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What happens when a NC cannot be corrected?

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BAkermanjr

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Posted 23 October 2024 - 03:29 PM

We are one week away from our initial SQF Audit, everything is running smoothly, even the employees have fallen in line.  In our GAP audit, I got a minor for having exposed aggregate concrete flooring in our proof box area.  We are a wholesale bakery, and the proof box runs between 94-96% humidity, and 96* for 10+ hours a day.  Putting in any type of flooring, or removing what we currently have, would be a week long, if not longer, process that we simply do not have the down time for.  The moisture in the existing floor would have to be completely removed, which would take days.

 

So, when we get audited next week, this will be a known issue, and I know the auditor will give me another minor on it, with expectations that the CA report should determine how we will correct it.  But it cannot be corrected.

 

Risk Analysis on the flooring?  We do have stainless rails that run the whole length of the box, just the exposed parts are where the concrete is.


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SQFconsultant

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Posted 23 October 2024 - 03:45 PM

Schedule the repair (in writing), get an estimate right now and commit to the repair (in writing) Pay for the repair in advance so you have a receipt marked PAID by the contractor.  Write out a procedure that you follow with a log (in writing) showing that you are monitoring the situation. Have all docs ready for Auditor review.

 

You night not get gigged - but that would be a gift.  I'd get the above done today.


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Posted 23 October 2024 - 03:47 PM

Although it should not matter, you did not mention the CB. I have noticed some CBs do things differently.

 

From how I understand it, you DO have a way to fix it, but your facility has chosen not to take the downtime needed. I don't know how long ago your GAP was, but unless it was recent, the CB may wonder why you didn't choose to repair it.

 

The way my head is working here, I don't feel like you don't get 2 minors in a row for the same thing, they escalate into Majors. Then you will have to dedicate the downtime and capitol to fix it. And you will be on a timeline, unless you get an extension. 

 

Follow Glenn's steps and you may mitigate this....


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BAkermanjr

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Posted 23 October 2024 - 03:47 PM

Glenn, we simply do not have the time to fix it, running 5-6 days a week, 12-14 hours a day, the amount of money lost in having to shut down the whole facility for the repair would greatly outweigh the repair.  What happens next year when the auditor comes in, and it's still the same?  Is it another NC?


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SQFconsultant

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Posted 23 October 2024 - 03:48 PM

By the way, how do you.... "know that the auditor will give me another minor on it"????


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AltonBrownFanClub

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Posted 23 October 2024 - 03:50 PM

I think an epoxy floor coating is your solution.

Concrete creates a lot of dust with the friction of employee feet, carts, etc.

It really should be sealed and easier to clean.

 

https://www.armorgar...rial-epoxy.html

 

This kit dries in 1-2 hours and can be walked on in 12 hours.

You might have to come in at night/after shift to apply it. At worst, you lose 1 day of production.

It's an easy call for me. Especially when your SQF certification hangs in the balance.


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BAkermanjr

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Posted 23 October 2024 - 03:54 PM

So, ASI is the CB on my audit, and with the moisture in the box, there is no chance of any dust being created, the concern is the moisture from the floor rolling up onto the product on the racks of product.

 

As for the epoxy type flooring, we have had 3 different companies come in to quote/look at the issue, and all have said it cannot be done, without completely drying or removing the damp concrete.  The floor simply will not stick, and will pop up.


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SQFconsultant

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Posted 23 October 2024 - 03:58 PM

Glenn, we simply do not have the time to fix it, running 5-6 days a week, 12-14 hours a day, the amount of money lost in having to shut down the whole facility for the repair would greatly outweigh the repair.  What happens next year when the auditor comes in, and it's still the same?  Is it another NC?

 

-------------------------------

 

Reread what I said - get the docs, pay for the repair now and show that to the Auditor.

 

You will make the time regardless because a minor gives you 30 day to send you corrective action in, (like a before and after photo for instance), you might get an extension - but I promise you if the same situation comes up again on the next audit, I doubt it will be a minor - major is more like it.

 

Your docs from a contractor need to show a timely repair is going to be made   -- you can not allow something that is on one audit to be there again on the next audit, unless your company enjoys getting nailed to the wall by Auditors.

 

The ideas that I gave you have worked for several of our clients, they got free passes in fact.

 

Flooring issues like this seem to escalate very easily and very quickly - thus, that's a priority.


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Setanta

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Posted 23 October 2024 - 04:05 PM

If your company wants to have the SQF Certification, you are going to have to fix the things that they find as recommendations. They are auditors, ideally experienced in your field, and they know what can and cannot be done.

 

None of us get to pick and choose what we want to do IF WE want the cert. If my CB comes in and says I need a new dock door or new seals on my door, I am going to have to find a way to do that. 


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AltonBrownFanClub

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Posted 23 October 2024 - 04:11 PM

 

As for the epoxy type flooring, we have had 3 different companies come in to quote/look at the issue, and all have said it cannot be done, without completely drying or removing the damp concrete.  The floor simply will not stick, and will pop up.

The flooring companies, professionals on this forum, and myself have all told you the same thing you just typed. (in bold)

You have to dry out the concrete, apply the coating, and fix the issue.

 

 

 

running 5-6 days a week, 12-14 hours a day

Looks like you have 2 full days a week where someone could make the repair.

You could also repair in sections after production each day. (10-12 hours)

 

The product I linked is dry in 12 hours. So suck it up, stay late, and correct the NC. Bottom line.


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Scampi

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Posted 23 October 2024 - 04:17 PM

Um in this day and age, there is zero excuse for a raw floor circa 1905

 

the company is either on board with food safety or they are not, you unfortunately won't get a lot of sympathy here on the lack of buy in from company owners/senior leaders

 

and good luck getting recertified once you've failed an audit for repeated non conformances for the same issue

 

As a note: tell them car plants SCHEDULE SHUT DOWNS FOR MAINTENANCE so why should it be different for you?


Edited by Scampi, 23 October 2024 - 04:17 PM.

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jfrey123

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Posted 23 October 2024 - 04:46 PM

Glenn, we simply do not have the time to fix it, running 5-6 days a week, 12-14 hours a day, the amount of money lost in having to shut down the whole facility for the repair would greatly outweigh the repair.  What happens next year when the auditor comes in, and it's still the same?  Is it another NC?

 

A repeat NC from the year before gets escalated to a major finding automatically in SQF.  As others have mentioned, writing up that you have full knowledge of the NC and an action plan in place to correct it can get you out of a minor finding during this audit (I've done this a lot: auditor spots something broken, and I've already got a work order and action plan to address it).  However, if they show up again next year and nothing has improved, then it'll be a minor at minimum or possibly a major for not following your own CAPA plans.

 

It's not about having the perfect facility; it's about discovering and mitigating the risks that are present.

 

So thinking about the area:  is it part of your EMP, and have you had any suspect results from the floor itself?  Warm and moist for proofing bread is the ideal spot for more micro to bloom and flourish, so most auditors are going to look hard at this issue.  A robust EMP testing of that room with good results will give you some defense on the delayed repairs.  Conversely, if your EMP indicates that room is a hazard, then your company's execs are going to have some explaining to do.

 

I'd do everything you can to mitigate it for this audit, all while being prepared to take a hit.  Once it gets listed as a finding, then your execs will have the pressure to find a solution.  Perhaps contacting the shipping companies who offer heated transportation could yield a trailer that holds 96F on electric power, and having it parked in a dock door for a month to repair the room is a possible solution.


Edited by jfrey123, 23 October 2024 - 04:46 PM.

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BAkermanjr

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Posted 23 October 2024 - 04:52 PM

In full transparency, I am the exec making this call.  I am also the SQF Practitioner, sometimes oven man, or production line supervisor.  We are a mid level sized, family owned bakery.

 

As for the biological, I have done them in the box, with no hits over the last 2 years since we started, we are diligent in cleaning the box, as we are aware of the risks.

 

Just got off the phone with the quick dry epoxy flooring company, can't handle the constant humidity.  I do have another contact I will reach out to, and at least have a quote on hand for if and when I need it during the audit.  It needs to get done, no denying it, just hard to pull the trigger.


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Setanta

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Posted 23 October 2024 - 04:59 PM

In full transparency, I am the exec making this call.  I am also the SQF Practitioner, sometimes oven man, or production line supervisor.  We are a mid level sized, family owned bakery.

 

.  It needs to get done, no denying it, just hard to pull the trigger.

 

It will be harder to pull the trigger on any expansion on sales if, because you lack a GFSI/SQF audit cert, you aren't allowed to sell to Costco, Sam's Club or Wal-Mart. 


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SQFconsultant

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Posted 23 October 2024 - 05:21 PM

I will reach out to, and at least have a quote on hand for if and when I need it during the audit.  It needs to get done, no denying it, just hard to pull the trigger.

 

I didn't say get a quote only - get a signed contract in place, and paid receipt and have the date like the next week after the audit explaining you were not able to get it set up prior to the audit.

 

I'd stop stalling and get it done... cause other things will pop up as gaps don't always catch everything.

 

Finger on the trigger eh?


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All the Best,

 

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Glenn Oster.

 

 

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Setanta

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Posted 23 October 2024 - 05:39 PM

You wrote: " So, when we get audited next week, this will be a known issue, and I know the auditor will give me another minor on it, with expectations that the CA report should determine how we will correct it."

 

Just to be clear, SQF or any certifying body will NOT tell you how to correct it.

That falls under consulting. You will have to figure out the best way to fix this.


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G M

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Posted 23 October 2024 - 06:06 PM

For the underlying question "What happens when a NC cannot be corrected?" -- it gets escalated to a higher category, and if that isn't corrected, you lose the certification.

 

I do not believe the floor cannot be sealed (unless it is crumbling, in which case it should be replaced entirely).  Scour it, clean it, dry it out -- there are treatments that will stick for years.  Will it be permanent and flawless, probably not, but it will work and be cleaner and safer than bare concrete.  Many large facilities dedicate a few days up to a few weeks of downtime each year to this kind of maintenance because it has to be done, and can't happen during production.


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AltonBrownFanClub

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Posted 23 October 2024 - 06:17 PM

In full transparency, I am the exec making this call. 

A screenshot of this comment belongs in the recent McDonalds thread haha

 

Take a look at the Quaker plant in Danville, Illinois.

Or the Boars Head plant in Jarratt, Virginia.

They didn't have time for repairs either, and look what happened.

 

So sad that something bad happens before some people even CONSIDER doing the right thing.

You've had inspectors and food safety professionals grilling you and still "it's hard to pull the trigger"

 

It's not hard at all. Fix the issue, do your job, protect consumers. SMH  :doh:


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BAkermanjr

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Posted 23 October 2024 - 06:21 PM

So, to put my mind at rest, I have reached out, and secured a quote from a flooring company that we have used in the past, they assured me it will hold, and can put it in under 48 hours, considering it is only about 600 sq ft.

 

Thank you to everyone for the advice, albeit a bit hard to swallow, nerves are killing me for my first audit, even though I know we will be fine.  Everything else in perfect order, paperwork, building, etc, and the floor of one area woke me up at 1:30 this morning, and I just couldn't get it out of my head.


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TimG

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Posted 23 October 2024 - 07:45 PM

So, to put my mind at rest, I have reached out, and secured a quote from a flooring company that we have used in the past, they assured me it will hold, and can put it in under 48 hours, considering it is only about 600 sq ft.

 

Thank you to everyone for the advice, albeit a bit hard to swallow, nerves are killing me for my first audit, even though I know we will be fine.  Everything else in perfect order, paperwork, building, etc, and the floor of one area woke me up at 1:30 this morning, and I just couldn't get it out of my head.

 

Take a breath, we've all been there. Make sure you know that even though you have a lot in perfect order, there will still (probably) be some minors that the auditor will find. One thing you don't want to do is ever take a stance of "we just won't be able to fix this" with the auditor, that just will NOT fly (don't even give that impression, IMO).

My unannounced is coming up in a few weeks and I'm getting the 'wake up at 2am and remember I need to do X..' jitters too.


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jfrey123

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Posted 23 October 2024 - 07:55 PM

@BAkerman, I think the vast majority of us have been in your shoes.  It's tough, and you will get pushback, but you're standing up for your customers and making the hard call.  First audit jitters don't really go away, but they do get easier to manage.  Not to freak you out more, but be prepared for what I call "The Luck of the Auditor" on their visit:  Something that you cannot fathom happening is going to happen.  Someone is going to forget a startup form, someone is going to come up to you with a problem directly in front of the auditor, someone interviewed by the auditor is going to forgot to list all of the steps they do for chemical safety, etc.  Something will pop up, so just be ready to roll with it.  My favorite story I read on this forum was someone had an employee bring a tin cat up to them with the auditor present and ask what to do with the rodent that was trapped inside.

 

You've lined up the ducks in a neat little row, now you just gotta walk them through the Door of Certification.


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kconf

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Posted 23 October 2024 - 07:57 PM

Tim is right. Stay positive and appear solution oriented even when it seems impossible. 


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ChristinaK

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Posted 23 October 2024 - 09:07 PM

I've had the floor repair argument with a former boss about shutting down production to repair epoxy floors. At least you got to have the argument with yourself? Ha.

 

I don't think you mentioned what material the walls are, but I recommend having the epoxy floor go up the wall a bit (like an epoxy baseboard trim? not sure if it has a name) to fully cover the seam between the wall and floor, especially for a wet/moist/humid room.

One important thing you'll want to do is figuring out when you will need to schedule the floor to be repaired/patched or replaced. Once water or too much moisture starts seeping underneath a couple of cracks in the epoxy, you're going to see much worse damage start happening even faster. Not to mention the microbio hazard of still, trapped water.

 

Good luck on your SQF cert! Try to think of anything that "goes wrong" as an opportunity to improve; framing it like that can help make the audit process less stressful.


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