Nonconformances caused by employee errors are to be expected in a food facility, especially if an establishment has high staff turnover, temporary personnel, or a large number of manual processes. When these types of nonconformances occur, the decision of whether to conduct a root cause analysis or implement both corrective and preventive actions depends largely on the type of deviation at hand. For example, an employee deviation in the form of failing to change gloves and wash hands after returning to a production area would require a correction or a corrective action, but a full root cause analysis investigation or the implementation of a preventive measure may not be necessary.
However, an employee deviation of greater severity, such as one involving a critical safety or food safety violation warrants the use of all steps in a CAPA program and may also include disciplinary action for the employee involved. An example of a deviation of this type may include failure to follow lock-out tag-out procedures, which could result in serious injury to personnel or significant equipment damage. Another example could include falsification of product temperatures on a critical control point monitoring form, which could result in unsafe products entering commerce. In both of these examples, disciplinary action should be used as part of the CAPA program in accordance with your company’s human resources policies.
In Kellerman Consulting’s next video in the CAPA series, we discuss management and auditing of the CAPA program. Subscribe to our YouTube channel or follow us on LinkedIn to be notified of new educational food safety resources.