5 replies to this topic

[ReynoldsPackaging1]

Hello,

I'm looking for some clarification on something our SQF auditor suggested during our audit.  He mentioned that our production retains need to be in a secured location i.e. locked area. 

 

We are a pouch manufacturer and our retains are our testing samples that the operators perform their quality checks on.  Most are cut or manipulated in a way that would not make it a usable pouch in the outside world. They are stored in boxes away from production areas.

Our building is also locked requiring either a code or to be let in by an employee and then escorted at all times.

 

This concern was not mentioned in past audits so I'm curious if the auditor was just looking for something or is this a legitimate concern that could turn into a minor in next year's audit.

 

Any insight on this would be helpful.

 

Thank you!

[nwilson]

I would place signage in area and on the boxes/case that these pouches are stored in to state that these are off limits/not for use/QA samples/etc.  Then create a retain policy or SOP (if you don't already have one) to document the process and all the things that will be used to control the retains.  Your site security should also be referenced as this is another layer of control.  Keeping a retain log of all items and label the cases with some of the pertinent information is also a good idea as you have inventory of what is retained.  

 

I've stored retains in production and warehousing areas and have not had any issues SQF wise in over 13 years of audits as all the above was accounted for.  You basically just need to show you have complete control of the retains and that no one is walking off with them and if they do how would you find out.  

[SQFconsultant]

Things do pop up that never popped up before, it happens!

 

With that said, I'd write a quick policy on these and secure store them, their own section with signage, etc.

 

I don't think it's an unreasonable thing to say by an Auditor - it speaks to a potential "control" issue.

[G M]

Something as simple as an "Authorized Personnel Only" sign and some tamper evident tape on the boxes will get you most of what you need.  Then of course store the tape in a secured location, and have trained and authorized individuals pack the samples away.

[Brothbro]

Personally when I worked in an SQF facility the retention samples were not "secured" so to speak in a locked area. But since our product was shelf stable they were kept in an upstairs area that was not on the production floor, and as such no operation staff besides QA had any activity there. In the decades the facility kept retains this way, there was never any issue. This may be because of the unique setup, or simply because in years past this particular issue wasn't on many auditor's radar.

 

I would take some steps to improve your retention sample security if it's been called out on your last SQF audit. Your particular method may have raised some concerns with the auditor, perhaps the retains were stored near other supplies so staff may haul them away by mistake. I'd agree with above that at least having a "keep off" sign would be a step in the right direction as well as some training with floor staff to inform them that these are retention samples and not to be moved/messed with. I understand that some facilities don't have a spare room to stash pallets of retain samples for locked storage, or may not be able to create a locked gated area at the drop of a hat. But it may come to that if some minor improvements aren't seen as satisfactory.

[Tony-C]

Hi ReynoldsPackaging1,

 

As per previous posts, if your site is secure, then I would have thought the clearly identifying the boxes/area as for retained samples would be sufficient.

 

Having said that, the SQF Food Safety Code: Manufacture of Food Packaging Edition 9 Clause 2.4.4.5 States:

‘Raw materials and finished product obtained for sampling and/or inspection shall be properly destroyed to prevent re-entry into the production process or sale to the customer.’

 

So the auditor could have given you a non-conformance, and if it isn’t too much trouble I would therefore have samples locked away and move on. I’m sure that you have bigger fish to fry.

 

Kind regards,

 

Tony