Week 33 Corrective Action - We’ve got SALSA sussed..!
We’ve got SALSA sussed..!
Week 33 Corrective Action
Corrective & Preventive
Action is important to any business.
If your business has any sort of Incident
or Complaint, it is important to follow it through with Corrective and Preventive
Action.
Incidents are sometimes serious,
such as a Withdrawal or Recall. Sometimes, however, they are not as serious, they
happen on site before the product has left the building, therefore is still
under your control. However, it still needs ‘Actioning’ to Correct and Prevent.
If you were to have a Recall or
Withdrawal, it is imperative to ensure the immediate issue is addressed and the
product is taken off the market. And obviously, you would want to prevent it
from happening again. An investigation into why it happened would highlight the
reason, so you can action the Preventive Controls.
For less serious Incidents which
might happen on site, such as the Non-Conforming Materials we spoke about last
week, we still require immediate Corrective Action. If you don’t follow this
through with your investigation into why it happened and prevent it from
happening again, you would have a reoccurring issue. Every time an issue
reoccurs, this costs time and money. Therefore, we also need the Preventive
Action.
That is the reason why this section
has been added to the SALSA Standard. To help you and your business prevent
reoccurring issues from happening.
Let’s check out how to tackle
this one!
What’s coming next…
Week 34 Traceability
Corrective & Preventive Actions - what do you need
to show your SALSA auditor?
Corrective & Preventive
Action Procedure
Incident Record
Complaint Record
Corrective & Preventive
Action Procedure
Having a Corrective &
Preventive Action Procedure for staff to be trained against and follow is a
must. This is so that if they are responsible for carrying out incident
reporting they are clear on what they must do. Explain the difference between
the terms to help staff understand.
Corrective action: An
action taken to address the immediate issue.
Root Cause Investigation: An
investigation into why the issue has occurred.
Preventive action: An
action to prevent the issue from occurring again.
I am going to focus on examples of
Incidents which may happen on site and take you through Corrective and
Preventive Actions, (not Recalls or Withdrawals, as we have a whole section on
Managing Incidents in a few weeks’ time).
Corrective Action - is to address
the immediate issue. For example, if your metal detector test failed, you would
stop the line and quarantine the product which had passed through it since the
last ‘good test’.
The Preventive Action would be to
get an engineer to repair the metal detector. Re-test the metal detector and
confirm it is functioning correctly. The quarantine product would have to be
passed back through the functioning metal detector prior to it being released
as ‘good product’.
An incident could arise where a
staff member has not carried out a task as per the procedure. Such as, not
following the Metal Detection CCP Procedure correctly, and not completing it to
the correct frequency, or without all of the test sticks (there are 3 Test
Sticks to pass through, one is Stainless Steel (SS), one is Ferrous (F) and one
is Non-Ferrous(NF)). The same Corrective Action would apply as per above. All
the product must be quarantined since the last ‘good check’. A re-test must be
carried out through the metal detector with the correct test pieces and
re-start the correct frequency.
Then the investigation must be
carried out as to why this staff member has not followed procedure. The
investigation could go down the route of; the staff member was not trained in
how to carry out the CCP. Or, the CCP Procedure was not correct in the first
place, and needed altering to ensure the correct instructions for frequency and
test pieces is detailed and documented correctly. It could be that the staff
member didn’t think it mattered, or was rushing, or simply forgot. In any of
these cases, a retrain of the procedure would be required as your Preventive
Action. If the procedure needed to be updated, obviously do that first!
To complete the investigation, you
need to chat to the staff member/s involved and read procedures. Some people
find the investigation part the hardest part to document, so let me give you a
couple of different methods people use to try and get to the bottom of it!
You may have heard of them…. The ‘5
Whys’ and the ‘Fishbone’. Fancy names, simple methods really.
5 Whys
Write the investigation answering Why,
5 times, or until you get the answer to enable you to understand the root cause
of the issue, and Preventive Action required.
Q1. Why did the staff member not carry out the metal
detection test with all test pieces and at the correct frequency? Not trained
or inadequate procedure?
A1. He wasn’t trained.
Q2. Why wasn’t he trained?
A2. He was defined as a CCP Monitoring member of staff but
thought he’d better do it as the other trained member of staff was off that
day, he thought he was doing the right thing.
Q3. Why are there not deputy trained staff to do CCP checks
in case of absence?
A3. It’s the first time its happened, we need to train more
staff members to ensure this doesn’t happen again.
The above example shows the
questions lead to a Preventive measure in just 3 questions. However, if you
don’t get there in 3 questions you just carry on until you do find the answer.
Fishbone Method
This method looks at the different
areas of the business which could be responsible:
1.
Machinery
2.
Procedure
3.
People
4.
Materials (Ingredients, Packaging, Labelling
etc)
If we take the example of the metal detection test being carried out incorrectly by the staff member. However, it was confirmed that the staff member was trained on the correct Metal Detection Procedure. When checking the procedure, you find that it has not been documented specifically enough. The procedure states how to carry out the checks but does not state how often. The procedure states to pass the test sticks though the metal detector, but it doesn’t state which ones, when there should be 3 of specific sizes.
An update of the procedure and a
retrain of staff members would be your Preventive Action. However, it would
also flag up to me, that the person who wrote the Procedure may not be experienced
in writing the procedures. Are they the right person for the ‘procedure writing’
job, or would they benefit from more training themselves? Is there another
person in your team with more experience in writing procedures and training
documents?
Incident Record and / or Complaint
Record
You need a place to record your
Corrective & Preventive Actions, which could be on more than one record. If
you have Incident Records and Complaints Records, you need to include sections
on both, to add your:
·
Corrective Actions
·
Investigation
·
Preventive Actions
If you have a section within each
record, this means it is less likely to be forgotten, or not completed.
See the example below:
When auditors look at examples
they will look for fully completed forms, with all supporting information as
evidence you have carried out the Corrective & Preventives Actions
effectively.
At the end of the day, this
section of SALSA is here to help your business become more efficient in your methods
of working, causing less problems as time progresses, without costly
reoccurring problems.
It’s a good one to get right and I
hope this helps in doing so!
As always, I am more than happy to
answer any food safety related questions, whether they are SALSA related or
not. Get in touch!
Be careful and stay safe!
Ruth
Ruthshawconsultingltd@gmail.com
07732
966 836
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