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X-Ray Machine Requirement for Initial Audit: Clarification Needed

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Andynz

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Posted 27 September 2024 - 03:44 AM

Hi everyone,

I just went through my initial audit with Costco, and I received an automatic failure because we did not have an X-ray machine installed for foreign material detection. This was a bit of a surprise to me because, according to my understanding of Costco's Food Safety & Quality Audit Expectations, the X-ray machine is required by the anniversary audit, not necessarily during the initial audit.

Here’s the specific guideline I’m referring to:

"Facilities that have not installed a detection device by the time of their Costco anniversary audit will receive an automatic audit failure."

Since this was our first audit, I believed we had until the anniversary audit to install the equipment. Has anyone else experienced something similar? Was I wrong in assuming this timeline?

Any advice on how to handle this or how I should approach the audit team to appeal the decision would be greatly appreciated.


Edited by Andynz, 27 September 2024 - 03:46 AM.

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AtomicDancer

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Posted 27 September 2024 - 04:18 PM

We were advised at our audit last year to write a CAPEX plan that detailed the cost of the X-ray unit, realistic amount of money that can be set aside each year and an expected install date within 5 years. We are also struggling with the fact that for our product, X-ray is not as efficient as Metal Detection.


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jfrey123

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Posted 27 September 2024 - 04:25 PM

I wasn't directly involved in the full audit of one of my facilities selling to Costco, we were given a year to implement the X-ray requirement last August.  I believe the caveat was that we had to have a written plan detailing the owners have reviewed and committed to the capital expenditure including a timeline for testing, validation and implementation.  This facility is now in its unannounced SQF window, and I don't know if they got the system into place as planned yet.  Fingers crossed for them lol.


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SQFconsultant

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Posted 28 September 2024 - 02:07 PM

Auditors involved in doing the Costco audits are messing up big time. Yes, I am sure there are good Auditors out there but when it comes to Costco and this X-ray thing it becomes a real wild animal.

 

Your info is correct, the Auditor was incorrect in how he/she applied the requirement - regardless I'd be hot footing it right now to get that X-Ray in place or to justify not having one with a letter by what Costco considers to be an "Expert."

 

We just had a go around with a extremely unprofessional grandstanding Auditor with a Costco supplier that has been selling to them for over 15 years and that did in fact install an X-Ray but found it tremendously problematic due to the frozen nature/density of the product and they took it out - every time they had a Costco audit nothing was ever said until about a month ago when the Auditor announces in the middle of production that's what I was waiting for - (an operator got nervous during the MD check and passed thru a box of product that had not fully been Nitrogen'd) He yells out that is why you have to have an X-Ray! and proceeds to drop their SQF score into the weeds.

 

Bottom line - we regained the loss and went back up in the 90's, didn't need an expert letter because we went into explaining that Costco had in fact accepted the MD in place of an X-ray as they have been accepting it all these years - it worked!

 

Bad Auditors are bad for business.


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G M

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Posted 30 September 2024 - 01:52 PM

The Costco expectations seem poorly written, and self-contradictory:

 

[a list of requirements that does not include a FM inspection device]
"Operations must have a comprehensive foreign material control plan in place for known and reasonably foreseeable physical hazards. The foreign material control plan at a minimum must include: "
 
[an explicit statement saying one particular kind of FM device is mandatory under most circumstances]
"All manufacturing operations must have a properly installed and calibrated X-ray detection device for finished product, except in the following circumstances:"
 
[and a statement that FM detectors of any kind aren't necessary during the initial audit]
"Facilities that have not installed a detection device by the time of their Costco anniversary audit will receive an automatic audit failure."
 
 
Since their formal list of expectations is a hot mess I would recommend getting clarification from your supplier contact at Costco.  The auditor seems focused on the second part I listed, and is ignoring the other two more lenient statements.   Most of the time Costco seems reasonably amenable to accepting plans for upgrading equipment if you have a formal plan to do so.

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