Corrective Actions: When to Document Non-Conformances and Deviations
I've always thought of corrective actions as being for any non-conformance with our operations program. So to me a corrective action wasn't violating a CCP, OPRP or non-compliance with a law, but would include documenting refusing a truck that is unclean. Is that right?
Or should corrective actions only be documented when CCPs are violated? What are your thoughts on this?
How do you currently define a non-conformance that is related to a CCP/OPPR violation?
I do not restrict the term to simply CCP violations. Anything that brings you into compliance with your own programs procedures and policies are Corrective Actions. Simple ones are taken on a routine basis to stay in operation.
I utilize an exception report for those that are unexpected or out of the ordinary. This will document how a situation was resolved and communicate a condition that may develop into a trend or need future Preventive controls to be implemented.
Hi Fatsquirrel,
A corrective action is any action taken when a deviation occurs in order to re-establish control, including those at CCPs. The following are from CODEX General Principles of Food Hygiene (CXC 1-1969):
Corrective action definition - Any action taken when a deviation occurs in order to re-establish control, segregate and determine the disposition of the affected product, if any, and prevent or minimize reoccurrence of the deviation.
Part two Hazard analysis and critical control point (HACCP) system and guidelines for its application - PRINCIPLE 5
Establish the corrective actions to be taken when monitoring indicates a deviation from a critical limit at a CCP has occurred.
Kind regards,
Tony
Any action I take because it's outside of my PRP or SOP is a corrective action. Kicking a dirty trailer should be recorded on your receiving checklist as it was your staff following the SOP, and I often use the daily forms already in use to document such small corrective actions.
But I reserve CAPAs for situations where multiple CA's have repeated, or where they are a direct threat to the safety of the food we produce. If you notice that a series of dirty trucks have shown up and had to be rejected, it's time to look at the bigger picture and start asking why?
Hi Fatsquirrel,
I use a different terminology here to avoid some of the confusion:
Corrections - for minor non-conformances where you fix the non-conformance at the time it is identified and document both the problem and the solution.
Corrections can be recorded on routine documentation and as per the previous post should be monitored and escalated to corrective action when trend analysis/record reviews show repeat minor non-conformities of the same type.
Kind regards,
Tony