Root Cause cannot be human error

Hello All! My company has just had it's annual re-certification audit and I am working on our corrective actions. One of our findings was not having self-closing devices on ALL doors. We had interpreted 13.1.4.1 " All external windows, ventilation openings, doors, and other openings shall be effectively sealed when closed and proofed against dust, vermin, and other pests. External personnel access doors shall be effectively insect-proofed and fitted with a self-closing device and proper seals to protect against entry of dust, vermin, and other pests." as meaning that doors personnel use to enter the building. The doors found without are fire exit doors. We have purchased the devices and are installing them as we speak. My question is, if my root cause cannot be "human error" per the certification body, what would my potential root cause be?

The actual root cause must be human error as it was a human that failed to fully grasp the requirements of the code and install same.

That is what I figured. However, the instructions for the checklist of submittal specifically states that  "A Root Cause cannot be restatement of the finding or human error."  Therefore, I am frustrated.

who's your CB?

The root cause is that you followed fire code and that trumps SQF ----that should get around that problem   (assuming the fire code only requires doors that release and push open, but cannot be opened from the outside)

I wouldn't be comfortable with a CB who gets to dictate the root cause of anything....................sometimes  (ok alot of the time) it IS human error

Eagle. 

I have gone back through our past NCRs and found that human error has been accepted! You are very right, sometimes things just are human error.

These doors can be opened from the outside, but are never unlocked. 

I used misinterpretation of the meaning "personnel access."

Thanks everyone for your answers, it has helped ease my headache!

This could be worded back into a training error, makes short term non conformance action a training class, long term correct closures IMO.

The actual root cause must be human error as it was a human that failed to fully grasp the requirements of the code and install same.

Eh, I am guessing they don't want it to be a 'human error oops' type response and are looking for the specifics to be listed. I don't see why 'Slight misinterpretation of the code whereby the assumption was made this requirement only applied to heavily frequented entrances and exits.'

Just a heads up after you install the self closers, get ready to find those doors propped open now from the people that take their sneaky smoke breaks or use those emergency exits as a shortcut.

Good point Tim, I have luckily had some pretty understanding auditors and this has not been an issue for me (yet, I'm sure I just jinxed myself).  But yes, I 100% agree - if you can get cameras on those doors you should.  You'll figure out your frequent offenders quickly.

On more than one occasion, I've stated as root cause "Current and/or Former QAM/FSM mis-interpreted code" and it's been accepted.

I've also had an auditor not know how to read a piece of piping and gave us a point bc he thought the pressure rating on a galvanized stainless steel pipe was the stainless grade, and my root cause was "Auditor was uninformed about how to properly read numbering on galvanized pipe and therefore incorrectly gave point" and our C/A was a note from the manufacturer on how to read the numbers printed on pipes.

He accepted it- he was a technical writer filling in for audits, so I'm sure he didn't want that one to go to his bosses. 

Sometimes creative wording of your answer might help.  The suggestion above on improper training might be a good solution.

With the new addition to cGMP re: Food Safety, Food Fraud etc I was able to buy my company some time to get a mitigation program together but it wasn't easy.  

On more than one occasion, I've stated as root cause "Current and/or Former QAM/FSM mis-interpreted code" and it's been accepted.

 

I've also had an auditor not know how to read a piece of piping and gave us a point bc he thought the pressure rating on a galvanized stainless steel pipe was the stainless grade, and my root cause was "Auditor was uninformed about how to properly read numbering on galvanized pipe and therefore incorrectly gave point" and our C/A was a note from the manufacturer on how to read the numbers printed on pipes.

 

He accepted it- he was a technical writer filling in for audits, so I'm sure he didn't want that one to go to his bosses. 

 

Sometimes creative wording of your answer might help.  The suggestion above on improper training might be a good solution.

 Speaking of Fire exits do you guys have any recommendation for tamper proof security seals for emergency exit doors/roof access, our company has been using stickers but I can tell that they just move them and then re stick the same sticker/ 

Thanks

 Speaking of Fire exits do you guys have any recommendation for tamper proof security seals for emergency exit doors/roof access, our company has been using stickers but I can tell that they just move them and then re stick the same sticker/ 

 

Thanks

> Post 8 ??

I agree that 'human error' shouldn't be the root cause.  It needs to be more specific.  
I was also told that the RC and CA should state WHO.  Doesn't have to be an individual.

"The maintenance department was unaware of ....."  "The production staff received more training on ......"
"The HACCP team failed to implement ......"   "The QC staff implemented testing on ........"

 Speaking of Fire exits do you guys have any recommendation for tamper proof security seals for emergency exit doors/roof access, our company has been using stickers but I can tell that they just move them and then re stick the same sticker/ 

 

Thanks

Install the emergency door mechanism that only unlocks if the fire alarm goes off 

https://www.grainger...oor-Alarm-1U122

You should be able to say it was an oversight on management part.