5 replies to this topic

[lavalienteQA]

Hi all,

 

I was dinged as such- 

 

"The crisis management plan includes the contingency planning for the loss of potable water; however, the site does not include an explanation of the steps that will be taken to run the plant in the event that the potable water is found to be contaminated or unfit for human consumption."

 

for-

 

11.5.1.2   Contingency plans shall be in place for instances when the potable water supply is deemed to be contaminated or otherwise inappropriate for use.

 

 

 I have steps - my explanation states " ....Assess source of loss and determine options for contingency plan.  

All events will be assessed on a per case basis and crisis management team will assume roles and responsibilities as stated within crisis management plan". 

 

So within my plan I break down:

 

Evacuations

Disposition

Responsibilities 

 

Shouldn't that have sufficed? or should I have broken down the steps only for potable water and forget the other circumstances. 

 

 

[Tony-C]

Hi lavalienteQA,

 

Contingency plans for a loss of water involve seeking an alternative supply.

 

Contingency plans for water contamination involve seeking an alternative supply but first cleaning/disinfecting the affected water distribution system. Then testing the alternative supply is satisfactory through the water distribution system. Also quarantining any product affected by the contaminated water until it can be assessed.

 

Kind regards,

 

Tony

 

[Scampi]

You failed to address your actual water supply............that's why you got dinged

 

It's not just about the product that may have been affected, but you need to demonstrate how you could / would continue to run with an alternative supply and what steps would occur to make that happen

[SQFconsultant]

It was a nice boiler plate response, however you did not directly state what you will do - you provided a plan but left out the actual action.  Everything else on your plan is just snow and auditor's hate snow. That's why you got whacked 

[jfrey123]

"We'll cross that bridge when we get to it" is not a plan.  You've listed that if something happens, you'll make a plan to deal with it at the time it happens.  This defeats the purpose of having a contingency plan, where you've asked yourself ahead of time about the "what if's" and developed a plan to address them.

 

Say for example you do actually lose potable water.  In that moment, what's step one?  For me, it's determining whether we can continue to operate through the end of that shift (basically whether your process requires water to begin with).  Even if your process is dry, loss of potable water means employees can't effectively wash their hands, ergo you'll probably need to shut down production.  And the method for shutting down active production should be defined to ensure you don't contribute to any risks with the food.

 

So next steps: how long are we not going to have potable water?  If the crisis spans multiple days, you're considering a full shutdown during that time or bringing in potable water.  Sounds good, but where are you going to get it?  Last time I prepared a crisis plan, I had reached out to various companies in my area to get quotes for portable handwash stations and tenders of water so we could import and use it for sanitation.  If your actual process uses water, which of these companies can get you potable water in quantities needed to continue production?  Once that could provide the water we needed were added to my crisis management program (company names and phone numbers),and qualified onto my supplier register.

 

It doesn't have to be pages and pages of predetermined plans.  I'm with you in some sense that assessing an individual situation is something managers and owners need to participate in, and decisions need to be made on the fly.  But you should have a basic framework of what a crisis looks like, and some of the basic steps you're prepared to take should one occur.  Pro-tip:  since you'll revise this plan as part of your corrective action, get your SQF team to sit down and run through what a loss of potable water would mean to your plant, and write it up as your mock crisis for the next year.  Since you need to revise it, take full credit for doing the work.

[lavalienteQA]

Thanks all for the clarity!