12 replies to this topic

[Plastic Ducky]

Well I must admit I am confused.

 

My SQF auditor is asking for a written preventative controls plan. I guess I thought that my Food Safety Plan that addresses all of the prerequisite programs and the preventative protections they provide is the PC plan. But she states there is a specific format for a PC plan. I have been using the free FDA food safety plan builder which covers every process step and all. I don't know what is left to give. Can somebody help me understand what it is that they want?

 

So then I wrote what i thought was a PC plan. It was structured as follows: 

The plan was broken into categories i thought were the proper structuring for a PC plan. Each category notes the Policy or SOP from my SQF Policy manual that addresses that area of the PC plan.

 

1 Hygiene training for managers, supervisors and employees

2. Current Good Manufacturing Practices

3. CCPs

4. Sanitation Procedures

5.Food Allergen Control Program

6. Environmental Monitoring Program

7. Product Testing

8. Pest Control

9. Food Defense

10. Supply Chain Controls

11. Product Recall/Withdraw

 

But, neither the document created above nor FDA Food Safety Plan Builder nor my other attempts has satisfied the auditor for a PC plan.

 

I thought the depiction above of 1-11 was the "proper format" for a PC plan. Can anyone point out what I am doing wrong? I am lost.

 

PD

[will.merrill]

Preventive* Controls are similar to the Prerequisite Programs of a HACCP... suggest you check your HACCP before you get too deep into this. You don't want them to be significantly different. Nor do you need to waste time inventing something already on your shelf.

 

*I always favor the original correct spelling of this word, otherwise we'd have correctative action... Consistency is key.

[Plastic Ducky]

Speaking of consistency, that is the problem I am having

 

I am going through a format for PC plan provided by "ConnectFood". It is the same information I put into my Food Safety Plan. Just arranged in a different format..I still don't understand why previous attempts to answer this CA have been rejected.

[Scampi]

Ask you auditor to provide you the "reference" she is using..........sounds like she wants it a specific way.........

 

You can't move forward on this without more info from auditor. Can you give us her specific language in the report?

[Charles.C]

Preventive* Controls are similar to the Prerequisite Programs of a HACCP... suggest you check your HACCP before you get too deep into this. You don't want them to be significantly different. Nor do you need to waste time inventing something already on your shelf.

 

*I always favor the original correct spelling of this word, otherwise we'd have correctative action... Consistency is key.

 

OT

 

I have a suspicion (unchecked) that the "at" form was for some unknown reason preferred by the early haccp writers. However I also saw this -

 

John Russell Bartlett, in his 1848 A Dictionary of Americanisms, sniffed that preventative was "A corruption sometimes met with for preventive both in England and America." He was followed by Matthew Harrison, who in his 1861 The Rise, Progress, and Present Structure of the English Language stated that preventative was nothing more than preventive "written and spoken improperly." This was followed by another hundred or years of language guides claiming that one of these words was proper and one was not.

 

In recent decades there has been some softening in the opposition to preventative. Some guides will allow that it is not a mistake, but advise using preventive for greater clarity. We advise you to use the word which speaks to your heart. Or emulate Daniel Defoe, and use both.

https://www.merriam-...or-preventative

 

[MsMars]

Ducky: 

1. I must ask - have you taken the PCQI course? 

2.  Have you considered PCs in your hazard analysis? You can have both PCs and CCPs in a Food Safety Plan.  

 

As others have stated above, it would also be helpful for you to give us the exact verbiage the auditor is using when she is rejecting your plan. 

[Plastic Ducky]

Ok now,

 

I should have told you all I was from Texas to avoid undue excitement over word choice. You know, down in Texas we often add syllables  to words (Remember G W Bush?)

 

like "interpretate" and "misunderestimate" and the like....

 

John Russel Bartlett may be a stickler for grammar, but as matter of perspective, he would be hard pushed to communicate in Texas at present day. Since sanity/reality/and language are little more that group consensus, he may find himself as the one totally speaking improperly.

 

But seriously, 

 

I favor Mr. Mars comments. It would seem the most simple option to satisfy the request.

 

Thank you All!!!!

 

As always you are all the best!!!!

[MsMars]

Ok now,

 

I should have told you all I was from Texas to avoid undue excitement over word choice. You know, down in Texas we often add syllables  to words (Remember G W Bush?)

 

like "interpretate" and "misunderestimate" and the like....

 

John Russel Bartlett may be a stickler for grammar, but as matter of perspective, he would be hard pushed to communicate in Texas at present day. Since sanity/reality/and language are little more that group consensus, he may find himself as the one totally speaking improperly.

 

But seriously, 

 

I favor Mr. Mars comments. It would seem the most simple option to satisfy the request.

 

Thank you All!!!!

 

As always you are all the best!!!!

 

Ducky, 

It is truly "preventative" and not "preventive" according the FDA.  Why the difference - beats me.  For context - I am originally from the Southern region as well, so the word choice didn't cause much excitement with me.

 

From what I know, the FDA want to see your Food Safety Plan similar to what is prescribed in the PCQI course, otherwise a lot of unnecessary questions are asked. Sounds like your auditor is also taking this route. Some respected fellow members on this forum would probably encourage you to shout "Anarchy!" - but in all honesty, my food safety program was already effective and I could prove it, so I changed the formatting in my risk analysis and program to consider PCs, tweaked a few pre-requisite programs, and moved on with my life. 

[will.merrill]

My understanding as a Texan and a former U.S. Government employee ("Hi, my name is Will and I am a recovering government employee") is that one commonly misspelled and mispronounced word permeated the language so badly that the "authorities" of English language caved in and added it to their various dictionaries because dictionaries ceased being sources standards to reference and have become reflections of societal usage. There are multitudes of such words which evolved this way... You won't find "preventative" in an English dictionary published before 1975. Gee, in another 50 years, if things keep evolving the same way, you WILL likely find "correctative" in the dictionary.

 

I don't get even mildly excited when I hear that word in conversation outside my work environment... But, as a Quality Professional, engaged in discussion with other quality professionals, about standards, terminology matters. I feel it is important to be consistent, especially if you can be consistent and correct (vs consistently incorrect). Hence, my reason for mentioning it in the first place. Not trying to offend or criticize anyone, just starting a conversation about standards. (Okay, "hijacking your thread."

[MsMars]

Ducky, 

It is truly "preventative" and not "preventive" according the FDA.  Why the difference - beats me.  For context - I am originally from the Southern region as well, so the word choice didn't cause much excitement with me.

 

 

Scratch what I said, other way around.  Preventive Controls. Preventative actions.  

Must have that Friday mush-brain.

How is one expected to keep this straight? I stand by what I said... I don't count on the FDA to simplify things for anyone.

[Plastic Ducky]

Thank you all for your candor, I love the info about the evolution of language as well!!!

 

Thank you Mrs. Mars! I will go back and add preventive controls to the food safety program and see if that does the trick

 

Thank you!

[PieGuy191]

Here are a couple of documents that I got when I went to PCQI training.  They might be of some help.

[PieGuy191]

It helps to actually attach the files.  

Attached Files

•  FSPCA_Ap2_Worksheets__V1.2FINAL.docx   57.82KB   71 downloads
•  FSPCA-FSPlan-Template-2017-01-07_with-comments.docx   77.54KB   88 downloads