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Major NC for Ants

Major Ants NC

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#1 PSC

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Posted 18 May 2016 - 10:22 PM

We just finished our BRC audit. We had 7 minors and 1 major. The major cost us our A grade. The major were for some ants that were seen in the middle of our production floor. I've never seen this issue in our facility. They weren't there a few hours before the walk-through with the auditor.

 

The auditor told us he spoke with the person that reviews his report and he argued for it to be a minor, but his senior stated that they must stay consistent and it needed to be a Major. Clearly it's an issue we are at fault for and if it's legitimately a major then we'll accept it. However, if there is there is evidence to support an argument that it should be a minor, I'd like to argue the Major non-conformity. 

 

My question is this: Is finding a few ants in an open product area (high-care) considered a Major NC? Is there anyone else who has experienced this issue or something similar and what type of NC did you receive?

 

 

p.s. It was a very small amount of ants (10-20 maybe).

 

p.s.s. The auditor told us they do not distinguish between ants and roaches. Meaning, they do not view them differently when they see them in a facility.



#2 Charles.C

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Posted 18 May 2016 - 11:37 PM

We just finished our BRC audit. We had 7 minors and 1 major. The major cost us our A grade. The major were for some ants that were seen in the middle of our production floor. I've never seen this issue in our facility. They weren't there a few hours before the walk-through with the auditor.

 

The auditor told us he spoke with the person that reviews his report and he argued for it to be a minor, but his senior stated that they must stay consistent and it needed to be a Major. Clearly it's an issue we are at fault for and if it's legitimately a major then we'll accept it. However, if there is there is evidence to support an argument that it should be a minor, I'd like to argue the Major non-conformity. 

 

My question is this: Is finding a few ants in an open product area (high-care) considered a Major NC? Is there anyone else who has experienced this issue or something similar and what type of NC did you receive?

 

 

p.s. It was a very small amount of ants (10-20 maybe).

 

p.s.s. The auditor told us they do not distinguish between ants and roaches. Meaning, they do not view them differently when they see them in a facility.

 

Hi PSC,

 

  Critical  Where there is a critical failure to comply with a food safety or legal issue.
•  Major  Where there is a substantial failure to meet the requirements of a ‘statement of intent’ or any clause of the Standard or a
situation is identified which would, on the basis of available objective evidence, raise significant doubt as to the conformity of
the product being supplied.

•  Minor  Where a clause has not been fully met but, on the basis of objective evidence, the conformity of the product is not in
doubt.

 

 

Hmmm. Conformity = ? Significant Doubt = ? Available =?

 

I assume the other Minors really were Minors.

 

Ants are obviously a GMP defect but afaik not regarded as a specific safety hazard.  Potentially a legal "adulterant"?, maybe in some locations.

 

As to Ants = Roaches, more like David and Goliath IMO. Although some ants are non-small and vicious ?.

 

My guess the High Care aspect was the auditorial Red Line. No auditorial wiggle room / back exposed. Possibly also related to the actual Product.

 

Regardless, considering no specific safety hazard, it is "unfortunate" IMO.

 

Did the auditor provide any more objective explanation other than the roach analogy (eg statement of Intent) ? Hard to believe one ant would have also been a Major ?


Kind Regards,

 

Charles.C


#3 Simon

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Posted 19 May 2016 - 06:01 AM

It is very unfortunate but an infestation of any kind in a high risk area would have to be a major irrespective of number.


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#4 GMO

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Posted 20 May 2016 - 10:37 AM

A few things I would say which could argue this up to a major (sorry).

 

If ants can get in, so can roaches.

Ants (although small) don't wash their hands on entry to high care (I jest but it is breaking your barrier).

If normal garden ants, it's almost worse because they normally nest outside and venture inside for food.  So you probably have some kind of structural defect; I would bet within a concrete slab, which is allowing them through.  If you think about it, this is a really alarming thing because if the ants are getting in, the defect will be massive from a micro perspective.

Have I ever seen ants in high care?  No.  Flies, yes, ants no.

 

I can see why you want to argue it down but I am sorry I do agree with the major here.  The numbers are immaterial.



#5 PSC

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Posted 24 May 2016 - 04:27 PM

I appreciate the feedback. We'll take our lumps and move on. 







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