BRCGS 4.14 - Pest control major non conformance
Correction- 1. Area was cleaned and open bags send to trash. 2&3. Flies and ants are removed. Informed pest control company representative of deficiencies.
Preventive action plan-1. Warehouse QA auditor will need to inspect the dry area for spills. 2&3. Food Safety Manager will inspect external traps every quarter to make sure PCO is monitoring them correctly and no activity or other concerns are present. In addition, at any time a new technician arrives to the plant a follow up review to external traps will be complete by Food Safety manager. No left over bags will be brought back to warehouse. Trash compactor will be cleaned weekly by sanitation team.
Root cause-1. QA auditors did not audit for spills on mentioned areas. 2 & 3. Pest Control company make a change of employees and a new pest control technician in July came to Palermo's and didn't notice outside activity. Spills where caused by open bags of flours that where left over by ops.
This year we received a minor in 4.11.2 Excessive debris and spills observed in the cooler and dry storage areas
Auditor marked as major yet they are under two separate clauses. Ended up leaving the minor and adding a major for 1.1.1 management commitment
Looking to challenge, unsure if this would be a smart choice. Thoughts? Thanks everyone!
The original audit stated that there were "numerous spills of dry goods" in various places.
There was insect activity in the flour sifting room.
There was liquid and sludge and live flies around the trash compactor.
You implemented corrective actions to ensure this would not happen again.
The latest audit noted that there were "excessive debris and spills observed in the cooler and dry storage areas"
Regardless of what clause it is, the findings show that the corrective actions you implemented to fix the non-conformances from the previous audit are not working.
So, from an auditors perspective, not only have you not eliminated "numerous spills", but the corrective actions you described are either not working, or are not being monitored effectively.
That's why the auditor escalated the finding to a Major in clause 1.1.1, because apparently there is insufficient "management commitment" to ensure previous audit findings were addressed,
Marshall
Hi Esoto728,
Your non-conformance appears to be justified, although it does not appear to be the right clause of the BRCGS Global Standard for Food Safety Issue 8 that you are quoting as 1.1.1 is related to policy.
Clause 1.1.1 is:
The site shall have a documented policy which states the site’s intention to meet its obligation to
produce safe, legal and authentic products to the specified quality, and its responsibility to its customers. This shall be:
• signed by the person with overall responsibility for the site
• communicated to all staff.
Perhaps it is against Section 1.1 Senior Management Commitment and Continual Improvement?
The relevant clause here is 1.1.12:
The site’s senior management shall ensure that the root causes of any non-conformities against the Standard identified at the previous audit have been effectively addressed to prevent recurrence.
More from BRCGS Global Standard for Food Safety Guidance:
If effective preventive action has not been introduced a non-conformity may be raised against this clause at the next audit, in addition to a non-conformity against the clause that has the recurring issue.
Kind regards,
Tony
Hi Esoto,
I would additionally suggest/re-emphasise that, as stated, your RCAs were perhaps not "true" RCAs, ie there is an obvious one more "WHY".
Can have a look at this Post / thread -
I think the preventive action should be that the employees that work in that space need to clean up before they leave (and not leave it for sanitation because that isnt their job. Everyone should know that they need to clean up after themselves). The supervisors in that department - NOT QA - need to ensure this gets completed at the end of each shift and drive compliance.
Sit them all down and show them the result of their actions and teach them why cleaning up the spills are important. Tell them that the change will start immediately and their supervisor and/or management will walk the area to ensure it is being completed or there will be consequences.
Maintaining a clean work area should always in their job description. I wouldn't just single out that area for spills either - it should be the whole facility. Managers should walk with supervisors at the end of each shift to ensure that everyone is aware of the new changes and your expectation for how their work area should look before they leave for the day AND throughout the day. It'll likely take you a month to fully implement and to get everyone on board with the change and Supervisors comfortable with disciplining on that change.
This should not be left up to a QA audit. Those departments need to be held accountable for their areas. It may take time because its really changing the food safety culture in your facility.