Top 5 Document Control Errors Made in GFSI-Benchmarked Audits

Document control is arguably the most common requirement to receive a non-conformance during a GFSI-benchmarked audit (BRC, FSSC 22000, IFS, and SQF). It is estimated that approximately 25% of all audits have a non-conformance for this requirement.

Essential Parts of Document Control 

Document control includes:

  • Document identification
  • Authorization of documents
  • Version control
  • Rescinding of obsolete documents
  • Maintenance of a master document list
  • Maintenance of a revision history for documents

1. The most common error made is having a document in use somewhere at the site that is not the most current version.

This is often a form that is being filled in or a procedure that an employee is referencing that is outdated. Typically this occurs because there is a gap in the program regarding where controlled versions are maintained. The keys to avoiding this are:

  • Establishing a list of the locations where controlled versions are kept and ensuring that this list is used when rescinding obsolete versions.
  • Ensuring that employees are made aware of where they can get controlled versions of a document. This also includes making them aware that they are not permitted to make extra copies and stash them for later use. Their private stash is not on the official controlled list.

2. Another common error is having a document in use that is not in the document control program at all.

This is most often some sort of reference material that was originally developed as a “cheat sheet”, such as a chart that lists key equipment set-up parameters or a chart in the laboratory with abbreviated information from finished product specification sheets. These reference sheets can be quite valuable, but they must be included in the document control program to ensure that the information is current and is universally applied.

3. Errors are commonly made when documenting revisions.

These errors include:

  • Making an update to a document, but not providing a new version number
  • Not recording the changes that were made (i.e. there is no revision history)
  • Not updating the Master Document List with the new version number

These errors are often made when the revision is hurried. The focus is on getting the new document in use and the supporting activities are overlooked.

4. A common omission in the document control program is control of documents from external sources.

When external documents are part of the Food Safety Management System, they must be controlled for the same reasons that internal documents need to be controlled. Document control ensures that the most current procedures are in use and that a record is maintained of which procedures were in place at any given time.

Examples of external documents that may need to be included in your document control program include:

  • Raw material specifications provided by your suppliers
  • Customer Expectations Manuals provided by your customers
  • Sample labels provided by your chemical and pest management suppliers

5. One of the most common errors in a document control program is failing to identify the personnel who are authorized to approve new or amended documents.

A person knowledgeable about the content of the document must be assigned responsibility for approving it. Too often, this responsibility is assigned to a single person across an organization. This might be the food safety coordinator or the document control clerk. However, it is not reasonable that a single person is knowledgeable about all procedures including, but not limited to those used for storage and logistics, production, maintenance, sanitation, and quality.

A better approach is to identify personnel responsible for authorizing changes based on function or discipline. For example, the sanitation manager may be responsible for authorizing new or modified sanitation procedures. And, like with all responsibilities, it is imperative that a qualified alternate, or deputy, also be identified.

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