TIMBER PRODUCTS December 2015 Newsletter Volume: 12/08/2015

What's a 5.3.3.1?

If your inspector finds a non-conformance at your facility, he may refer to it as a "5.3.3.1".  This term comes from Section 5.3.3.1 of ALSC's Wood Packaging Enforcement Regulations which states:  

"It is the obligation of the agency to audit the wood packaging facility on a periodic basis, and the obligation of the wood packaging facility to produce a properly labeled wood packaging product. Samples of previously manufactured wood packaging products shall be inspected in accordance with the Policy as part of the agency supervision. The agency shall sample a sufficient amount of wood packaging representative of the products produced by the wood packaging facility to adequately evaluate the proficiency of the facility. When a sample of wood packaging indicates the product is not properly labeled the product shall be corrected. The agency shall verify that the product has been corrected by either removal of the quality mark or by remanufacture of the wood packaging product. The agency shall take whatever steps necessary to prevent recurrence. Each month the agency headquarters personnel shall review the performance of each wood packaging facility and take whatever action warranted. In addition, the review shall include the assessment of the agency sample results for each inspection. If the inspection results fail to meet the specified criteria, the agency shall increase inspections until such time as the results are within the specified criteria at which time the frequency of inspections may return to normal."

The section in purple explains that if the non-conforming issue "fails to meet a specified criteria" it becomes serious enough to cause the agency to increase it's visits until the facility can show that they have not only corrected the non-conforming issue but have also modified their processes to prevent the recurrence of the non-conformance.  This is the case not only for a major issue but also for multiple minor issues.  An ALSC response dated November 14, 2014 offers this explanation:

"A minor issue occurring on multiple agency inspections point to a facility where an increased visit would be expected. Similarly, a single inspection where minor excess findings occur in multiple items would also result in a need for increased visits."

"Staff Reasoning: When minor issues are noted multiple times on the agency inspections during a time frame or when multiple items in one inspection show minor excess issues, these results indicate a commitment to proper labeling and/or records may need to be addressed. In these cases, by the agency increasing visits, the importance of maintaining proper labeling of WPM and proper records is brought to the attention of the facility and fulfills the intent of the requirement."

Once the facility processes show no recurrence of the non-conformance, the 5.3.3.1 is lifted and inspections can return to their normal level of occurrence.  It is important to address a 5.3.3.1 non-conformance quickly in order to avoid ongoing and frequent agency inspections.