Appeal of Nonconformance Finding

Golfman25

Trusted Information Resource
So if you have TWO unlabeled containers, what substance is in each container? This sort of stubborness reads as very petty.


Do you have ANY work Instructions? Are all the inspections being done on-the-fly?
Any more stubborn than auditors/people who demand labeling under all circumstances? If asking the person in control of the containers isn't possible (the old they won the lottery last night BS), identification is easy. If it's amber colored and the viscosity of honey it's A108. If it as a brownish tint and a light viscosity it's 1325. If it's clear, then it's E310. It's not rocket science.

Now the reason I'm stubborn about it is because of the beast the "labelers" want me to create. If we implement a label policy, then I have to probably double the number of containers as they won't be reusable, then have room to store them, and then "police" the labels (which can come off, get smudged, or otherwise become illegible). Chances are an unlabeled container will show up somewhere, and boom "violation" that has to be reacted to. All this for something that has no significant impact on our day to day operation. What sense does that make?

As to work instructions, we have plenty. Every job has a work order with all the instructions -- what tools, machines, and any specific issues to address. Measured inspections are done to print/computer layouts. The inspections done on-the-fly are sorting -- largely dependent on what the run produced which can be different each time. Usually representative samples are provided to compare.
 

Golfman25

Trusted Information Resource
In general, I'd say ISO 9001 clause 8.5.2 Identification and traceability: "The organization shall use suitable means to identify outputs when it is necessary to ensure the conformity of products and services ... The organization shall control the unique identification of the outputs when traceability is a requirement, and shall retain the documented information necessary to enable traceability."

Because it's a secondary container, it follows that the oils being there is the output of a dispensing / pouring process (or activity, but that's a different discussion).

However, because you previously stated "the type of oil would have little effect on the quality of products in question", from a risk-based perspective there is little risk that the conformity of products would be affected, and clause 8.5.2 may not apply to the oils.
This is a good point. The oils aren't part of the output, so not really applicable. But in fact, our "weakness" is keeping labels on product as it moves thru the operations. I'd rather spend time working on that one, cause that's a much bigger issue.
 

Tidge

Trusted Information Resource
Any more stubborn than auditors/people who demand labeling under all circumstances? If asking the person in control of the containers isn't possible (the old they won the lottery last night BS), identification is easy. If it's amber colored and the viscosity of honey it's A108. If it as a brownish tint and a light viscosity it's 1325. If it's clear, then it's E310. It's not rocket science.
Obviously you feel differently, but this approach strikes me as sloppy housekeeping for a shop. Our in-house machine shop has many different liquids (including cutting fluid, machine oils, rinse solutions, paints and cleansers, etc.) and somehow the labels for the dispensing/collecting containers are able to be maintained.

It's not my place to engage in ten rounds of "what if?", but if the requirement is to keep control of the manufacturing materials used on the floor (including what comes onto the floor and what leaves the floor) and it can't be demonstrated that they are under control the onus isn't on the auditor to imagine that the controls exist and are effective.
As to work instructions, we have plenty. Every job has a work order with all the instructions -- what tools, machines, and any specific issues to address. Measured inspections are done to print/computer layouts. The inspections done on-the-fly are sorting -- largely dependent on what the run produced which can be different each time. Usually representative samples are provided to compare.
If the work instructions for final inspection were released per an approval process that was approved by the process owner and someone acting as the independent quality approver, then (in the absence of any evidence that not having such WI is impacting quality) I don't think there is an issue with not having WI specifically for in-process job duties. Show the evidence of the approved process flow and the approved WI.
 

Golfman25

Trusted Information Resource
Obviously you feel differently, but this approach strikes me as sloppy housekeeping for a shop. Our in-house machine shop has many different liquids (including cutting fluid, machine oils, rinse solutions, paints and cleansers, etc.) and somehow the labels for the dispensing/collecting containers are able to be maintained.

It's not my place to engage in ten rounds of "what if?", but if the requirement is to keep control of the manufacturing materials used on the floor (including what comes onto the floor and what leaves the floor) and it can't be demonstrated that they are under control the onus isn't on the auditor to imagine that the controls exist and are effective.
Funny, my machine shop does too. But it's a completely different environment from my stamping department, which does drawforming (which is much different from the stamping people normally see). Understand, that the oil comes and goes within hours as the jobs are processed. So not much is really static, just sitting around. And what do we do if we decide we have to mix an "oil cocktail" to get the viscosity we want because the material for a particular job decided to act like a little *&^% today? We are going to make 1000 pcs., so we need maybe a cup of oil. It will be there for 2 hours. max. Is it good enough to label it "oil?"
 

Miner

Forum Moderator
Leader
Admin
Just a couple alternative ideas for the labeling problem:
  • Use different colored containers with an identification key posted nearby
  • Use a permanent physical mark or stamp on the containers with an identification key posted nearby
  • Store the container in a special location at the workstation and label the location
 

Wearerofmanyhats

New, don't hurt me
Just a couple alternative ideas for the labeling problem:
  • Use different colored containers with an identification key posted nearby
  • Use a permanent physical mark or stamp on the containers with an identification key posted nearby
  • Store the container in a special location at the workstation and label the location
i've seen all three of these implemented, consider container/label shapes too. From a safety standpoint how does the employee know what to do if said chemical is ingested? (get two birds stoned at once since its an osha requirement also)

when i worked at an auto parts manufacturer in town we had a similar situation with satellite containers being an issue. We solved this problem with a.)storing the oil containers in their respective location (cubby) b.) having labels color coded that were hung from the container itself that were easily replaced. In some cases if i used hydaulic fluid in place of light oil it could be a serious problem for our capital equipment so we had to go in depth.

silly story time: i once was cleaning with a solvent which had rubbed off the "brake cleaner" sharpie logo and accidentally ruined a customer's paint job on his truck. OOPS.
 
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Miner

Forum Moderator
Leader
Admin
I forgot to add another. Use a metal tag with the oil ID stamped out like a stencil. You can connect that to the container in a variety of ways (e.g., wire, chain, slotted holder, etc.).
 

Wearerofmanyhats

New, don't hurt me
I forgot to add another. Use a metal tag with the oil ID stamped out like a stencil. You can connect that to the container in a variety of ways (e.g., wire, chain, slotted holder, etc.).
boom, snag a tag from the oily tag board slap it on your container and go
 

Golfman25

Trusted Information Resource
I do appreciate the debate and back and forth. So if I go ahead and implement an "oil labeling system" I'll need to provide my guys with clear guidance. So I am going to lay out a few regular every day situations for comment. First a little shop background. Total people -- 7-10 depending on how busy we are. Run 3-5 jobs per day, and 20-30 jobs per week. A lot of small runs, 1000 pcs. or less. Some medium runs, several thousand pcs. And a few longer runs, 100,000 pcs. or more. All oils are stored in a central location in properly labeled manufacturer-provided 55-gallon barrels.

1) Robbie starts his day with part A. He'll be running 350 pcs. He'll be using pre-cut strips of metal so he'll be coating the strips via a paint roller before forming. He sets his die and grabs the paint tray and roller. He adds a few ounces of 1325 oil to the try and proceeds to coat the first few strips. It's going to take him about 30 min. to run all parts. When he's finished, the paint tray is empty and he puts it back on the shelf. Does the paint try need to be labeled while in use?

2) Robbie moves on to his next job, part B. He'll be running 1500 pcs. via. a coil fed process. Lubrication will be provided via a gravity drip system. He sets his job, and needs a quart of A108 oil. He takes a small container, fills it with A108, and transfers it to the reservoir of the gravity drip system. It will take him 1-2 hours to run the parts. A) Does the small container he used to transfer the oil from the 55 gallon drum to the reservoir need to be labeled? B) Does the reservoir need to be labeled?

3) Now we'll go to Mark. He's running a longer job, part C, with a coil fed process. He'll be running this job for a few days. He sets his die and will be using a gravity drip system to provide lubrication. Because it's a long run, he fills up a gallon container of A108, and fills the reservoir, leaving about 2/3 gallon remaining in the container. That container will be in his possession at his workstation the entire day and week. He's filling the reservoir all morning. By lunchtime it's empty, so he refills after lunch, and continues for the remainder of the day. The oil pools and drains off the bolster plate of the machine, so Mark puts a container in place to catch the drippings for recycling. A) Does the gallon container need to be labeled? B) Does the reservoir need to be labeled? C) Does the catch container need to be labeled?

4) Last one is John. He's stuck with a difficult job. The metal is giving him the "middle finger" and just doesn't want to form correctly. He's working with the oil and decides he's going to try an "oil cocktail" mixing two oils 50% A108 and 50% 1325. He makes about a quart of the mixture in a container, does a voodoo dance, and bingo it works. He uses a brush to apply the oil and runs parts for a few hours. A) Does the container need to be labeled? What does the label say?

I know that's a long post and I only hit a few regular scenarios. Your feedback is appreciated. Thanks.
 

Wearerofmanyhats

New, don't hurt me
I do appreciate the debate and back and forth. So if I go ahead and implement an "oil labeling system" I'll need to provide my guys with clear guidance. So I am going to lay out a few regular every day situations for comment. First a little shop background. Total people -- 7-10 depending on how busy we are. Run 3-5 jobs per day, and 20-30 jobs per week. A lot of small runs, 1000 pcs. or less. Some medium runs, several thousand pcs. And a few longer runs, 100,000 pcs. or more. All oils are stored in a central location in properly labeled manufacturer-provided 55-gallon barrels.

1) Robbie starts his day with part A. He'll be running 350 pcs. He'll be using pre-cut strips of metal so he'll be coating the strips via a paint roller before forming. He sets his die and grabs the paint tray and roller. He adds a few ounces of 1325 oil to the try and proceeds to coat the first few strips. It's going to take him about 30 min. to run all parts. When he's finished, the paint tray is empty and he puts it back on the shelf. Does the paint try need to be labeled while in use?

2) Robbie moves on to his next job, part B. He'll be running 1500 pcs. via. a coil fed process. Lubrication will be provided via a gravity drip system. He sets his job, and needs a quart of A108 oil. He takes a small container, fills it with A108, and transfers it to the reservoir of the gravity drip system. It will take him 1-2 hours to run the parts. A) Does the small container he used to transfer the oil from the 55 gallon drum to the reservoir need to be labeled? B) Does the reservoir need to be labeled?

3) Now we'll go to Mark. He's running a longer job, part C, with a coil fed process. He'll be running this job for a few days. He sets his die and will be using a gravity drip system to provide lubrication. Because it's a long run, he fills up a gallon container of A108, and fills the reservoir, leaving about 2/3 gallon remaining in the container. That container will be in his possession at his workstation the entire day and week. He's filling the reservoir all morning. By lunchtime it's empty, so he refills after lunch, and continues for the remainder of the day. The oil pools and drains off the bolster plate of the machine, so Mark puts a container in place to catch the drippings for recycling. A) Does the gallon container need to be labeled? B) Does the reservoir need to be labeled? C) Does the catch container need to be labeled?

4) Last one is John. He's stuck with a difficult job. The metal is giving him the "middle finger" and just doesn't want to form correctly. He's working with the oil and decides he's going to try an "oil cocktail" mixing two oils 50% A108 and 50% 1325. He makes about a quart of the mixture in a container, does a voodoo dance, and bingo it works. He uses a brush to apply the oil and runs parts for a few hours. A) Does the container need to be labeled? What does the label say?

I know that's a long post and I only hit a few regular scenarios. Your feedback is appreciated. Thanks.
Okay, so I am more involved with safety than I am quality at this point (former safety czar turned quality supervisor guy) so my buzzers are going off big time here from that standpoint. I'll try to suppress that. I sense that this CB is trying to achieve the same results my safety auditor would
(we had a few accidents leading to a pretty serious one, i saved my company out of some issues and now am being positioned to do the same with ISO).

So, in your case any satellite container MUST be labeled, no excuses. I purposely buy open top containers, and spend a small fortune on them. Any clean containers that are not labeled need to be stored in the fire cabinet where there are respective locations. We do toolbox talks with gathered signatures for our safety program that trains procedure for that. Process is kept in the safety handbook, policy as well. I'd say this is a safety issue handled by a safety team rather than an ISO finding.

However, if you use the wrong materials for any job its an issue. I'm new here so be gentle and take it with a grain of salt.
 
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