Recently, my SQF auditor gave me a minor (and maybe a major) for improper time documentation on our metal detector tests. When asked for clarification, he claimed it was the FSMA that outlined rules we were violating. I don't really think we're in violation, but we could change it without any problem but if they make it a major, I'll have to challenge... Anyway, thoughts on this and if anyone can shed any light on the specific FSMA regulation, I'd appreciate it. So what we do is we perform a metal detector test once an hour. A metal detector test is described in our procedure as starting at machine 1, testing 3 test wands (the sop of course has detailed instructions), and then moving on to machine 2, machine 3, etc. for all 6 of our machines. This process takes about 10 minutes to complete. We record all 3 metal detector wand results for each machine and document the time we start the procedure. The auditors issue was with not recording 6 times for 6 machines. The only FSMA info I could find was: "The records must be kept as original records, contain values and observations from monitoring, be accurate and legible, be created concurrently with the activity documented, and provide details on the history of work performed. They must include the name and location of the facility, the date and time the activity was documents (SIC), the signature or initials of the person doing the activity, and when appropriate, the identity of the product and the production code." My first argument would be that we are performing 1 metal detector test procedure that includes testing 6 machines (and really 18 wands total).
My second argument is that putting the specific time for each check does NOT increase food safety. Our procedure says if the wand doesn't detect we pull back all implicated product (since the last good check). If we're pulling back to the time of the start of the check as opposed to the specific time for that exact machine (for example, pulling back to 5:00 pm instead of 5:02 pm), we're actually including MORE implicated product and thus providing a slight extra buffer (in the example - 2 minutes). Any thoughts or code references?