SQF Audit NCR - Whether to Appeal or Submit?

I want to make sure I have the "rules" correct.  If the CAR was written, do I simply submit the information, proving the material is food grade to close the NCR, or do I have to file an appeal?

I also want to be very sure that we are correct. 

This is what she wrote

Proof.

Do you have documentation to prove what you verbally told the auditor?

If not, that's an issue.

Was part of the issue that the panels are not being cleaned properly, etc?

If  you feel the Auditor was just in the call - then you must submit a corrective action with all your proof and what you did to rectify, etc. that info gets reviewed and is either accepted or rejected.

If on the other hand you feel the call was incorrect, you must appeal it.

And by way - if you are an SQF Admin person who is the SQF Practitioner?

The Director of Operations.  Who is very good at getting all the physical requirements, labs and things actually accomplished.  I basically get the paper side of it done.  Hope that helps explain that.   We are very small. 

I am not sure what kind of proof I would have that we challenged it or provided the opportunity to show her that it is what it is other than the 6 people in the room during the closing meeting?

It is cleanable, one has a "dark" stain that we think is from a light or something probably during the installation years ago.  It has been there forever.  If she had said that it needed to be fixed, I would have understood that.  She wants the entire ceiling in 3 rooms replaced. 

So I must go through the appeal process. 

 

I want to make sure I have the "rules" correct.  If the CAR was written, do I simply submit the information, proving the material is food grade to close the NCR, or do I have to file an appeal?

 

I also want to be very sure that we are correct. 

 

 

This is what she wrote

 

"M11 - 11.2.3.1 :Walls, partitions, ceilings and doors shall be of durable construction. Internal surfaces shall be smooth and impervious

with a light-colored finish and shall be kept clean (refer to 11.2.13.1).

Evidence: The ceiling in the bottling room is not of durable construction and the internal surfaces are not smooth and impervious and not cleanable."

 

 

We tried to challenge and she would NOT go look at it.  We offered to put her on the scissor lift ( it is the ceiling) and she could touch it.  

 

To be clear, I am more of the SQF Administrator, I am not the PCQI - someone else is, but I want to make sure we are absolutely correct before I submit it.  ( I have found out he was wrong before)  This is the information he is giving me for "proof" 

 

"The ceiling panel specification (USG Sheetrock Brand Lay-In Gypsum Ceiling Panels).  The ceiling tiles are made from what we were telling the auditor, a vinyl-laminated face.  It is washable, scrubbable smooth textured and scratch resistant.  They meet USDA/FSIS requirements for food processing areas.  They are labeled as #3270 on the back of the panel.  Picture attached for proof."   "Well there are a few areas but the main area for Processing and Bottling of Bottled Drinking Water is PART 129, CFR Title 21, Section 129.20 (a) Plant construction and design.  Section 129.37 (d) Sanitary Operations."

 

Just trying to sort through this - you mention tiles. Are there gaps between each panel that would be hard to clean, or is it all one smooth panel for each room? Also, is this a drop ceiling? 

Otherwise, if the surface is smooth, durable, and cleanable, I don't see why this would be a non-conformance.

Just trying to sort through this - you mention tiles. Are there gaps between each panel that would be hard to clean, or is it all one smooth panel for each room? Also, is this a drop ceiling? 

 

Otherwise, if the surface is smooth, durable, and cleanable, I don't see why this would be a non-conformance.

 

It is a drop celing, and the Panels I listed originally are the panels.   There is lights with plastic covers every so many.  We are a bottled water facility, and the Dept of Agrigulture has come out and inspected many times.   

 

Just trying to sort through this - you mention tiles. Are there gaps between each panel that would be hard to clean, or is it all one smooth panel for each room? Also, is this a drop ceiling? 

 

Otherwise, if the surface is smooth, durable, and cleanable, I don't see why this would be a non-conformance.

 

It is a drop celing, and the Panels I listed originally are the panels.   There is lights with plastic covers every so many.  We are a bottled water facility, and the Dept of Agrigulture has come out and inspected many times.   

 

Ok, you need to prove that your drop ceiling is cleanable (not just the panels), and that you have records to show that you are doing that on some frequency. Also, you should have some pest control for the area above the drop ceiling. Drop ceilings aren't the greatest ceiling type, but you being a bottled water facility helps in that you would be lower risk for hazards associated with this ceiling type. I would be more concerned if you were a dry product facility.

You can certainly conduct a risk assessment for this including all your previous statements to justify your claim and then appeal the finding.

Her evidence is vague. I would ask your CBs technical for clarification of "not of durable construction", and "internal surfaces" and also "not cleanable" relating to the ceiling. If the type of ceiling is the issue, she should state that. There is no benefit from an audit that doesn't identify the specific issues with the items cited. How are you supposed to change something if you don't know what to change? Go back to your HACCP training and root cause analysis: Who, What, When, Where, Why, Why, Why, Why, Why, Why and don't let an auditor leave without answering all of your questions. Auditors might not like to hear this but you're paying for them to come in and test and measure your program and identify deficiencies. Make sure they're earning that money and completing their task. You might also mention in you inquiry for clarification, that she was unwilling to look at evidence or explain exactly what the issue was, which they can read for themselves in the audit report. It might help during the appeal process if you end up there. Good luck.

The auditor notes a nonconformance in the audit report.

You can appeal without providing a CAR if you believe that no correction is necessary and the current situation should be acceptable.

Otherwise, if you provide a CAR, then you are agreeing that there is a nonconformance that needs correction.

If the CAR is not acceptable, then you can appeal that decision.

If all appeals are rejected, then you will need to implement an acceptable corrective action.