15 replies to this topic

[trevordrew66]

Good Day to you all, hope someone can help me,

I am considering etching my production glass onto small whiteboards to enable the audit time to be recorded on the white board and wiped off when the next audit is carried. This will provide a good visual record of the checks being carried out, the problem i have is i will not have any proof of the glass checks being carried out historically, obviously if there is a failure there will be an isolation record but nothing more.

Am i causing myself a problem


Trevor

[Simon]

Hi Trevor,

If you look at it from an external auditor's point of view they will want to see records so that they can verify that procedures are being complied with. I like visual things like this but I'm not sure you'll get away with it. If the operators are simply writing the time they last checked down I suppose it's just as easy to write a line and initial a document - maybe not as visual unless you use A3 and coloured marker pens.

If you are BRC/IOP, in 4.3 Record Keeping "Control of non-production glass and brittle plastics" is included amongst the minimum records required list. And I think you're glass register records play an important part in demonstrating this control.

In answer to your question IMO I think you may well be causing yourself a problem.

Hope this helps.

Cheers,
Simon

[Neil Radford]

Trevor,
I support Simons opinion. The ability to provide historical evidence of glass checks would support a due diligence defence. I would support Simons view that you could be causing yourself a problem for the future in event of glass contamination claim.

Regards
Neil

[rheath]

Trevor,

We use a dry wipe system for our weekly testing of emergency shower wash and other similar checks.

To cover the document traceability we ensure that the wipe board is checked in our monthly hazard patrol - effectively ensuring that all visual systems are in place and working effectively.

This way we can ensure that the accountability of the actual checking lies with the process owner & the hazard patrol / auditors are simply checking that systems are working without the need to check every window & bolt etc

Regards

Richard

Edited by rheath, 26 October 2004 - 11:03 AM.

[Simon]

That's interesting Richard. Don't get me wrong I've nothing against it in principal, it's a common sense and practical approach and it may well be fine for something that's not critical, especially if it works.

I think you may have misinterpreted me a bit. I wasn't saying by using pen and paper to create records we remove accountability for checking, of course this responsibility should remain with each work area, it's just that the records are permanent.

I wonder taking it to a ridiculous extreme would this approach stand up when supporting a due diligence defence in a court of law. Is it enough?

Records for All V's Monthly Snapshot

You say you use a dry wipe system for weekly testing of emergency shower wash and other similar checks. Can you give us some examples and the standards they are covered by?

Who accepts wipe away records and what for?

Regards,
Simon

[rheath]

Simon,

The 3 pieces of regulation that spring immediately to mind are:

COSHH, (the need to provide emergengy precautions in event of chmical accident)

PUWER (provision & use of work Equipment Regs i.e. when we provide the shower we need to ensure that the equipment is suitable & maintained)

L8 - Control of Legionella

All these bits of legislation are pretty meaty and 'I believe' that our systems would stand up in court, in truth we will not know until tested.

To support my opinion we have an external H&S audit specialist who used our sytem as recommendation of good practice (albeit some operations do not test systems or have any records).

Our Subcontracted Environmental service provider (Water & Air safe programme), beleive the system to meet requirements.

The stance I would ultimately take is use the sytem that gives you the best chance of minimising/controlling contamination in the first place, hopefully we will not then need to cover whether documentation is adequate.

Kind regards

Richard


P.S. I didnt believe that you were suggesting process owners would loose accountability with paper based system, merely that you can more visually reinforce accoutability & monitoring with visual board i.e. you do not have to make a concious effort to look at records, supervisor can see when they are passing a work area.

[Simon]

Cheers Richard, but I can't help noticing that there are no examples on the food safety system side. That's what I was driving at, the food industry is very different and in my humble opinion I'm not sure whether this kind of record would be acceptable in the majority of cases. The only places I've seen ‘wipe off' records are in McDonalds and Asda toilets.

I'm probably totally wrong again; hopefully others will chip in with their experiences. Maybe an auditor or two might let us know how they'd call it.

Regards,
Simon

[rheath]

Simon,

I used the Health & Safety angle as there are there are many pieces of legislation that make the documentation/paper trail far more onerous than the hygiene side (basically because your H&S systems are tested in court far more often than Hygiene).

To add a food safety example albeit a little silly,

How do we demonstrate that personal hygiene practices are sound?

Do operators sign that they have washed their hands every time they have been to the loo, do supervisors undertake daily operator general cleanliness checks & log it, do operators sign each day to say that they are not taking uncontrolled items onto the shop floor.

These are examples of food safety hazards that we cover by policy, training, Instruction, supervision & routine periodic audits - I certainly wouldn’t advocate that we should be documenting these activities on a shiftly/daily/weekly basis.

I have two very polarised views, namely

1. In an ideal world we would have a piece of paper to prove we do everything we say we do.
2. In an ideal world we wouldn’t need a piece of paper to prove we do everything we say we do.

The pragmatic approach is probably somewhere between the two, we just need to decide where?!

I too would be curious to find a food auditors view on this particular example of glass control.

Regards

Rich

Edited by rheath, 26 October 2004 - 02:39 PM.

[Simon]

Do operators sign that they have washed their hands every time they have been to the loo, do supervisors undertake daily operator general cleanliness checks & log it, do operators sign each day to say that they are not taking uncontrolled items onto the shop floor.

<{POST_SNAPBACK}>

No.

I do agree with you Richard, but to take you back to the start of the thread. Tervor asked specifically whether temporary glass auditing records would be OK within a BRC/IoP remit.

And, in 4.3 Record Keeping "Control of non-production glass and brittle plastics" is included amongst the minimum records required list.

The question is would a BRC/IoP Certification Body Auditor accept temporary records albeit backed up by internal audits as a 'Record' or would there need to be permanent records of glass audits.

I'm not making the rules up - honest.

Regards,
Simon

[rheath]

I agree back to the initial question, the requirements in question:

4.3 - Record Keeping
The company shall maintain records to demonstrate the effective control of product safety, legality & quality
4.3.1 Records shall be maintained in order to prove that technical & hygiene procedures have been followed

For control of non-production glass & brittle plastics - If Trevor has:

-A glass register stipulating position/type of glass (Record)
-Isolation / Corrective Action report (Record)
-Periodic review that wipe board is being used & current e.g. monthly hazard patrol(Record)
-Customer Complaints (Record)
-Policy statement covering the use of wipe boards for control/auditing

IMO would see this as meeting the requirement of the standard.

Back to Trevor - have you ran this by your auditor? What was/is their view?

Regards

Richard

Edited by rheath, 26 October 2004 - 03:25 PM.

[Simon]

-A glass register stipulating position/type of glass (Record)

<{POST_SNAPBACK}>

A record is only a record when it is filled in, otherwise it is just a blank document template. Yes it shows you have a system in place but a blank document template alone doesn't demonstrate conformance to requirements.

In his proposed system Trevor will not have glass audit records.

Regards,
Simon

[rheath]

OK, I take your point with the static data.

To make it a record - What if there were columns with glass history e.g. intact, damaged, glass incident, replaced, quarantine etc

This way we avoid the need for regular access/updating, we can see the history of events in a plant and do not need to duplicate data recording..

[Simon]

To make it a record - What if there were columns with glass history e.g. intact, damaged, glass incident, replaced, quarantine etc

<{POST_SNAPBACK}>

I think that's the sort of thing they'd be looking for.

IMO the glass register and auditing of the items on it are probably the most important records in demonstrating ongoing glass control.

Thanks for you input Richard.

Is it just us two with a passion for glass control or does anyone else have a view?

Regards,
Simon

[rheath]

I just wanted to work the middle ground through to its natural end as I am a big supporter of visual check boards - there is always the trade off with record retention.

Regards

Rich

[Simon]

I am a big supporter of visual check boards

<{POST_SNAPBACK}>

Me too. :)

Regards,
Simon

[trevordrew66]

I agree back to the initial question, the requirements in question:

4.3 - Record Keeping
The company shall maintain records to demonstrate the effective control of product safety, legality & quality
4.3.1  Records shall be maintained in order to prove that technical & hygiene procedures have been followed

For control of non-production glass & brittle plastics - If Trevor has:

-A glass register stipulating position/type of glass (Record)
-Isolation / Corrective Action report (Record)
-Periodic review that wipe board is being used & current e.g. monthly hazard patrol(Record)
-Customer Complaints (Record)
-Policy statement covering the use of wipe boards for control/auditing

IMO would see this as meeting the requirement of the standard.

Back to Trevor - have you ran this by your auditor? What was/is their view?

Regards

Richard

<{POST_SNAPBACK}>

I have read with great interest your exchanges of views and think that you are right the next stage for me is to test this system with an auditor, i will not however be in a position to do this until mid-December but i will update you on the results,

Regards


Trevor