scan . From an auditorial POV. a reference is also helpful, even if only for an analogous situation. i recall some similar cases  exist in earlier threads here for calibration frequencies of scales which have a similar conceptual problem where there seems to be no standardized solution unless you enjoy deep statistical theory.

 

If you wish to elaborate the above procedure (but not advised if avoidable), can add a check routine such that failure of the reduced procedure causes a switch to the previous next level up plus later reversion if then shown ok again. This up-down methodology has an established validity within the AQL/MIL.Std official sampling texts. I can post a short extract if you are interested.

 

Regardless, IMEX auditors are insatiably sucked in by multi-staged logic processes as long as there are no obvious textual blunders. :smile:

 

Rgds / Charles.C


Kind Regards,

 

Charles.C


#5 ladytygrr

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Posted 25 September 2015 - 02:22 PM

Hi guys,

 

I'm resurrecting this topic. I think that jenmarshall's post above re: 2.5.3 answers my question/concern but would appreciate additional insight if I'm off base.

 

We are a snack food manufacturer on our way toward SQF L2. We are working with a food safety consultant whose main experience is with BRC but she has 35+ years in the food industry and is very close to getting her registration/licensure/insert-correct-term-here to be an official SQF consultant as well. 

 

She came in to do a review of our HACCP program and stated that SQF auditors are going to expect to see sign offs on pretty much any form we've created related to operations. I started reviewing our forms for content and to decide how often we could/should do a review. Most of the forms are obvious that we'd want to verify: Outgoing (Shipping) Log, Product Weight Checks, etc.

 

Some, however, are less obvious. We have one where we enter the total number of master cases we've packaged and any "loose" single packages of product. Why am I going to sign off on that? I realize our total production count will factor into traceability in the event of a recall or withdrawal. Is that my answer to this particular situation? That if those numbers inform us for traceability we'd basically be stupid NOT to have second count? Should I be double counting as soon as they finish packaging?

 

We also have a sign off for our primary packaging film. We have a double sign off to ensure the correct film is being put on and you cannot submit the form unless all fields are completed. So the secondary check is built right in. Granted, it's not necessarily done by a supervisor. But if they can't submit the form unless all fields are completed and there's already a second check for film integrity in terms of correctness, what am I signing off on?

 

Management is VERY against tasks or documents for the sake of tasks or documents so I'm trying to strike a balance between respecting that portion of our corporate culture but "obeying" SQF.

 

So, if we write something that states we are verifying X, Y, Z, Q forms daily; A, B, C forms weekly; and L, M, N, O forms monthly, and leave the rest of the forms out of it, are we meeting the requirement of 2.5.3 wherein we define what is verified, how often, etc.?

 

Thank you in advance,

 

~Emily~


Once in a while you get shown the light, in the darkest of places if you look at it right. -Grateful Dead

 


#6 Charles.C

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Posted 25 September 2015 - 04:47 PM

Hi Emily,

 

There was recently another thread here on Verification Frequency for food. Focussed mainly on CCP from memory

 

Some official validatory data was provided to support max. weekly review delay although individual posters preferred from 1-7 day limits due aspects such as you mention, eg  risk of losses

 

Whether a Food thread can validate a Packaging one, no idea. :smile:


Kind Regards,

 

Charles.C


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#7 ladytygrr

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Posted 25 September 2015 - 05:40 PM

Thanks, Charles. I'll do another search to see if I can find the thread you're referencing. Since we're a food mfr, that one may be a bit more relevant to our company anyway.

 

Thank you!


Once in a while you get shown the light, in the darkest of places if you look at it right. -Grateful Dead

 






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