14 replies to this topic

[kurmy]

We have quite a large number of documents used in our processing area. Currently we staple them together and cover the staple with a piece of heavy-duty tape to prevent the staple from ever coming out and contaminating the product. This process is done everyday with new production sheets and new staple and new tape.
My question have we reduced the risk to an acceptable level and does this meet the requirement of BRC 4.9.2.2. as the intent of staples becoming a source of contamination is prevented.

[Tony-C]

Hi kurmy,

 

The Standard clearly states in clause 4.9.2.2: Staples, paper clips and drawing pins shall not be used in open product areas.

 

‘SHALL’ VERSUS ‘MAY’

The style of the Standard is generally one of guidance, to allow companies to ensure that all aspects of control have been considered, so that thorough and comprehensive policies and procedures may be developed. In some instances, the Standard requires that criteria must be included within a policy or procedure, and this is generally covered by the term ‘shall’. If any of the points included are not covered adequately, a non-conformity will result.

However, there are also a number of clauses that provide examples or guidelines, generally preceded by the words ‘may include’ or ‘should’. This information is provided as guidance for incorporation in company policies and procedures. It is the responsibility of the company to ensure that the auditor is satisfied that the system in place is appropriate.

 

You may have reduced the risk, or you may have introduced another risk – the tape. Whichever, both will be scrutinised during an audit.

 

So, my first question, is this an open product area? if so the practice would be of concern. If not your practice may be acceptable.

 

Would it not be easier just to hold these in a plastic folder?

 

Kind regards,

 

Tony

[kurmy]

Hi Tony many thanks for your response.
Yes this is an open product area. A meat boning /processing room.
There's quite a lot of sheets per day. Approximately 20 to 30 in the bundle. It is convenient for the 10+ QA and area managers to have them folded up in their pockets.
We are looking at alternatives ie iPads /tablets or terminals to hold this information but as this is an expensive option I thought I would ask the question. Any advice on alternatives would be greatly appreciated.

[Charles.C]

Hi Tony many thanks for your response.
Yes this is an open product area. A meat boning /processing room.
There's quite a lot of sheets per day. Approximately 20 to 30 in the bundle. It is convenient for the 10+ QA and area managers to have them folded up in their pockets.
We are looking at alternatives ie iPads /tablets or terminals to hold this information but as this is an expensive option I thought I would ask the question. Any advice on alternatives would be greatly appreciated.

^^^^^ Just an additional comment - IIRC, pockets are also preferably absent

 

https://www.ifsqn.co...ets/#entry46468

[kurmy]

Agreed no "external" pockets in use. Also no high risk.

[pHruit]

Hi Tony many thanks for your response.
Yes this is an open product area. A meat boning /processing room.
There's quite a lot of sheets per day. Approximately 20 to 30 in the bundle. It is convenient for the 10+ QA and area managers to have them folded up in their pockets.
We are looking at alternatives ie iPads /tablets or terminals to hold this information but as this is an expensive option I thought I would ask the question. Any advice on alternatives would be greatly appreciated.

Clipboards?

Can get metal ones so you're not introducing wood/plastic, keeps the paperwork together without using staples/tape/paperclips etc.
 

[Charles.C]

Agreed no "external" pockets in use. Also no high risk.

Based on my experience, BRC auditors will not unreservably close their eyes in low risk environments.

[kurmy]

Thanks Charles. C, pHruit and Tony-C.
As I see it from responses
1- staples in paper work is a nonconformance regardless, as it is a "shall". Regardless of the tape.
2- Metal clipboards maybe the next best option.

Happy to hear any other thoughts.

[zoelawton]

We use clipboards where we have several pieces of paper. We also have a stainless steel desk where orders (countless paper documents) are om, spread out for ease etc. and the the clipboards hang on the side of the desk.

[SQFconsultant]

We have used a stapler that does not use metal staples. It cuts the paper itself in such a way to bind the sheets together.

Works great!

[trubertq]

No Staples in production area ever.... got dinged for this....

 

Metal clipboards or move as much of your recording to computer workstations as you can

[El Molino]

I can add another : storage clipboard - closed system with the papers stored inside with a clip - closes with a plastic snap - no metal - staples or wood looks like a book

[kurmy]

Many thanks for the ideas. Glad I asked.:)

[GMO]

Just get rid of the staples.  The knots you will tie yourself in to try and get this accepted aren't worth the pain!

[BerBN]

I have been using the stapleless staples for all documentation that is in the open product area for over 2 yrs now. No issues with same.

I have them numbered and recorded as high risk items, (as can only get plastic), checked daily at start-up before production begins. (any damaged are recorded, removed and replaced)