11 replies to this topic

[free_hat]

Good afternoon,

We recently completed our unannounced SQF audit and received a nonconformance for having an illegible scratch out on a document. During the original paperwork review the correct value was recorded above the scratch out and corrective action of retraining the operator on our record keeping SOP was documented at the bottom of the page. Due to the record being illegible, we still received the nonconformance. 

 

So my question is, how do other SQF Practitioners handle these situations? Do you have the employee re-write the entire document and staple it to the back? I know all the guidance documents say to cross it out with a single line and initial, but how are you supposed to handle an illegible document?

 

Thank you for your help!

[Charles.C]

Good afternoon,

We recently completed our unannounced SQF audit and received a nonconformance for having an illegible scratch out on a document. During the original paperwork review the correct value was recorded above the scratch out and corrective action of retraining the operator on our record keeping SOP was documented at the bottom of the page. Due to the record being illegible, we still received the nonconformance. 

 

So my question is, how do other SQF Practitioners handle these situations? Do you have the employee re-write the entire document and staple it to the back? I know all the guidance documents say to cross it out with a single line and initial, but how are you supposed to handle an illegible document?

 

Thank you for your help!

Hi free hat,

 

Sorry but I don't understand yr OP.

 

How can a scratch out be illegible ? Surely a scratch out is a scratch out ?

 

Do you mean a legible document mysteriously became illegible at the audit ?.

[QAKat]

Hi free hat,

 

Sorry but I don't understand yr OP.

 

How can a scratch out be illegible ? Surely a scratch out is a scratch out ?

 

Do you mean a legible document mysteriously became illegible at the audit ?.

Hi Charles,

 

I think he means a scratch out that is not just a line through. Sometimes employees don't know or forget how to fix mistakes and instead of just 1 line they do so many that it makes the paper look very messy and you cannot read what the original mistake was. I have some employees do those sorts of "corrections" on important documentation. He can correct me if I'm wrong.

 

 

 

Hi Free hat,

 

Not sure how helpful this is because the procedure we have in place is like yours, but in the instances where there are many mistakes or something is very illegible I do have them write everything over and staple it behind the original document like you mentioned. Luckily I have never had an issue in an audit with our original procedure even if it is hard to read what is behind the scratch out. 

[Charles.C]

Hi Charles,

 

I think he means a scratch out that is not just a line through. Sometimes employees don't know or forget how to fix mistakes and instead of just 1 line they do so many that it makes the paper look very messy and you cannot read what the original mistake was. I have some employees do those sorts of "corrections" on important documentation. He can correct me if I'm wrong.

 

 

 

Hi Free hat,

 

Not sure how helpful this is because the procedure we have in place is like yours, but in the instances where there are many mistakes or something is very illegible I do have them write everything over and staple it behind the original document like you mentioned. Luckily I have never had an issue in an audit with our original procedure even if it is hard to read what is behind the scratch out. 

Hi QAkat,

 

Thks, sounds feasible.

 

The quality/legibility of the original scratch-out is not mentioned unfortunately. I deduce it was illegible but ignored (ie compounded error).

 

SQF seemingly used to refer to this specific problem in the Code itself (see link below) but seems long gone, eg

 

https://www.ifsqn.co...ess/#entry80706

 

However the (NEW!) current Records Guidance has some similar text -
 

 

On paper-based records, the use of correction fluid to address corrections is not recommended. A line through the inaccurate recording, with accurate recording and initials of the monitor is recommended.

I note the specifics are not mandatory though. (as is also the "Guidance" itself).

 

Regardless, from an auditorial POV,  I suppose clause 2.2.3.2  sort of  over-rides any nuances. Tough.

 

2.2.3.2   All records shall be legible and confirmed by those undertaking monitoring activities that demonstrate inspections, analyses, and other essential activities that have been complete

 

[Tony-C]

Good afternoon,

We recently completed our unannounced SQF audit and received a nonconformance for having an illegible scratch out on a document. During the original paperwork review the correct value was recorded above the scratch out and corrective action of retraining the operator on our record keeping SOP was documented at the bottom of the page. Due to the record being illegible, we still received the nonconformance. 

 

So my question is, how do other SQF Practitioners handle these situations? Do you have the employee re-write the entire document and staple it to the back? I know all the guidance documents say to cross it out with a single line and initial, but how are you supposed to handle an illegible document?

 

Thank you for your help!

 

Hi free_hat,

 

A simple strikethrough and initial is usually sufficient.

 

It doesn’t make sense that a scribbling out makes your record illegible? Anyway, if a record is illegible then this should be picked up by a supervisor and rewritten straight away on the shift.

 

Also, you have taken corrective action and noted it on the record so this does seem to be a bit OTT from the auditor. Was the non-conformance for a single document? If so I would consider disputing the non-conformance.

 

Kind regards,

 

Tony

[G M]

... During the original paperwork review the correct value was recorded above the scratch out and corrective action of retraining the operator on our record keeping SOP was documented at the bottom of the page. Due to the record being illegible, we still received the nonconformance. 

...

^emphasis added

 

...

Also, you have taken corrective action and noted it on the record so this does seem to be a bit OTT from the auditor. Was the non-conformance for a single document? If so I would consider disputing the non-conformance.

...

 

Unless we're missing some details, it does sound like reasonable corrective actions were taken to a problem that was identified before the auditor saw it.  Disputing the NC might be the best response.

 

Perhaps free_hat can give us some more specific wording from the auditor or the clause cited to clarify.

[Scampi]

You received the non conformance because (correct me if i missed this)-there was no corrective action for the line itself

 

You retrained--but was anything done to verify the information that was scratched out?  Was a line added in the CA spelling out the data the was illegible?

[free_hat]

First, thank you all for the thoughtful responses, we really appreciate it. I will attempt to be more clear/concise in this response. 

 

The Non-Conformance:

 

2.2.3.2. All records shall be legible and confirmed by those undertaking monitoring activities that demonstrate inspections, analyses, and other essential activities that have been completed. 

 

Minor: One record in the mock recall with a write over prior to cross out and correction.

 

Additional Non-conformance Information:

1. We had one document with what I called a "scratch out" but he called a write over. The original value was not legible due to the write-over. 
2. Our immediate correction by the supervisor was to cross out the write over, initial it, and then record the correct value. 
   1. The next day, the employee was retrained on our Record Keeping SOP and this training was documented at the bottom of the record.
   2. This was the only issue on the document. All additional information was legible. No other issues were noted during the audit. 
3. The auditor stated that this was not sufficient because he could not see the original value under the write over. Therefore it was not a "legible" record. 

Side note:

1. We believe that this non-conformance was given because the auditor could not find any additional non-conformances during the audit and he did not feel comfortable giving us a 100. 

 

Why We Are Concerned:

1. The auditor went on to say that if we receive this non-conformance again next year, it will be upgraded to a major finding. So we need to know how to properly correct documents with this issue.

 

My Question:

1.  What is the proper way of handling this issue (scratch-outs or write write overs or black outs) in the future to prevent another non-conformance?

 Thank you all again for your help!

 

Best regards,

 

Free_Hat

 

 

You received the non conformance because (correct me if i missed this)-there was no corrective action for the line itself

 

You retrained--but was anything done to verify the information that was scratched out?  Was a line added in the CA spelling out the data the was illegible?

1. This is an interesting thought. How would you recommend documenting that the information was verified? An initialed supervisor note?

[jfrey123]

When I've been in charge of record review in the past, when I found improper "corrections" (scribbles, write overs, etc.), I made it a habit to go find the employee responsible, have them write a small number next to the bad mark, then copy that number down at the bottom or back of the page and write an explanation of what the mistake had been with the date.  This makes the case that, even though the originally writing can't be written, you at least have the employee's statement on what they wrote incorrectly directly on that form.  It also shows that the person reviewing the forms for accuracy is doing their job.

 

Always a chance an auditor will find an issue with that.  If they go through your batch records and find the same employee screwing up documents constantly, they'll expect to see retraining as a corrective action.  But hell, it's better than what my production manager used to do: have the employee sit at a desk and recopy the entire record cleanly onto a new form.  

[kingstudruler1]

Is the correct?   You found the problem (scratch out) prior to the audit.   You documented the issue and developed corrective and preventative actions (retraining).   

 

The auditor STILL gave you a minor.  

 

If so, I can't think of how you could have avoided the minor.  You did what you were supposed to.  Most auditors will let things go if you find and correct them on your own prior to the audit.  It's an inappropriate minor in my opinion as it encourages the "hiding" of issues for the sake of audit scores.  

Edited by kingstudruler1, 23 May 2023 - 05:09 PM.

[Scotty_SQF]

I feel you did what you were supposed to and should not have received a minor for that.  You definitely showed, you caught the issue, corrected it and documented it.  You were following your plan as it was written.  Not sure how else you could have done it.  Is it worth maybe fighting over it?  At the very least it would ease your minds for a potential major next year as the auditor said....though in my experience, a good auditor isn't going to escalate another finding like that to a major, they would find another part of the code to dock you on it.  Would be kind of ridiculous to get a major for one record like you described above, and I would be not very happy if would happen.

[Charles.C]

Maybe it is also necessary to consider the auditor's options.

 

The latter's  mandate afaik is to evaluate the documentation submitted  in the context of the requirements of the  SQF Standard which in this case appears to be absolutely specific, ie non-interpretable ? (2.2.3.2). (unless one wishes to argue over the interpretation of "shall").

 

So is the (afaik unchallenged) legibility defect of a nature justifying a Minor NC ?

 

A minor non-conformance is evidence of a random or infrequent failure to maintain compliance
with a requirement but does not indicate a breakdown in the food safety management system or
that food safety is compromised. It is evidence of an incomplete or inappropriate implementation
of SQF requirements, which, if not corrected, could lead to system element breakdown.

(The 1st and 2nd sentences appear somewhat self-contradictory ?)

 

 

JFI BRC appears similar but perhaps even less "forgiving" (ie more generic) than SQF in interpretation of "Minor", maybe also reflects BRC's different scoring System, eg -

 

 BRC-Minor.PNG   7.13KB   0 downloads

 

BRC's interpretation Guidance has -

 

Any alterations to records need to be justified and authorised. A suitable procedure must be in place to
manage any mistakes that are made (e.g. neatly crossing through the ‘inaccurate’ information, noting the
reason for the error and giving the initials of the person making the change). Note that the use of correction
fluid is not acceptable as this makes the initial information illegible.

 

I note that SQF detail Close-out requirements. I anticipate any mandatory RCA  would (simply) devolve to training.

 

I also note that SQF do "indicate" the requisite documentation actions to ensure non-occurrence of an (illegibility) defect.

 

I'm unaware of any SQF (semi-official?) document which examines an auditor's scope of "discretion/flexibility" but maybe it exists ?

Edited by Charles.C, 26 May 2023 - 12:33 PM.
edited