Clause 8.5.1 -- Is non Identification evidence of ineffective control of production

[Golfman25]

So we are looking at a non-conformance against 8.5.1 Control of production and service provision. Supporting evidence is: open containers of waste oil and good oil side-by-side with no identification (don't ask me how he knew one was waste and one good if not identified), lubricants kept by parts where one is used for parts and one for dies (not identified), liquids in water and spray bottles observed throughout production.

So the back story is we use several oils (probably 5-7) in our forming processes (metal stamping) and in our machines. Oils are ordered in bulk 55 gal drums and 5 gallon buckets. All have manufacturers information on them. As we run parts, our operators distribute said oils to their workstations via smaller containers (my guys love to recycle the plastic coffee containers) -- maybe a cup to a quart at a time. While there is no specific written identification on these containers, the operators know what it is and what it is used for as they fill the containers and use the product. In the event there could be confusion, the oil is easily identifiable via its color, viscosity, etc. and in the event it can't be distinguished can be scrapped out and fresh product used. Identification of the smaller containers is easier said than done as the oil likes to "eat" any labels, marker ink, etc. and is quickly made illegible. Oh, and the liquids in water bottles are the operators drinks.

Any thoughts? Discussion. Thanks in advance.

 

[hogheavenfarm]

So the oil is strictly for maintenance (and the water too), it has nothing to do with the product. I don't see a big issue, maybe OSHA might (unmarked containers), but thats about it. Lets see what the experts say...

 

[Randy]

OK here's what there is....Depending on location the waste oil not being labeled could or could not be an environmental violation (definitely a CAL EPA one). Both types of oil are most definitely contrary to OSHA 29CFR1910.1200 Hazard Communication Standard, Seconday containers ( your safety guy should know that and if not, get a new safety guy cause that's Basic Safety 101

Now, how the auditor fits that into 8.5.1 Control of production and service provision is dicey and grasping. There has to be a direct connection formed between the oil and whatever he was looking at, kinda like a quality auditor looking at daily inspections of forklifts.

 

[Golfman25]

OK here's what there is....Depending on location the waste oil not being labeled could or could not be an environmental violation (definitely a CAL EPA one). Both types of oil are most definitely contrary to OSHA 29CFR1910.1200 Hazard Communication Standard, Seconday containers ( your safety guy should know that and if not, get a new safety guy cause that's Basic Safety 101

Now, how the auditor fits that into 8.5.1 Control of production and service provision is dicey and grasping. There has to be a direct connection formed between the oil and whatever he was looking at, kinda like a quality auditor looking at daily inspections of forklifts.

Thanks for you input. I appreciate it. Lest we turn this into an OSHA thread, lets assume we are not dealing with Hazardous chemicals (we eliminated 95% of them years ago) or they are subject to the immediate use exception.

As for the auditor, I'm trying to figure it out as well.

 

[Randy]

lets assume we are not dealing with Hazardous chemicals

Trust me when I say by federal law even oil is considered a hazardous chemical in the workplace, as is distilled water, IPA and Simple Green.

"lets assume we are not dealing with Hazardous chemicals (we eliminated 95% of them years ago) or they are subject to the immediate use exception."

As you described them they are not for immediate use, but go ahead, whatever

 

[Golfman25]

Trust me when I say by federal law even oil is considered a hazardous chemical in the workplace, as is distilled water, IPA and Simple Green.

"lets assume we are not dealing with Hazardous chemicals (we eliminated 95% of them years ago) or they are subject to the immediate use exception."

As you described them they are not for immediate use, but go ahead, whatever

Definition: "Immediate use" means that the hazardous chemical will be under the control of and used only by the person who transfers it from a labeled container and only within the work shift in which it is transferred." That's pretty much what I described.

And I don't know, but the simple green people may disagree about applicability under Hazardous communication requirements.
https://cdn.simplegreen.com/downloads/SDS_EN-US_SimpleGreenAllPurposeCleaner.pdf
But we digress. Again, thanks for your input.

 

[mattador78]

Here the Uk under COSHH any oils in cans on a bench next to bottles of water would be a huge no no. As for the labelling i suppose if the tubs are being recycled could different oils be put in at different times causing contamination? What you could do is make a holder/holster for theses cans out of aluminium or mild steel and engrave on the holster what goes in there then each time they can just fill the can and pop it back in its slot readily identified. then just keep the MSDS sheets readily available.

 

[John Predmore]

Getting back to the OP question about ISO 8.5.1...
Many auditors have pet peeves they look for. This guy's might be the sin of unlabeled containers.
Best practice would be "the implementation of actions to prevent human error" which happens to be 8.5.1.g.

To judge whether product quality is potentially affected, you would have to assess what bad things could happen if waste oil is accidently used instead of good oil, or the wrong oil is used. You mentioned metal stamping and "one is used for parts and one is used for dies", so I would think the quality of oil matters. If there is a risk of poor product quality, then 8.5.1 requires commensurate level of control to mitigate risk. Your company gets to decide what level of risk and what level of control, subject to scrutiny of your decision by the auditor. Of course, if evidence shows product quality problems caused by mixed or expired lubrication occurred, the auditor will conclude the controls you chose are ineffective.

 

[Mike S.]

Aside from debate over what exact clause may best apply, I think the auditor has identified a problem area for you. Using old, unlabeled coffee containers to transfer oil? Unidentified spray bottles?

No offense intended but it sounds like practices used in a fast and loose garage-shop operation - or my garage.

 

[Randy]

No offense intended but it sounds like practices used in a fast and loose garage-shop operation - or my garage.

Yep, but what the heck, I've only a BS in Occupational Safety and 35+ years in the field with current specialization in Responsible Care