We Don't Want To Draw Attention To It.
"We Don't Want To Draw Attention To It"
Anyone else get this as an answer from management when trying to be proactive?
I made a simple sign stating the basic rules for storage of our liquid flavoring, some of which have >10 ppm sulfites. The sign stated how to store all containers, and then specific instructions to store the >10 ppm flavors on the bottom shelf.
I was told to not hang any storage instructions, as this will make the auditor ask questions, and we don't want to give him any ammunition.
In managements defense, only the assistant general manager puts flavors in the storage room, and keeps the room tidy daily. But on the line, we have multiple minimum wage employees using flavors and replacing flavors in a small cabinet next to their work table. Although the assistant general manager looks at these cabinets every day too, there will be gaps when he does not have time to organize everything.
I guess what I want to know is, does anybody else have to avoid doing things proactively, as to not raise the auditors awareness of possible issues?
I don't think it's about avoiding doing things proactively, but it's just good business to try and do plant communication in a way that doesn't raise alarms with auditors. In your situation, I would interpret managements response not that you shouldn't be proactive, but instead is there a way for us to fix this problem that doesn't also call attention to it? Your response strikes me as combative, but I don't know what the food safety culture in your plant is like, so it may be justified.
I always stick with the philosophy that you shouldn't go looking for problems you don't intend to fix, because you can't unlearn information. My classic example is always curiosity swabbing for micro or allergens. People love to go "we should just find out what's in that crack in the floor". When I would answer "do you plan on replacing the floor if there is something?" If the answer is no, you shouldn't be swabbing the crack, instead you should be working on a long-term plan to replace the floor, since you've already determined that it's a potential harborage point. The micro results are irrelevant and will only serve to make you more liable if you cannot act on them immediately.
In your case, I would think about what the real risk here. You already stated that it's not usually a problem, and what's the actual food safety risk of stacking these flavors out of order? Unless you've got a stellar facility, I'm sure there are other "proactive" areas you could work on that are worth drawing attention to and getting auditor attention.
Signs can also be a great way to make auditors feel like the facility is under control as well however, maybe come up with some "5s" signage that makes things look locked in, that can actually dissuade auditors from looking closely sometimes. :)
This can be a tricky subject. If the process and training is working, then hanging a sign shouldn't be an issue because we are following what the sign says!
With cabinets I hung signs on the inside of the cabinet. That way there was a reminder but not drawing the attention of outsiders/auditors. To me this situation is similar to a color code sign for utensils. We can't always guarantee that every employee everyday will follow the rules, however we train and hang up signs as reminders.
When there is resistance to something I am proposing to do, I make sure the employees are trained, I perform spot surprise internal inspections, and if those show gaps in our performance, have management help determine next steps. Good luck!
In your case, I would think about what the real risk here. You already stated that it's not usually a problem, and what's the actual food safety risk of stacking these flavors out of order? Unless you've got a stellar facility, I'm sure there are other "proactive" areas you could work on that are worth drawing attention to and getting auditor attention.
Signs can also be a great way to make auditors feel like the facility is under control as well however, maybe come up with some "5s" signage that makes things look locked in, that can actually dissuade auditors from looking closely sometimes. :)
Thank you F3.
I guess I was worried because we claim to be an allergen free facility, but we have flavoring with >10ppm sulfites, and our internal procedures say as long as they are on the bottom shelf, it is okay, because our finished product would be nowhere near allergic levels. Since we have no controls set up for this, and multiple people touching the product at will, my thought was to hang a sign as a reminder. As you state in your last paragraph, if the signs show we have a competence on the situation, and when we get questioned things are done correctly, doesn't that reflect more positively than hidden processes and secrets? I'm the first full-time SQF Practitioner for this small company, so I thought they were trying to shift towards an over the top food safety program for our easy to control, low risk food. But all they see are the excellent scores from years past and don't want to disturb anything they have going on.
I think you are right, and from now on my focus should be on the bigger picture/root cause of things. Maybe I will try and find a suitable replacement for these problem flavors and get all sulfites out of the factory!
This can be a tricky subject. If the process and training is working, then hanging a sign shouldn't be an issue because we are following what the sign says!
With cabinets I hung signs on the inside of the cabinet. That way there was a reminder but not drawing the attention of outsiders/auditors. To me this situation is similar to a color code sign for utensils. We can't always guarantee that every employee everyday will follow the rules, however we train and hang up signs as reminders.
When there is resistance to something I am proposing to do, I make sure the employees are trained, I perform spot surprise internal inspections, and if those show gaps in our performance, have management help determine next steps. Good luck!
Thanks Peaches.
That is exactly what I was thinking, I have color-coded signs for what is and what is not food contact, and signs saying when gloves are necessary as an aide to our training (all foreign staff, very limited English among workers) so why not remind people which exact flavors have sulfites, as that is not in our training (We just added two new sulfite full flavors in the last two weeks! How would they ever know?).
And on a side note, spot surprise internal inspections would be the best thing to ever happen to my company! (Also something I am not allowed to do)
Can you label the shelves instead of hanging a sign? We had an SQF auditor who liked that we had labeled shelves for food grade cleaners on a shelf above the non-food grade cleaners.
If you have an astute auditor, when they look at your chemical storage they will likely ask what procedures, documents, training and self-audits you have if there is a necessity to prevent cross contamination.
Vaguely On-Topic
Hi TWB,
In one factory i was auditing, workers were removing the large, hanging, "NO SPITTING" sign as i walked in. :smile:
Can you label the shelves instead of hanging a sign? We had an SQF auditor who liked that we had labeled shelves for food grade cleaners on a shelf above the non-food grade cleaners.
If you have an astute auditor, when they look at your chemical storage they will likely ask what procedures, documents, training and self-audits you have if there is a necessity to prevent cross contamination.
Thanks CMHeywood,
That is a good idea, but I can only do so in the main storage closet, not out on the line, where honestly it is way more important to control (nothing in the closet is open, so a spill would be no problem).
An astute auditor is our nightmare, our only two SQF audits were done by the same guy, very easygoing person, retired two weeks after last years audit.
Vaguely On-Topic
Hi TWB,
In one factory i was auditing, workers were removing the large, hanging, "NO SPITTING" sign as i walked in. :smile:
So I should remove those signs pre-audit? /s :spoton:
Why worry about removing the signs if this is one way to remind people of the policies and rules?
If you remove the signs and people don't spit on the floor (verified by audit, etc.), then you have created the accepted behavior and don't need the signs.
If you remove the signs and people are still spitting on the floor, then you probably need to put the signs back up.
Do you use posters, banners or signs as reminders for employees to be safe. It is the same with food safety - it is OK to have signs as reminders of your policy.
If an auditor sees spit on the floor, then it doesn't matter whether you have a sign or not. If you have told employees to not spit on the floor during the audit, but don't worry about it as much when there is not an audit, then you don't have a robust food safety program. You have a schizophrenic program that implies that there are two different sets of criteria - a stricter one during audits, and a more lax one when there are no audits.
What are you going to do when there are unannounced audits?
Why worry about removing the signs if this is one way to remind people of the policies and rules?
If you remove the signs and people don't spit on the floor (verified by audit, etc.), then you have created the accepted behavior and don't need the signs.
If you remove the signs and people are still spitting on the floor, then you probably need to put the signs back up.
Do you use posters, banners or signs as reminders for employees to be safe. It is the same with food safety - it is OK to have signs as reminders of your policy.
If an auditor sees spit on the floor, then it doesn't matter whether you have a sign or not. If you have told employees to not spit on the floor during the audit, but don't worry about it as much when there is not an audit, then you don't have a robust food safety program. You have a schizophrenic program that implies that there are two different sets of criteria - a stricter one during audits, and a more lax one when there are no audits.
What are you going to do when there are unannounced audits?
Well specifically, the spit signs was a joke on my end! (luckily!!) But I get the overall point you are making, it is black and white in a situation like that, either it is okay all the time, or it is not. We have unfortunately been waiting 6 weeks now for our companies first ever unannounced audit, so nerves around here are at an all time high. And yes, there are two different sets of criteria, because management here feels invincible thanks to our last two scores (95 and 97). They have now been sweating for weeks, where as I am hoping our auditor is a real hard-ass, and wakes some people up.
Pulling out all the stops and getting ready for an audit, but neglecting the food safety program the rest of the year is putting lipstick on the pig. It only looks pretty for a very short time. The pig will quickly wipe off the lipstick by doing its normal activities - wallowing in the mud, rooting for food in the dirt. The appearance has changed for a while but the long term behavior has not changed.
I previously was the FSP at the plant where I am working but someone else has this role now. The situation about management feeling invincible was somewhat prevalent here as well.
The problem was also compounded by the apparent perception by management that regular internal auditing and review of the outcomes of our food safety program was an extremely low priority. It was commonly postponed by some daily emergency.
It was like trying to pull teeth to get management to commit to review meetings. Probably because it didn't have anything that could be directly linked to making more money or reducing cost. A lot of verbal support ("yes, we all support food safety"), but they usually ran for the hills when they saw me coming. A lot of last minute "sorry, I can't come to the meeting. I something more urgent."
As an Auditor I'd be most concerned that you did not have proper instructions - I would see that as a plus during an audit.
As an Auditor I'd be most concerned that you did not have proper instructions - I would see that as a plus during an audit.
Thank you Glenn! I completely understand not wanting to draw attention to it, but I feel it is worse to have NO policy then to have to amend a policy, or prove we are following it.
It was like trying to pull teeth to get management to commit to review meetings.
Yes, I am still trying to have one of those prior to FSMA's forced Monthly Management Meetings, so maybe our first FSMA meeting won't be as chaotic as I am envisioning.
Vaguely On-Topic
Hi TWB,
In one factory i was auditing, workers were removing the large, hanging, "NO SPITTING" sign as i walked in. :smile:
Haha! that is a good one!
I once went in a factory as auditor. There was a memo on the information board saying "today is the BRC audit, please do not chew gum today"
just guess, how many persons were observed chewing gum. :mellow: