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Document Control - QC testing form

haccp document control recycled paper testing form qc gmp

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#1 catherinepc

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Posted 01 March 2019 - 03:35 AM

Hi all,

 

I would like to check regarding QC testing form. 

Our current practice is we use recycled paper to print out our QC testing form / record for our QC finished product analysis. 

 

 

Our customer came to audit our plants and raise this issue. They said that it should be printed on new A4 paper instead of using recycled paper. We did mentioned to them that this is only use for our internal documents. 

 

Is this not allowed in GMP or HACCP ? 

 

Thank you. 



#2 Zeeshan

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Posted 01 March 2019 - 08:06 AM

I've not seen a single management standard that prevent or regulate use of re-cycled paper for printing new records or documents. Only some precautions must be considered as good documentation practices.

 

1) Re-Cycled paper should be strong and intact that support legibility and proper record keeping. It must be strong to complete life cycle of new record (depends on retention period of new record).

 

2) The old records must be crossed so that there would be no confusion of mixing up of new and old records.

 

3) Care must be taken to check whether old records are not confidential with respect to Customer, Organization of Employee.



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#3 Scampi

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Posted 01 March 2019 - 01:45 PM

I've experienced the same, also from CFIA inspectors. I argued the point (and would always argue the point) that it's none of their business what paper is used. Now, I always put a big line through the text on the "bad" side of the paper.

 

Ask them to show you the regulation/requirement, otherwise keep doing what your doing


Because we always have is never an appropriate response!


#4 SQFconsultant

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Posted 01 March 2019 - 01:50 PM

Did they say why?


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#5 CMHeywood

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Posted 05 March 2019 - 07:55 PM

I thought A4 indicated a sheet size and not a particular type of paper.



#6 catherinepc

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Posted 08 March 2019 - 02:49 AM

Did they say why?

They didn't say why. We always have this kind of fussy auditor. 

:giggle:



#7 catherinepc

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Posted 08 March 2019 - 02:50 AM

I thought A4 indicated a sheet size and not a particular type of paper.

Sorry, they mean new paper instead of using a recycled paper. 

 

But we do mention to them that we do not use control document as recycled paper. 



#8 catherinepc

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Posted 08 March 2019 - 02:52 AM

I've experienced the same, also from CFIA inspectors. I argued the point (and would always argue the point) that it's none of their business what paper is used. Now, I always put a big line through the text on the "bad" side of the paper.

 

Ask them to show you the regulation/requirement, otherwise keep doing what your doing

Yes, exactly. I did mention to my staff that next time please ask them to show us the regulation / requirement. 



#9 catherinepc

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Posted 08 March 2019 - 02:55 AM

I've not seen a single management standard that prevent or regulate use of re-cycled paper for printing new records or documents. Only some precautions must be considered as good documentation practices.

 

1) Re-Cycled paper should be strong and intact that support legibility and proper record keeping. It must be strong to complete life cycle of new record (depends on retention period of new record).

 

2) The old records must be crossed so that there would be no confusion of mixing up of new and old records.

 

3) Care must be taken to check whether old records are not confidential with respect to Customer, Organization of Employee.

Yes. I have also check out local food safety / GMP standard. Our documentation has been audited by the authorities for so many years and they never had issues regarding this.

 

Anyhow,  Thank you for your suggestion. We will always practice proper document control. 







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