4 replies to this topic

[MDaleDDF]

So we just finished our unannounced audit last Wednesday.  It went really well, they're always going to find something, right? 

So the audit before last, I got hit for not keeping a record of label destruction in production.   So any labels that we end up not using can't just be put in the trash, they have to be torn or scored out with a black marker, etc.   So I did my CA on that last year and had one of the line guys sign off and rip leftover labels in half.

This year we're walking through and by the door to our trash compactor there's a garbage can, with one bag of mix in the garbage.   Auditor sees this, asks why the label isn't destroyed.   I say "well it's going through the trash compactor, so it will be destroyed in there.", (and fyi, our compactor is like one of those car crusher things.   If I got stuck in there and it was turned on, I'd be killed, it's heavy duty.)  

 

Auditor says no dice and writes me a MNC.   No biggie, I can easily do the CAR and come up with a simple destruction that covers extra bags off the line, etc, but here's my issue with this the more I think about it:   I truly feel it was going to be destroyed,   The auditor said "What's to stop someone from taking that label and using it?"    IMHO, everything.   This would require someone to get into our compactor (which is covered in heavy steel and locked from the outside), dig through all the disgusting trash in there, retrieve a label that will surely be disgusting, wet, and crushed, and almost certainly ripped to shreds, then repack whatever fake mix they have in mind, and sell this 5# bag of mix for his almighty profit of what?   A few bucks, tops?

I just don't see it.    So what do I do?   Jump through the hoops, or bite back on the MNC?

Edited by MDaleDDF, 18 January 2022 - 02:06 PM.

[olenazh]

You should definitely bite back! You have a contract with a garbage removal company who's destroying your labels - why would the auditor doubt that? Going by the auditor's logic, anything you're doing could be questioned! File a complaint about this incident, I would even put under question the auditor's competency.

RE: "they're always going to find something" - that's so true! When I had a customer audit and NSF auditor asked me about my recent FSSC audit result - he couldn't believe I got zero non-conformances, and said actually "If it was me - I would definitely find something!" At least, he was fair:)

[Scampi]

Fight back---pretty sure the language also says "disfigured" which it would be once compacted

 

It may be a case of the language in this part of your waste management program being to vague (i.e. you just said they would be compacted, not that they'd be disfigured as a result of said compaction"

 

ASAIK, only pharma labels are required to be actually destroyed, with a certificate of destruction

[Sharon (Dewsbury)]

Hi All,

I suppose it depends on the wording of the procedure and the NC raised. If the procedures say an operative cuts them up, defaces them etc.......... then this did not happen in the case observed. Yes the label is very unlikely to get used BUT procedure was not followed.

[MDaleDDF]

Yeahhhhh, that's what makes it touchy.   Last year they wrote me up for not destroying/defacng labels that weren't used in production, so I wrote a procedure and it's being followed and signed off on, got a work instruction, etc etc.   This wasn't the case.   What happened was it was a bag we didn't end up putting into a case, a leftover.   So it was thrown in the trash, and I got wrote up because of the label on the bag.   

So I already filled our my CAR and I'm going to play nice to appease the rest of the people in my building.   They know how I can be and the entire HACCP team was basically "for god's sake matt just go along to get along" in our meeting yesterday, and I was like "F DAT", but I'll be nice.   I do KINDA see the auditor's point, and I've had this auditor before, and he's the absolute best auditor I've worked with.   Truly a gem and great at slipping in guidance without it being guidance, as of course they're not allowed to do that, but he says things so that I can read between the lines, and he's helped me out a bunch.

So in the end, yall are probably right, but I'm going to jump through the hoops like a circus animal......

 

Thanks for the input all, much appreciated.   You guys rock.