Recording Times of Metal Detector Tests
Recently, my SQF auditor gave me a minor (and maybe a major) for improper time documentation on our metal detector tests. When asked for clarification, he claimed it was the FSMA that outlined rules we were violating. I don't really think we're in violation, but we could change it without any problem but if they make it a major, I'll have to challenge... Anyway, thoughts on this and if anyone can shed any light on the specific FSMA regulation, I'd appreciate it. So what we do is we perform a metal detector test once an hour. A metal detector test is described in our procedure as starting at machine 1, testing 3 test wands (the sop of course has detailed instructions), and then moving on to machine 2, machine 3, etc. for all 6 of our machines. This process takes about 10 minutes to complete. We record all 3 metal detector wand results for each machine and document the time we start the procedure. The auditors issue was with not recording 6 times for 6 machines. The only FSMA info I could find was: "The records must be kept as original records, contain values and observations from monitoring, be accurate and legible, be created concurrently with the activity documented, and provide details on the history of work performed. They must include the name and location of the facility, the date and time the activity was documents (SIC), the signature or initials of the person doing the activity, and when appropriate, the identity of the product and the production code." My first argument would be that we are performing 1 metal detector test procedure that includes testing 6 machines (and really 18 wands total).
My second argument is that putting the specific time for each check does NOT increase food safety. Our procedure says if the wand doesn't detect we pull back all implicated product (since the last good check). If we're pulling back to the time of the start of the check as opposed to the specific time for that exact machine (for example, pulling back to 5:00 pm instead of 5:02 pm), we're actually including MORE implicated product and thus providing a slight extra buffer (in the example - 2 minutes). Any thoughts or code references?
I remember this being an issue for the company I previously worked for. We had 3 metal detectors and the Line lead always did the tests and record keeping. He would always write in 15 minute intervals( he always did something at 11:00, 1:15, or, 3:30 because of his mild OCD :rofl2: He's a good friend of mine so I always give him crap about it. Anyways, back on to the subject. The auditor complained that there was no physical way he was at all 3 metal detectors and finished it at the same time, so it was forging of documents. We just told our lead to always write the exact time down when you start and or finish a procedure. Never was a problem again. Well, it was for awhile for the line lead. :roflmao:
Oh I thought it's auditor obligation to keep you Informed of the Audit Progress and findings.
I understand that you perform the metal detector tests for every hour by using 3 test wands for all the 6 machines.
If you record the time for each testing/about every hour (emphasize "about"), you should be okay. During lunch break, we say lunch break.
This year our auditor is focusing on FSMA as well.
I'm interested to hear more what other people advice are on here.
Dear All,
Surely the appropriate auditee's answer for the OP should have simply been the exact analog of the classsic auditor's mantra "Show me !"
Thanks all.
Just for clarification, the problem wasn't for if the metal detector tests were done each hour or not (they were), but that all 6 checks were performed as 1 test and only 1 time was documented.
To Charles, I did ask the auditor for the specific code he was referencing and he said 'look it up' and was somewhat hostile to any questioning on the topic.
As for the minor vs. major talk, he (the auditor) said he was putting it in as a minor but thinks the CB will change it in review (I don't think they will) as it's such a big issue. I started to plead my case about not affecting food safety but quit as he was resistant. I'll, of course, articulate my complaint fully if it does somehow come back as a major.
As long as your policy/procedure specifies when you are doing the checks (i.e. once per hour +/- 10 minutes or every product changeover etc...)
And each actual check of the MD is recorded with the time it was actually checked, I'm not sure what the issue is here.
The time you physically challenge the metal detector is the time you log it.
You can't do three challenges of six metal detectors and record all of them at the same time. I think that is what the auditor is getting at.
Marshall