11 replies to this topic

[Callmecern]

We are a manufacturer of plastic film for direct contact with food. 

 

We are getting our 3rd party cert starting with AIB but then moving to BRCGS later. My office manager is adamant that every single piece of paper, training poster, general work instruction gets assigned a document number for document control, and every single meeting/ morning huddle is written down and explained what was talked about and then signed by everyone.

 

This seems way overkill. For example we were going to put a small flyer above the work station basically saying to remember to keep your area clean and sweep the floor of scraps ect.. My office manager says this flyer needs to be assigned a document approved and added to the master list for control. 

 

 

This seems extremely excessive.  

Edited by Callmecern, 16 October 2024 - 04:38 PM.

[amathon]

Your office manager's approach, while thorough, may indeed seem excessive for simple reminders like a flyer encouraging cleanliness. Document control is crucial in certifications like AIB and BRCGS, especially for controlled documents that affect processes, quality, and food safety. However, not every single piece of communication, such as informal posters or flyers, typically needs to go through the full document control process unless it directly impacts regulatory compliance or product safety.

 

For something like a flyer reminding employees to keep workstations clean, a simpler approach might suffice, such as incorporating it into broader training materials or general housekeeping procedures that are already documented and controlled.

 

That said, BRCGS emphasizes the importance of a strong document control system, but it is more focused on critical documents like SOPs, training records, and procedures that directly relate to food safety, quality, and compliance. You might consider discussing a risk-based approach, where only key documents are subject to formal control, while more informal communications remain flexible.

[SQFconsultant]

I don't think your office manager is excessive, I think he/she is spot on.

[Dorothy87]

hi :) 

 

BRC clause 3.2 Document Control 

 

Documents must be effectively controlled to ensure that staff are working with the most up-to-date information and to minimise the potential for mistakes. Documents include policies, procedures, work instructions, records, forms, specifications, data lists and any information that is written down and defined.

 

No one will stop you from controlling such docs but this will be a killer unless you have a special QAS co-ordinator. 

 

Just make sure your posters/signs follow procedures/polices. 

 

Edited by Dorothy87, 16 October 2024 - 07:38 PM.

[G M]

...

 

No one will stop you from controlling such docs but this will be a killer unless you have a special QAS co-ordinator. 

...

 

Which brings up the idea that the food safety and quality department isn't the only one making and posting signage. 

 

Maintenance wants some instructions for how to operate/calibrate some machine -- not on our controlled documents list. 

Health & safety wants a sign telling people to wear earplugs -- not on our controlled document list.

Continuous improvement has a card near some workstation telling people how to convert numbers of team members into man hours -- not on our documents list.

 

Should some of these have official controls, sure, but not everything is part of the food safety and quality systems.

[ChristinaK]

It might seem like overkill, but it will hold up to BRCGS. If the office manager is going to be the one responsible for controlling these documents and maintaining a log and all that, I say let them be.

 

What I've done for things like posters or quick reference guides is reference the document the information comes from rather than assigning it a new document number. For example, a large poster of "GMP Rules". In the bottom left corner is "Ref. [document # for GMP plan]" and the bottom right corner has the date the poster was made/hung, the department, and who made it. Then we just included that in our controlled documents procedure and...ta-da!

[beautiophile]

There's a grey area between "controlled" work instruction and poka-yoke.

Edited by beautiophile, 17 October 2024 - 02:12 AM.

[Tony-C]

Hi Callmecern,

 

You need to decide which documents are part of the product safety and quality management system and control them. Hygiene and housekeeping instructions are more than likely part of the system.

 

BRCGS Global Standard for Packaging Materials Issue 6 Section 3.2 Document control requires a list of all controlled documents indicating the latest revision number.

 

Also note that BRCGS Guidance states that ‘It should also be clear when a document is not controlled’.

So, if you decide that some documents aren’t part of the product safety and quality management system then it is best to mark those documents as Uncontrolled. In the old ISO 9001 days we used to have a rubber stamp and used red ink to stamp such documents as Uncontrolled.

 

Kind regards,

 

Tony

[Callmecern]

It might seem like overkill, but it will hold up to BRCGS. If the office manager is going to be the one responsible for controlling these documents and maintaining a log and all that, I say let them be.

 

What I've done for things like posters or quick reference guides is reference the document the information comes from rather than assigning it a new document number. For example, a large poster of "GMP Rules". In the bottom left corner is "Ref. [document # for GMP plan]" and the bottom right corner has the date the poster was made/hung, the department, and who made it. Then we just included that in our controlled documents procedure and...ta-da!

 

I guess a lot of it is also getting to a point that we are hitting the minimum requirements already. What my office manager is wanting to do would restrict/ make any and all communication in the plant impossible. For example we have a hard to run product coming up this afternoon and the crew gets together for 3 min before hand to remind everyone on what needs to happen she would have them filling out a document saying there was a meeting or a training and then have to write down what was discussed. Then any sort of poka yoke would have to be sent for approval and assigned document number. We have a machine that we wanted to put a warning stick on saying be sure to turn off air before shift ends..... She wants this document controlled. The amount of documents documents and training sheets we would have would be in the 10s of thousands. 

 

Am i crazy to think that this is a bit much and no auditor is going to have issues with us having a few flyers or visual aids around the plant. And even if they did have an issue i cant imagine that this would give us much of an infraction for sure not worth going crazy with paperwork. 

 

If it helps we are a blown film plastics manufacturer (we make bags)  

[G M]

To put it in perspective it might be worth estimating an amount of time it takes to maintain a document, the number of documents involved, and the number of assistants you will need just to manage all those document updates.

 

Let them be the ones who say no to it when you show how many man-hours it will take to maintain that level of control.

[Scampi]

I disagree with most here:

 

Yes, it sounds like over kill

 

Posters reminding people to follow the rules already in place and trained upon is just that, a reminder

 

Daily huddles do not require minutes UNLESS you're training on a new/modified procedure

 

Here's a really great article to support my view

https://digitalediti...zI5Ni4xOS4wLjA.

[AtomicDancer]

I think it's overkill.

If it's related to food safety, food quality, people safety, audit material, then yes, it should be controlled.

A sign saying the fridge will be cleaned on friday night or DANGER stickers, etc, do not need to be controlled.

 

Remind the person in charge of this policy that if they put it into the Policy, it *must* be followed at all times, meaning a CAPA must be completed for each and every violation of the policy. If they are hellbent on it, let them, do a mock audit and see if you can find an out of date document (of the not related to food safety, food quality, people safety, or audit material) and see what happens.