16 replies to this topic

[TAW]

Our upcoming un-announced recertificaiton audit window starts on Monday 1/23/23 and I have run into a bit of an issue and need some guidance.

 

We have been dealing with floor repair issues since I started here, but the main crux of the issue is that a relative of the owner is in charge of floor repairs and isn't very pro-active into responding to mine and/or the production manager's pleas to have everything fixed and waited until the last possible minute to start on repairs.  We notified them of the issues repeatedly over the past 5 months escalating it as much as possible through phone calls, e-mails, conversations etc.  We have a polymer coated floor and it did not hold up as well as it should have over the past 6 months.  Only yesterday did this person assemble a crew to tear out the old polymer floor and the floor underneath (concrete) is gravelling in a few major spots.  The production manager and I immediately shutdown the area, it isn't safe enough to produce food there at the moment until the floor is fixed.

 

The SQF code states that 

11.1.2.1 Floors shall be made of a smooth, dense, impact-resistant material (we have the dense part covered but it is definitely not impact resistant or smooth).  Hence the emergency shutdown.

 

What I am confused about is the blackout-dates part of the code.  

2.1.1.8 Senior site management shall designate defined blackout periods that prevent unannounced re-certification audits from occurring out of season or when the site is not operating for legitimate business reasons. The list of blackout dates and their justification shall be submitted to the certification body a minimum of one (1) month before the sixty (60) day re-certification window for the agreed-upon unannounced audit.

 

What about this situation?  Is it wise or even possible to ask the CB for an emergency blackout?  If our auditor shows up next week, we may not be operating and that could be grounds for an automatic failure.

 

 

[Setanta]

I don't think this is going to constitute an emergency in the eyes of your CB. It sounds like your facility has had months to make repairs and did not. The fact your management team waited too long is NOT going to convince the CB it is an emergency.
My advice, make the repairs as good as you can, AS QUICKLY as possible, and hope the auditor doesn't show on Monday.

Edited by Setanta, 20 January 2023 - 04:45 PM.

[TAW]

The management team (myself and the production manager) have literally been repeating this to the owner and the owner's relative who is in charge of this for months.  The both of us knew that an assessment would need to be done to determine the condition of the  concrete floor when it was torn out.  They kept reassuring us it would be okay.

[Setanta]

I think this might be a case of FAFO. F___ (fool)Around and Find Out.

I'm really sorry. HOPEFULLY they can get this done before that knock on your door.

[TAW]

Well that's what we told them, but the produciton manager and I have our documentation and our ducks in a row.  Its put up or shut up time for the relative.  

[Setanta]

Maybe someone else can provide some better options.

[Kara S.]

Well this happened to me during covid/ virtual audit time so different circumstances. 

 

The facility planned a bagger replacement during the PLANNED virtual audit. It was the department that ran product for costco as well so it HAD to be running for the costco addendum. I kid you not - it was like the week before the audit. We called the CB and they agreed to change our audit date - whether we hit with a rescheduling fee, I am not sure. 

 

Just call and ask! Best you can do. 

Edited by Kara S., 20 January 2023 - 07:20 PM.

[jfrey123]

How big of an area are we talking about?  And where is it in relation to your active production?  Can you somehow segregate the area as off-limits, document that you're actively working on a repair (written up internal maintenance forms, contract with a local contractor to perform the repair, etc), and safely continue production during this construction phase?  You get credit for identifying issues prior to the audit, and so long as you've got the process underway to repair and no hazards to your product can be identified, an auditor would be hard pressed to write it up as a finding in violation of code.

 

Company I used to work for had a sewer backup occur during one of their last SQF audits.  They asked me for help in crafting a response, the auditor finding that the company left a roll up door open and allowed plumbers to access the bathrooms via the production floor (through an office) to get into the area.  They had stopped production for the day and felt this would be okay to rectify the problem.  What we found was the backup affected all buildings in the area due to local flooding of a nearby river.  The plant corrective action was that they should have officially activated the crisis management plant, in writing, in conjunction with the full stop of production activities.  With product inside sealed and secure, the plumbers in and out rushing to handle the issue would have been acceptable pending the full sanitation of the production area after their job was done, with inspections to ensure conditions were back to normal before resuming production.

 

Apples to oranges comparison, I know, I share the story just to say you're not going to have a perfect building during your audit (and something might be way out of control).  But if you work your programs and take charge of the problem, you'll likely survive the audit just fine.

[TAW]

Well its not very big.  And it is an active production area.  We could segregate it off but we wouldn't have very much production to do during the audit for the auditor to see if they happen to show.  I suggested segregating it, but it is possible we will have the work completed by late Monday evening. 

[SQFconsultant]

Better to try as you just might win.

We have had similar sets of circumstances with clients over the years and one thing we found is that it was better to pick up the phone and call the cb than not.

And there is no reason to even tell them tje saga about the floor - just say that you had an emergency and that the flooringbis being fixed bevinning such and such date and how you feel that may impact tje audit with not enough for the auditor to look at etc

I found if they had the audit set already they are going to say there is nothing they can do to make amy changes (then you will prettu much know they are comin ) ot they may say OK and request ypur estimated date of completion or they will say that you need to allow for an extended couple of days for physical inspection thus auditor gets more auditing time x2 or x3 of limited production each day.

If that would be the case then you need to follow all of your protocols for doing construction work and document same so the auditor can teview your sageguards, inspect the off-area for backup and then general production.

We had a potato chip client that used a relatibe that ran a flooring coming and they dragged their feet right into the audit window and sure enough that was when the audit was set, but we buttoned everything up, documented everything and when the audit happened the Auditor complimented the staff on doing everything right and we had a successful couple of days.

[SQFconsultant]

Sorry for the typos.

[GreyeagleA]

I would do your best to get it fixed as soon as you can but if you and your production manager have documentation that you have been after management to fix the issue then they can answer to the auditor.  We have a similar situation in one of our facilities, the plant manager there doesn't like to spend money on PM's and we are missing quite a few from last year in his plant and well.. he can explain it to the auditor when it comes up and that facility is having an unannounced audit this year. 

[OrRedFood]

That is a tough situation.  I agree that the reality is that you did have months to fix it, but the timing was not in your control.  On the other hand, you have shut production down during the work, which is the most important thing.  If your unannounced window starts Monday, you should push to get ther work to continue over the weekend. 

 

Another suggestion it to be sure you have a "Change Form" filled out, that details the scope of the project, the food safety protections in place, the parts of the plant and FS systems it affects.  Ideally the Owner/Operations manager should read and sign it, along with production, quality, maintenance and upper management. There should also be a written plan for planning the project, cleaning up the areas affected, and an inspection to release the area back to production.   

 

Here's a generic form, in case you need some ideas.  You are playing catch up at this point, but some documentation that shows you have thought this through and planned for the cleanup portion and a formal release of the area to food production/storage/etc. will go a long way. 

Attached Files

•  Management of Change Form.docx   32.03KB   21 downloads

[Scampi]

our job IS NOT to manage other people, including owners.  Our job is to train, educate and reinforce the program that is written (with management commitment!!!)

 

 

I agree is Setanta  FAFO

 

 

All you are responsible for is what you have done--notified (repeatedly)  halted production and documented everything

 

The lack of proactive corrections on behalf on management is NOT on you (even though it may feel that way)   There is a reason the commitment letter comes from management and not the FSQA

[Mulan1010]

   Please call your SQF Certification Body and let them know that you are not running production until whatever date due to damage to your flooring required you to shut down for it to be fixed.  Unless they ask specific questions, which you should answer truthfully, they do not need to know all the politics and drama of why now.  Things happen; however, ensure you have your documentation on the event and how you ensured the product was safe available in case the auditor asks about it when you are able to have the audit.  Hopefully the floor will look great after they are done. - Best of luck as it is hard to be between family and friends in a business when one or more are not willing to do what is best for the company.

   If it helps you to feel better, we had our unannounced audit this year and we had a few days during that time frame that our plant did not run for a few different reasons.  As soon as we were aware we would not be in production we contacted our CB and let them know.  Last year, just two days before our scheduled audit we had an emergency situation occur that required a shut down for a few days so we had to reschedule the audit. The next scheduled date the auditor had to cancel due to bad weather and could not travel.  We did not receive any grief from the CB for any of these cases.  They take into account that things happen, it is life.  Plus, no facility wants to be shut down if do not have to as we only lose money that way.

[Setanta]

I'm curious about whether or not you had the audit this week and did the work get completed?

[TAW]

Not this week.  And the major part of the repair is done. We are back to production and the other part of the repair which doesn't affect produciton should be done this weekend