22 replies to this topic

[rotiboy1002]

During BRC audit, if the auditor ask me something that I am not sure, can I refer to the policy/SOP before answering the question?

[Simon]

Of course you can 100%. The only caveat is if you were doing it all of the time during the audit and clearly did not understand the system then a doubt about your competence to manage the system would be raised; especially if your were the designated manager. Further there may be a doubt about the realization of the food safety management system - as if it is mature and well implemented you should have a very god idea about the policies, procedures, systems, rules that are in place.

The odd check here and there is completely normal.

Regards,
Simon

[rotiboy1002]

Is that applicable to employees working on the line? Can they have a cheat sheet? Will that be considered as a non-conformance?

[mind over matter]

During BRC audit, if the auditor ask me something that I am not sure, can I refer to the policy/SOP before answering the question?

Yes, use them as reference. It's the same with all standards, not just BRC.

[mind over matter]

Is that applicable to employees working on the line?

You wrote your documented system for your company...for the employees' reference, use them as reference. Everyone should be aware of it and knows where to find it if they want to review it, etc.

Can they have a cheat sheet? Will that be considered as a non-conformance?

What do you mean by a cheat sheet?

[rotiboy1002]

What do you mean by a cheat sheet?

A list of questions and answers that can be expect during the audit.

[mind over matter]

A list of questions and answers that can be expect during the audit.

I don't see any problem with that. Tip: If they (employees) don't understand the question, say so. If they don't know the answer to a particular question off the top of their heads, they can refer the auditor to someone who probably does know the answer (e.g. supervisior, department manager) or to a document that has the answer.

[Madam A. D-tor]

Is that applicable to employees working on the line? Can they have a cheat sheet? Will that be considered as a non-conformance?

Dear Rotiboy,

I would not appreciate if I find out during an audit, that workers were prepared for an audit with such a FAQ-during-audit-list and wearing this with them.

During an audit tour, workers are asked questions relating to the job they are doing. Some examples:
- Can you tell me what you are doing?
- What are you checking for? What are the limits? (=when is the product still good?) What do you do if the limits are exceeded?
- How do you know how to install the machine?
- Can you demonstrated me how you conduct a metal detector test/ check the temperature/ check/clean the filters/ conduct the incoming good inspection?
- Are there any hygiene rules you need to apply? Can you tell me what is amongst others in these rules?
- Are you involved in cleaning? If yes, how do you know what to clean and how?

As Simon said, it is normally to refer to a documented procedure/SOP/scheme if relevant. As you see above, the things that will be asked to the workers inline are things, that they need to know to do a proper job. Some forms, instructions, will be already available on the working floor and it very good if people refers to them (e.g. machine installation sheet, cleaning scheme). It is however not positive if they are going to check everything in the documents. Especially when these are things, that in the auditor’s eyes, should be known by the worker. E.g. A man is checking product temperature of heated products, which is a CCP. If asked what are the limits, he kindly takes me to the office and tell me that the limits are written in this instruction. It is good that there is an instruction (there should be one) but from a person checking the temperature at the moment I ask the question, I expect that he know what he is checking for. The same for hygiene rules: workers should know the most important things like hand washing, eating, drinking, chewing gum, smoking, glove procedures (if available), jewellery, hairnets, etc.



I expect that you are preparing for your first audit. When is the audit planned?

If you feel unsure because you are unfamiliar with the audit questions, you can (perhaps, if there is still time) plan a prè-audit. Most CBs provide the service of such an audit. Also consultants can do such a prè-audit. It will get you and your company familiar with auditing.



There is really no need for a cheat-list. Workers only need to know there job. As is what day do every day.

[mind over matter]

Dear Rotiboy,

I would not appreciate if I find out during an audit, that workers were prepared for an audit with such a FAQ-during-audit-list and wearing this with them.

During an audit tour, workers are asked questions relating to the job they are doing. Some examples:
- Can you tell me what you are doing?
- What are you checking for? What are the limits? (=when is the product still good?) What do you do if the limits are exceeded?
- How do you know how to install the machine?
- Can you demonstrated me how you conduct a metal detector test/ check the temperature/ check/clean the filters/ conduct the incoming good inspection?
- Are there any hygiene rules you need to apply? Can you tell me what is amongst others in these rules?
- Are you involved in cleaning? If yes, how do you know what to clean and how?

As Simon said, it is normally to refer to a documented procedure/SOP/scheme if relevant. As you see above, the things that will be asked to the workers inline are things, that they need to know to do a proper job. Some forms, instructions, will be already available on the working floor and it very good if people refers to them (e.g. machine installation sheet, cleaning scheme). It is however not positive if they are going to check everything in the documents. Especially when these are things, that in the auditor’s eyes, should be known by the worker. E.g. A man is checking product temperature of heated products, which is a CCP. If asked what are the limits, he kindly takes me to the office and tell me that the limits are written in this instruction. It is good that there is an instruction (there should be one) but from a person checking the temperature at the moment I ask the question, I expect that he know what he is checking for. The same for hygiene rules: workers should know the most important things like hand washing, eating, drinking, chewing gum, smoking, glove procedures (if available), jewellery, hairnets, etc.



I expect that you are preparing for your first audit. When is the audit planned?

If you feel unsure because you are unfamiliar with the audit questions, you can (perhaps, if there is still time) plan a prè-audit. Most CBs provide the service of such an audit. Also consultants can do such a prè-audit. It will get you and your company familiar with auditing.



There is really no need for a cheat-list. Workers only need to know there job. As is what day do every day.

I agree with you to some extent but memorization is not a requirement, is it? You also need to consider whether the worker is a new hire or old employee, whether the SOP/policy was newly written/revised or not. Besides, specs, etc can change......

Auditor should expect that current documents/guides are easily and readily available where and when needed, not memorize.

Mind you I can't even memorize my own mobile numbers. And I sometimes forget the birthday of my wife.

Edited by mind over matter, 24 October 2011 - 06:51 PM.

[Madam A. D-tor]

I agree with you to some extent but memorization is not a requirement, is it? You also need to consider whether the worker is a new hire or old employee, whether the SOP/policy was newly written/revised or not. Besides, specs, etc can change......

Auditor should expect that current documents/guides are easily and readily available where and when needed, not memorize.

Mind you I can't even memorize my own mobile numbers. And I sometimes forget the birthday of my wife.

Of course we all forget somethings sometimes.
But this is not about memorisation. This is about your daily job. This is about food safety. If a worker can not tell what he is doing.... think of the risks for the company. If the worker uses documents/guides/specifications/instructions it is fine. The questions then will lead to this documents.
But it is not good to make a list, with questions the auditor may ask. It makes people nervous (at least more nervous then they should be). If the question is not on their list, they do not know what to answer. Workers should just tell what they do every day.

[Madam A. D-tor]

Mind you I can't even memorize my own mobile numbers. And I sometimes forget the birthday of my wife.

Just for illustration:
- Auditor is not asking for your phone number, but if you know how to use your phone.
- You do not need to know the exact date of your wifes birthday (you can put that in your calendar), but you need to know what your wife is expecting from you on that day.
(By the way, she might expect, that you forget her real age )

[mind over matter]

Of course we all forget somethings sometimes.
But this is not about memorisation. This is about your daily job. This is about food safety. If a worker can not tell what he is doing.... think of the risks for the company. If the worker uses documents/guides/specifications/instructions it is fine. The questions then will lead to this documents.
But it is not good to make a list, with questions the auditor may ask. It makes people nervous (at least more nervous then they should be). If the question is not on their list, they do not know what to answer. Workers should just tell what they do every day.

What is the purpose of creating procedures, instructions etc? Do you think you still need those if workers can remember everything? I don't see anything wrong with cheat list as long as it matched with the current process document and actual practice.

*Edit: Could you please cite the deviated clause under BRC?

Edited by mind over matter, 24 October 2011 - 08:04 PM.

[mind over matter]

Just for illustration:
- Auditor is not asking for your phone number, but if you know how to use your phone.
- You do not need to know the exact date of your wifes birthday (you can put that in your calendar), but you need to know what your wife is expecting from you on that day.
(By the way, she might expect, that you forget her real age )

I was only joking on that part.

[Madam A. D-tor]

What is the purpose of creating procedures, instructions etc? Do you think you still need those if workers can remember everything? I don't see anything wrong with cheat list as long as it matched with the current process document and actual practice.

*Edit: Could you please cite the deviated clause under BRC?

Dear MoM,

Please read again my previous posts. Again: it is not about memorisation, it is about daily jobs. A worker need to know what he is doing. If procedures/instructions are required in his daily job it is fine, if he/she shows them. But, he/she must answer the questions frankly.

scene:
auditor: "Hi, I am A. D-Tor, what is your name?"
Worker, checks his cheat sheet first: "eh, I do not know, this question is not on my list".
auditor: "what are you doing right now?"
Worker: "according this cheat sheet, I am a worker for the largest producer of ..."
auditor: "what are your responsibilities (meaning wat is your function/job)?"
worker, (relieved, cause this question is on his sheet): "I am responsible for good hygiene and good quality of the product".
auditor: "Ok, I see that you conduct the metal detector checks. Can you demonstrate me, how you do this?"
worker walks to production office to take a copy of the metal detecor instruction and gives it to the auditor.
auditor: "ehm, OK, Can you please demonstrate how you normally do the test?"
worker starts reading out loud the instruction and doing it step by step as is described.

This worker is performing this checks daily, probably a few times a day. He/she does not need the documented instruction. He/she does not need a cheat sheet.

Several requirements are involved, but I did never indicate that this is a NC. I wrote that I would not appreciate such thing, as I illustrated in the case above.
Again, showing documents is a good thing, it is good if workers know were to find them, and what to find in them, it is good if they are used in daily business and hang in production area. I just do not like the idea of a cheat sheet with the most common questions an auditor may ask. It is not necessarry and only cost a lot of time in preparing this sheets. The time for preparing an audit can be used on a much better way. (e.g. training of workers, prè-audit, gap analyses, internal audits)

BRC, issue 5, requirements involved:
1.1 resources;
3.2 requirements of the standards to be implemented;
3.3.4 instructions to be communicated to relevant staff;
5.2.1.7 training allergens;
6.1.3 proces monitoring by trained staff;
7.1 (fundamental) workers should be demonstrable competent;
7.1.1 workers are trained prior to commencing to work;
7.1.2 persons engaged in CCP monitoring should be trained;
7.1.5 review compenties of staff;
7.3 personal hygiene rules to be adopted by personnel;
and others.

[Madam A. D-tor]

Just for illustration:
- Auditor is not asking for your phone number, but if you know how to use your phone.
- You do not need to know the exact date of your wifes birthday (you can put that in your calendar), but you need to know what your wife is expecting from you on that day.
(By the way, she might expect, that you forget her real age )

I was only joking on that part.

I know that it was a joke, but the reaction is serious:
There is no need to remember a phone number, but you should know how to use it.
If you should need a cheat sheet to tell me how to use your phone (just the daily things: answering, phoning) I would rise an eyebrow.

[rotiboy1002]

I think I can get something out of what you two discussed here. I can see why Q&A list is not a good idea now. Hard memorization of the policies & procedures is definitely not a requirement. But basic understanding of the scope of job/task is important to show that the employee was trained for the position. However, if the auditor ask them the detail procedures and they can't answer, I will prefer them to refer to the SOP before answering rather than simply say something or say he/she doesn't know the answer.

Our audit is in 2 weeks time. We had a consultant but he doesn't seem checking thoroughly while doing the GAP audit. I am just interested to get more point of view instead of having everything from one person. I think that's the beauty of this forum.

[GMO]

I agree that a memorisation list of Q&As isn't a good idea, but, there is nothing wrong IMO with putting a 1 page summary on, say a metal detector telling you the critical limits, test frequency and what to do if there's a failure. I wouldn't suggest this just for auditors though, I have found it helps if you have a failure in 'real life'. People forget and so it's good to have a memory jogger (and also I've had senior management asking team members to disobey rules. I find it then gives them the confidence to say "no, look it says here I can't run a line without checking the metal detector" etc.)

[mind over matter]

Dear MoM,

Please read again my previous posts. Again: it is not about memorisation, it is about daily jobs. A worker need to know what he is doing. If procedures/instructions are required in his daily job it is fine, if he/she shows them. But, he/she must answer the questions frankly.

scene:
auditor: "Hi, I am A. D-Tor, what is your name?"
Worker, checks his cheat sheet first: "eh, I do not know, this question is not on my list".
auditor: "what are you doing right now?"
Worker: "according this cheat sheet, I am a worker for the largest producer of ..."
auditor: "what are your responsibilities (meaning wat is your function/job)?"
worker, (relieved, cause this question is on his sheet): "I am responsible for good hygiene and good quality of the product".
auditor: "Ok, I see that you conduct the metal detector checks. Can you demonstrate me, how you do this?"
worker walks to production office to take a copy of the metal detecor instruction and gives it to the auditor.
auditor: "ehm, OK, Can you please demonstrate how you normally do the test?"
worker starts reading out loud the instruction and doing it step by step as is described.

This illustration is an exaggeration. Seriously speaking, my memory is not that good and I depend on notes and references. This should not be misinterpreted as lack of knowledge, incompetent or should be termed as unawareness.

This worker is performing this checks daily, probably a few times a day. He/she does not need the documented instruction. He/she does not need a cheat sheet.

I beg to differ. If I would be the auditor I would really appreciate SOPs, work instructions, etc. within arm's length of workers/users, rather than on a shelf down the hall, upstairs. It was there to be used, and that is just such a use.

Several requirements are involved, but I did never indicate that this is a NC. I wrote that I would not appreciate such thing, as I illustrated in the case above.
Again, showing documents is a good thing, it is good if workers know were to find them, and what to find in them, it is good if they are used in daily business and hang in production area. I just do not like the idea of a cheat sheet with the most common questions an auditor may ask. It is not necessarry and only cost a lot of time in preparing this sheets. The time for preparing an audit can be used on a much better way. (e.g. training of workers, prè-audit, gap analyses, internal audits)

BRC, issue 5, requirements involved:
1.1 resources;
3.2 requirements of the standards to be implemented;
3.3.4 instructions to be communicated to relevant staff;
5.2.1.7 training allergens;
6.1.3 proces monitoring by trained staff;
7.1 (fundamental) workers should be demonstrable competent;
7.1.1 workers are trained prior to commencing to work;
7.1.2 persons engaged in CCP monitoring should be trained;
7.1.5 review compenties of staff;
7.3 personal hygiene rules to be adopted by personnel;
and others.

Clarification - I am with you that employees are expected to know there job, what they do every day etc. And I agree with you that this particular case is not an NC because there is no rule against saying to an auditor, "Let me check the document to make sure I get it exactly right" pulling out the policy or SOP and reading it to him/her. I have an office mate (auditee) who was so nervous during an audit (not sure if her first time or due to previous bad experiences) that she literally couldn't remember certain details. But, in fairness that's rare, and it's also very obvious. So, that's the reason why I suggested in my earlier post that if they don't know the answer to a particular question, they can refer the auditor to someone who probably does know the answer (e.g. supervisior, department manager) or to a document that has the answer.

Edited by mind over matter, 25 October 2011 - 08:36 AM.

[faisal rafique]

Professional Auditor are there to see compliance, mostly sample based he may ask for employees about a critical thing to see is system is working or not. He may not be intrested in questionnaire, yes you can refer to any procedure or SOP.

[Madam A. D-tor]

I agree that a memorisation list of Q&As isn't a good idea, but, there is nothing wrong IMO with putting a 1 page summary on, say a metal detector telling you the critical limits, test frequency and what to do if there's a failure. I wouldn't suggest this just for auditors though, I have found it helps if you have a failure in 'real life'. People forget and so it's good to have a memory jogger (and also I've had senior management asking team members to disobey rules. I find it then gives them the confidence to say "no, look it says here I can't run a line without checking the metal detector" etc.)

Dear GMO,
I agree, there is nothing wrong with one point lessons, reminders or instructions on walls or equipment (as long as the papers do not consist a contamination risk)

I think I can get something out of what you two discussed here. I can see why Q&A list is not a good idea now. Hard memorization of the policies & procedures is definitely not a requirement. But basic understanding of the scope of job/task is important to show that the employee was trained for the position. However, if the auditor ask them the detail procedures and they can't answer, I will prefer them to refer to the SOP before answering rather than simply say something or say he/she doesn't know the answer.

Our audit is in 2 weeks time. We had a consultant but he doesn't seem checking thoroughly while doing the GAP audit. I am just interested to get more point of view instead of having everything from one person. I think that's the beauty of this forum.

Dear Rotiboy,
I am glad that this discussion is helping you.
It is OK if they refer to documents (SOP, procedures, instructions, memo's, emails, etc.) if details are asked for.
I can only tell from my own experience. As an auditor I hardly ever ask for such details. As audited QA manager, never had an auditor asking workers inline for such details.

I wish you all the best on your forthcoming audit.
If there are any more questions, feel free to ask.

This illustration is an exaggeration. Seriously speaking, my memory is not that good and I depend on notes and references. This should not be misinterpreted as lack of knowledge, incompetent or should be termed as unawareness.


I beg to differ. If I would be the auditor I would really appreciate SOPs, work instructions, etc. within arm's length of workers/users, rather than on a shelf down the hall, upstairs. It was there to be used, and that is just such a use.


Clarification - I am with you that employees are expected to know there job, what they do every day etc. And I agree with you that this particular case is not an NC because there is no rule against saying to an auditor, "Let me check the document to make sure I get it exactly right" pulling out the policy or SOP and reading it to him/her. I have an office mate (auditee) who was so nervous during an audit (not sure if her first time or due to previous bad experiences) that she literally couldn't remember certain details. But, in fairness that's rare, and it's also very obvious. So, that's the reason why I suggested in my earlier post that if they don't know the answer to a particular question, they can refer the auditor to someone who probably does know the answer (e.g. supervisior, department manager) or to a document that has the answer.

Dear MoM,
In generally speaking we do agree with eachother.
I do not think there is anything wrong with reference to SOP, procedures, instructions, reference documents, etc. esspecially not, if these are within arm.s length of the workers.
Notes and referene are fine and OK to use. I have no problems with that. And it is as you said: workers should know their jobs.
Also Ok to refer to other people if the question is no part of their job. Personnally I prefer to interview the workers in stead of department managers.

Amd yes, sometimes people get so nervous they do not know their own name anymore. I used to work with a guy who could not find any document when getting nervous during an audit. The first time I thought that he tried to delay the audit. Such things happen and an auditor has to deal with it. (Mostly, by asking just simple questions in the field of the worker and making small jokes to get them comfortable)

[Ron Gardner]

I kind of disagree with this to a point. I have had auditors ask floor production people what HACCP/GMP means and what are the principles. 

I give all employees a card they can keep on their person with basic HACCP/GMP knowledge. If the auditor was just asking? do you wash your hands? or Do you pick things up off the floor? Id see no reason for additional information. But when Auditors ask questions like. name the three Hazards found in HACCP and give me an example of one of those Hazards?  Most employees are not going to know this. I would say most Production Managers/Supervisors don't know this.

I don't see a problem with an employees being able to use helper cards for the tough questions. Yes I agree employees should know their job and the SOPs related to that job. But I disagree that an employee should be held to the standards of a Manager.  In todays world several employees haven't finished high school, or cant even read, or they don't know the common language. 

[Miss Frankie]

We are SQF, but I printed each element and have it in the beginning of each section of my SQF manual. So it's super easy to glance at with w/o digging for taking much time looking for it.

[Duncan]

My suggestion would be to incorporate instructions/reference materials to be used at the point of use into your quality manual, document control them and incorporate them into standard operations and not make special provisions for audits.

 

 

 Clause 3.1.2 States:

"The food safety and quality manual shall be fully implemented and the manual or relevant components shall be readily available to relevant staff."

 

I've seen sites bullet-point key aspects of their metal detection procedure and put it up as a poster right next to the metal detector, so operators can constantly refer to it.

 

 

Clause 6.1.1 states:

"Documented process specifications and work instructions/procedures shall be available for the key processes in the production of products to ensure product safety, legality and quality. The specifications/procedures as appropriate shall include:

• recipes – including identification of any allergens

• mixing instructions, speed, time

• equipment process settings

• cooking times and temperatures

• cooling times and temperatures

• labelling instructions

• coding and shelf-life marking

• any additional critical control points identified in the HACCP or food safety plan.

Process specifications shall be in accordance with the agreed finished product specification."

 

 

The inclusion of equipment process settings and reference to the HACCP plan here can be taken in conjunction with 3.1.2 so that providing instructions/reference materials to operators at the point of use is not just permitted, but required.

 

There's no limit placed on the instructional materials you can provide... Just make sure it's documented as part of your quality manual and not a special 'cheat sheet' used specifically to get through audits.

Attached Files

•  sect 3 Qualityy manual.PNG   96.85KB   0 downloads
•  process control.PNG   111.45KB   0 downloads

Edited by Duncan, 05 March 2022 - 01:42 PM.