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![]() Clean Room Gowning Work Instruction
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| Author | Topic: Clean Room Gowning Work Instruction |
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ISO GUY Forum Contributor Posts: 81 |
During an internal audit of one of our facilities I cam across something interesting. As I was doing the audit I cam across a page from one of our SOPâs which was so beautifully blown up and laminated. In short the section explained how the employees entering the room were to gown up (i.e. wash hands, put on hair bonnets, coats, etc·). So I checked the revision level that was on this page, then checked it against the actual SOP, and much to my surprise (not really) the nicely laminated document on the wall was a prior revision. When I pointed this out to the QA Manager she agreed that it needed to be removed (which it still has not been removed a month later), but then said well we can put them up as a guideline but leave the control off of it. Which to that I suggested that she not do that. First of all I explained to her that it is in a SOP, secondly it tells the employee what needs to be done, lastly I asked if you leave it up as a guideline with no control if any changes were made who would know to go change the ãguidelineä. Well she proceeded to argue that gown up procedures will never change they will always be the same. I politely said that gown up procedures may change they could become more or less stringent, and that if they do change that the ãguidelineä which would be uncontrolled would also need to be updated and revised according to our procedures. My question is am I wrong about wanting this to be controlled or can a guideline on gown up be left up? IP: Logged |
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CarolX Forum Contributor Posts: 108 |
My thoughts on this.... The procedure must be controlled. As you stated, this procedure could be changed. But .... IMHO a procedure is useless if kept in a binder on a manager's desk, or on a computer that is not accesible to everyone. I think laminating and posting the procedure is an excellent idea. Now you need to find some agreement with the QA Manager on the control of this document. Good Luck and hope I didn't confuse the issue more. IP: Logged |
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barb butrym Forum Contributor Posts: 637 |
the control needed is local control. What i use when i need it...is a tag/label that identifies the document the posting is from, and the current revision level..and that no changes to that information occurred. that gets updated when the SOP does...IF there ever is a change to the gown up protocol...then the posted document will be changed.... Works for me for color coded blown up visual aides mostly, especially when the partial drawing does not show the doc # and rev level....but the principal is the same...just make it easy and do-able the control belongs to the person that wants it up (ergo LOCAL)...they post it so they take ownership for reviewing changes to the document and updating teh label...and replacing it if needed. [This message has been edited by barb butrym (edited 14 August 2000).] IP: Logged |
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Claes Gefvenberg Forum Contributor Posts: 23 |
Yes I definitely think it should be controlled. I'll also have to agree with Carol, and would like to extend the discussion a bit. This way of presentation makes the procedure far more accessible than a binder. Controlling it something else,however... We have quite a few documents of this kind, and I'll admit that we used to have a very hard time controlling them. More often than not they proved not to be current versions and / or unauthorized copies. This is no longer a problem: Every copy of a procedure has a registered owner. We make no difference between binders and wall posters in that respect. A database solved that problem. We also have all procedures available on our intranet. This is very important as it has enabled us to reduce the number of paper copies significantly. In short we are hard at work getting the relevant information to the right people, and at the same time getting away from the binder terror. It is admittedly simpler to spread binders all over the place, but this approach works far better for us. / Claes IP: Logged |
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Andy Bassett Forum Contributor Posts: 274 |
I can agree with everyone on this, but at the same time i do have a certain amount of sympathy for the original problem, as i come across it regularly. Just how detailed do you go with controlling documents? The danger of not controlling is clear, the danger of over- controlling is also clear; people will be petrified of issuing notices/signs/instructions. What i normally do is create something like a level 4 document called 'Help Instructions'. These fall outside the system and are not signed-off or approved. I just ask that people store them in one folder on a server, so that we can see which is the latest version. Regards
[This message has been edited by Andy Bassett (edited 16 August 2000).] IP: Logged |
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David Mullins Forum Contributor Posts: 248 |
Andy, Your external auditors and consultant customers are happy with you creating uncontrolled guidance documents of this nature? You might get the auditor to laugh a lot while s/he writes out the nonconformance. I'd say your only hope is to prove that not one of them (the examples you cited) affected quality. This being the case you might be confusing the less learned "quality person" as to what is allowable under the requirements. ------------------ IP: Logged |
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Andy Bassett Forum Contributor Posts: 274 |
Yes David - You are right, such instructions do need to be related to items that dont affect quality. However the next question is what does actually affect quality? If we wanted to be pedantic we could say that everything in the end can eventually affect quality, even down to the use of pool cars. I firmly beleive that such instructions do have a place and a useful function in 'De-Hasseling' an organisation by providing guidance on the simple annoying small things of working life. Yes the customers are happy, as they have a comprehensive system with levels of complexity according to the need, and yes the auditors are happy unless they see in this area any quality related instructions. ------------------ IP: Logged |
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ISO GUY Forum Contributor Posts: 81 |
I just want to say thank you to all that have responded so far. I would have to say that gown up procedures to enter a clean room would affect quality if not done properly. IP: Logged |
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Marc Smith Cheech Wizard Posts: 4119 |
"...However the next question is what does actually affect quality? If we wanted to be pedantic we could say that everything in the end can eventually affect quality, even down to the use of pool cars..." This is the heart of it. Where control lies is irrelevant - local or higher. In addition, it is not just whether it affects quality but to what degree (which is why I quoted Andy. The importance of a document describing suit-up depends upon the specific situation. For example, what class clean room are we talking here? Class 10,000 (e.g www.carrenterprises.com ). Class 1000? (e.g. www.midamericaplastics.com ) I tend to go for the OJT in suit-up. Tell the folks what they need to wear and where and when. Suit-up isn't really that complex, in my opinion, that a planned layout of the dressing area cannot easily address. I think too much is documented, though, in many companies. If I was running a company and we had a clean room for certain processes I would want people working in there who didn't need an instruction at the door telling them how to suit-up. Initial instruction should be enough. I have to vote for removing the instruction all together and addressing the issue through layout of the dressing area and OJT. Most of the nonconformances I have seen in suit-up were unrelated to the instruction - it was stupid stuff like wearing a mask on the chin for comfort (do it once and if no one complains just keep right on doing it if you want). Or not completely covering the hair. Or wearing makeup or perfume. Stupid stuff like these examples is mostly what I've seen. Sequence of what items have seldom been a significant problem. But again, in my opinion many (most) companies go way overboard in what they document while doing little or nothing to enforce obvious infractions. I see this in reviewing forms quite often. It's supposed to be initialed and dated by people found that when they 'forgot' no one said anything. After that it's all down hill. I'm a democrat, but I will use a republican complaint: Enforce the rules you have (e.g. OJT compliance) before you draft and issue new rules to enforce (e.g. we need a work instruction on how to suit-up.). Lastly - I must admit - I agree gowning procedures don't often change much. Unlike many procedures / systems (particularly in manufacturing) gowning is pretty basic and consistent with consideration to the class of clean room. I believe changes in gowning 'procedure' should be communicated during shift change or weekly meetings (depends upon how your company is set up). [This message has been edited by Marc Smith (edited 17 August 2000).] IP: Logged |
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CarolX Forum Contributor Posts: 108 |
Marc, "I'm a democrat, but I will use a republican complaint: Enforce the rules you have (e.g. OJT compliance) before you draft and issue new rules to enforce (e.g. we need a work instruction on how to suit-up.)." Wow, did you hit the nail on the head!!!!! How many times I have seen this occur where I work. Instead of enforcing what we have, upper management wants to create new rules. IP: Logged |
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Marc Smith Cheech Wizard Posts: 4119 |
IMHO -- Typically: Upper Management = Politicians They rarely address the root cause. They typically address the symptom(s). And even when they address the symptom they quite often are far off base there as well. OOh well... IP: Logged |
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Andy Bassett Forum Contributor Posts: 274 |
Dont complain too much Marc. That and unreadable standards probably keeps the likes of us in business. Regards PS Am i developing a bad attitude? If so it must be all your influence ------------------ IP: Logged |
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Marc Smith Cheech Wizard Posts: 4119 |
I'm not really complaining. I can't even say this is fact. It is, however, my perception... And I do qualify with the word 'typically' as its not always the case. Just most of the time.... And you're gona blame me for bad habits you develop??? ![]() IP: Logged |
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Tom W Forum Contributor Posts: 18 |
Documents need to be available where the absence could affect quality. Controlling the documents needs to be done. It can be done a hundred diffrent ways but, it should be done. Depending on your company how critical is the gown up process? Decide if done wrong could it affect quality? If yes then control a posting and update it as needed. I have seen where a list is made of all postings that are controlled with the revision level and serial number if applicable. IP: Logged |
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ISO GUY Forum Contributor Posts: 81 |
quote:
We are not drafting new rules to enforce, this was in place well before I startd working for my employeer. Also I never said that gown-up procedures change on a regular basis, what I did say is that if they do change they need to be updated. The gown-up procedures are already in an SOP and have been for years. So if they change they procedure in place would needo be revised. If they are not controlled who is going to know that the changes are made or communicated. Lastly it is very important that they follow the proper gown-up procedures, since what they are doing is packaging sterile edical devices, unless of course you don't care if the Doctor uses a sterile device on you, I guess that would be your call. IP: Logged |
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Marc Smith Cheech Wizard Posts: 4119 |
You say: "...The gown-up procedures are already in an SOP and have been for years...." I'm sorry, but I don't buy the old "...we've been doing it this way for years so it must be right..." arguement. My point is this: Stand back and ask yourself whether you need that procedure. Just because it's there doesn't mean its needed. You say: "...Lastly it is very important that they follow the proper gown-up procedures..." I agree that gowning is typically important. That doesn't make it a complex procedure requiring a work instruction (which is what a gowning procedure is). As I said in my post, if it was my company I wouldn't want people working in a clean room who needed an instruction on how to gown after they were instructed how to do it. I've been in many companies in many clean rooms (including medical device assembly clean rooms) and have never seen a seriously complex gowning sequence. Even 'space suits' aren't that complicated. With sub-levels it's a matter of layering sequence. I liken this to the sign in the bathroom which says: "Wash Hands Before Returning To Work". If you truly need that sign even after you've told your employees, I'd say: 1. If it takes a sign to 'remind' your employees to wash their hands after using the restroom, you may want to rethink your hiring criteria for that position. 2. People won't pay attention to the sign if they didn't listen to you when you told them that is a company policy. Just my opinion. You must remember I'm a documentation minimalist and am pro-OJT. I simply do not always agree with the level of documentation many companies produce. I believe many documents are unneccessary reactionary reflexes unrelated to solving the root cause of the problem that instigated the reaction to begin with. You said: "...Also I never said that gown-up procedures change on a regular basis, what I did say is that if they do change they need to be updated...." Yes, to which I responded that these rare occasions can be easily dealt with in communication meetings. My response was in sympathy with the QA Manager who wanted to essentially demote or eliminate the document all together (or to me it sounds like this was the implication). A last question to you: Is improper gowning a problem now? Can any nonconformances (other than to the gowning procedure its self) be traced to improper gowning? [This message has been edited by Marc Smith (edited 17 August 2000).] IP: Logged |
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David Mullins Forum Contributor Posts: 248 |
Geez Marc, you do pretty good for an old bloke. Your last entry is not only on the mark, it was too close to home. We have a 35/350 clean room, and have recently revised the gowning procedure (yes we have one). People put their mask on at different stages of the gowning process, which in no way effects contamination, but is a nonconformance against the procedure. Do we need the procedure? Probably not, as the people who work in there have been doing it for some time, and new people/visitors are taken through the process step by step (OJT). Is gowning important? Yes. More important than the gowning procedure is going to the toilet first, so you don't gown up and get in there, only to find you're busting ................ ------------------ IP: Logged |
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ISO GUY Forum Contributor Posts: 81 |
I have to laugh. I have watched employees miss the most basic things when they gown up i.e. wash hands first. You say would you want to hire someone who needs a procedure to follow on gown-up. Well I am in no way putting these employees down, but i do not think you are going to find rocket scientest to do the job these people are doing. They are not paid very well ( I think they make about $8/hour) I do not belive just because we have the procedure that it must be right, but I do step back and ask myself why did they put this in place in the first place?? Then look at past history and see maybe there was a problem. Yes the employees have OJT as you like to say, but there is also a very high turn over rate. I personaly feel much more comfortable with the controlled sign hanging reminding people step by step on how to gown up. I also know that our customers feel much more comfortable with it this way also, and you know what they say "The Customer is Always Right". IP: Logged |
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barb butrym Forum Contributor Posts: 637 |
DoD auditors/mil specs sometimes require a documented procedure.....or at least did at one time, which is why they exist...probably. IP: Logged |
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