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Process Startup Only items in a Control Plan

outdoorsNW

Quite Involved in Discussions
#1
In a control plan, how would you handle start up items such as chemicals are only added when a new tank is made up and are never checked or added again?

For instance, we seed new tanks with chemicals that are deposited during the process, so a new tank performs the same as a used tank. After new bath make up, running product easily maintains the minimum levels needed, so we do not check again.

Evaporation, oxidation, etc. has no significant effect on the startup chemical.

We do check other chemicals in the tank. One of the other chemicals in the tank would go out of spec before the startup chemical.

Although generally not considered a good practice, in this case, would you put “none” in the control method and reaction plan columns?

Tom
 
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Helmut Jilling

Auditor / Consultant
#2
In a control plan, how would you handle start up items such as chemicals are only added when a new tank is made up and are never checked or added again?

For instance, we seed new tanks with chemicals that are deposited during the process, so a new tank performs the same as a used tank. After new bath make up, running product easily maintains the minimum levels needed, so we do not check again.

Evaporation, oxidation, etc. has no significant effect on the startup chemical.

We do check other chemicals in the tank. One of the other chemicals in the tank would go out of spec before the startup chemical.

Although generally not considered a good practice, in this case, would you put ?none? in the control method and reaction plan columns?

Tom
What you are describing is very unique and unusual, but it could be valid. I would ask you what evidence you have to demonstrate your claims are true, and would expect some data, or objective evidence to support it. I would also look at internal and external issues and evidence to see if it was an issue. Maybe ask relevant personnel like operators or maintenance or process techs.
 
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