2.2.2 Records Security to Prevent Damage or Deterioration

2.2.2.3 Records shall be readily accessible, retrievable, securely stored to prevent damage and deterioration and shall be retained in accordance with periods specified by customer or regulations.

In our GAP Audit the auditor said that are records are not secure from fire or flood.  We do back up our computer systems every night and have a storage room on site that we store records. 

I had our QA Department start electronically scanning and saving some of the production paperwork but it is to time consuming.  I am unsure also on which records this applies to.  We have Bill of Ladings in the office that are not scanned and get filed and then stored in the storage room after a year.  I am assuming these are records and it applies to them also.  We are a small company and don't have enough staff to electronically scan all documents to back them up.  Senior management is unwilling to pay for a fire safe storage area or change to all electronic records.

I was wondering how other people are doing this and which records this applies to.

hello jportz,

Are your area prone to flooding? You can include that in your management of incidents that during natural calamities such as earthquake, fire, flood and man-made disaster such as arson and sabotage that you can readily protect your records. Make a procedure how to do it if incidents happen. In your food defecse program you can also mention it that records will/can be protected by the site from damage.

regards,

redfox

Hi jportz,

AFAI can see, this clause is seldom a source of nonconformances in SQF audits so i anticipate that there was some particular reason why the auditor was not satisfied with the security regarding fire/flood. If not stated it  should have been.

Please clarify.

We are not prone to flooding.  I am curious as to how others deal with securely storing their records.  We have everything on the computes backed up to a disk daily and that disk is taken home by the controller.  We have an on-site storage room where documents are stored for past years.  All current years documents and records are stored in file cabinets in the plant.  We started electronically scanning some production paperwork and backing it up daily on the computer system but, there is not enough time or people to scan all records and documents.

Hmmm, I am not understanding why an Auditor is stating this specific information to you as FIRE and FLOOD is not specified in 2.2.2.3.  You are required to store securely and of course to prevent damage.  I think this was an overstep.  If this was the case, the Auditor could have told you a bunch of other things too like to put a dehumidifier in the room to prevent mold or mildew, etc. That is also not in the code.  The code broken down simply means how do you protect your records, how do you secure them, that's it.

Hi jportz,

My experience is with BRC. Records are stored in various locations depending on their specific nature and whomsoever is producing them. Some PC-based, some hard copy. Most backed up/duplicated but probably not 100%.

No flammable items stored in vicinities of record storage rooms.

Factory has no history of fire or flood. Never received any auditor comments regarding records security.

I noted that the SQF Guidance makes no specific requirements regarding this clause. Rather unusual.

Afai could see, your OP is the first posted query regarding this SQF clause on the Forum.

I would have wanted/asked to know the reason if the auditor had expressed a lack of confidence.

Wondering if this may be the same Auditor that visited an SQF client of ours. They store their paper records on the 10th floor of the building and they were told that their policy didn't say anything about protecting from a flood.... considering that Jesus promised no more epic floods.  This was challenged and removed however.

I would have politely challenged the auditor on this. The code doesn't specifically state fire/flood. Your area is not prone to floods...It's not a reasonable foreseeable hazard. You shouldn't have lost points for this. Our facility is SQF 2 and has been for 10 years.  We don't scan any of our production records and are on the ground floor. Our last audit was 99%.

We store our records in file cabinets, or in boxes on pallets, the pallet serves as flood protection much as it protects palatalized ingredients from flooding. we have a fire suppression system to protect from fire damage. we make electronic copies (with weekly offsite backup) of our CCP records, and computers are password protected.

As was stated above fire and flood are not mentioned in the code; fire and flood each appear one time in the SQF 7.2 module 2  implementation guidance for 2.1.6,   Auditors should be inspecting to the code.

You specifically stated a GAP audit, not a scored audit correct? I would assume that you could go back to the gap auditor for more info on this...