20 replies to this topic

[gcse-fhp]

"Show me where that requirement is in the standard"

Nothing is right about this challenge. Do you see why?

Alright then, let me start things off about why it is a totally wrong challenge:

•The likely attitude behind the challenge is wrong – it is arrogant and antagonistic.

•The challenge reveals a shameful and distracting reality - some auditors cannot differentiate between personal opinions and facts.

•The reason or presumed justification for the challenge is regrettable – Standards purport to be complete when they are not.

•The focus of the challenge is wrong – it focuses on the standard and/or the auditor’s interpretation of the standard instead of the issue at hand.

[Ken]

http://www.ifsqn.com...t&f=130&t=18537

I must admit to being guilty of this although I may not use the same words. My view is that auditors are there to determine conformity to a specific standard and through this process may identify possibly areas of non conformity. Auditors can only raise a non conformance if the issue is within the scope of the standard. I do have a problem when an auditor tries to raise a non conformity against something which isn't in the standard hence 'Can you show me where this requirement is in the standard'. The audit should focus on conformity to the standard as that is what the auditor is there to do. I do challenge non conformities where relevant but also readily accept them if there is non conformity against the standard - agreement of non conformity is an important part of the audit process and the closing meeting.

[RMAV]

There should be room for healthy debate without it becoming personal or emotional. Many times have two persons disagreed on a given clause and how that clause is addressed. Further, wherever there is law, regulation, or in this case, a standard, there is a faction of legalism. Ultimately, one must cut through all the opinion and return to:

What does the standard say?
What is the intent of the standard?
How does this issue affect the product/customer?

If you let legalism have its way, you may end up spending $2MM resurfacing the floors of a warehouse where there is no risk to an enclosed product.

[gcse-fhp]

Hello Ken and RMAV,

Thank you for your contributions. You made very good points that both auditors and audited parties should keep in mind. The three key questions listed by RMAV are of particular importance in this regard.

All parties must focus on why audits are being conducted in the first place. Audits are not for “GOT YA” purposes and they are not just for seeking “PASS” grades with infused intimidation, antagonistic, distracting or enticement tactics.

Thanks again for joining the conversation!

Regards,

Gcse-fhp

Edited by gcse-fhp, 04 May 2012 - 12:56 PM.

[GMO]

I disagree.

I think it could be worded better but an auditor cannot raise a non conformance which is not part of a standard IMO, otherwise how can they expect you to have known in advance that you should put something in place?

Now I don't expect every little detail to be written down but I do expect something related to the non conformity to be there.

I remember when I last did some auditing training, our trainer (from Campden BRI, a very well respected food research and training organisation) was very clear when they said "you must relate each non conformance to the relevant part of the standard you are auditing against." IMO it's good auditing practice anyway. Not only does it force you out of that mindset of having 'pet hates' but it also protects you as an auditor from the challenge that will inevitably come back.

For example, in a previous workplace we had a non conformance on BRC because the crisis team list with contact details was in a separate document to the crisis procedure. This was for practical reasons so we could update the team without retraining everyone. The document was referenced within the crisis procedure and hard copies were held together. This was raised as a non conformance even though within BRC 5 there was nothing which precluded you from doing this. This was then specifically identified as acceptable in BRC 6. Therefore, IMO the auditor in this case did make a mistake (and we would have argued harder but we'd only got two minors.)

Auditors are people and so are prone to making mistakes. They're not perfect. I don't think there is anything wrong with challenging things sometimes as some auditors do seem to find it difficult to separate "ideal best practice" from "meeting the standard".

[gcse-fhp]

Hello GMO,

I understand what you are saying. You have spoken as to be expected given the current universally adopted model for auditing. I happen to believe that the current model (irrespective of the standard in view) is riddled with such issues as we are now discussing and more.

So to keep things a bit simpler, do you disagree or agree with any of these points?

The likely attitude behind the challenge is wrong – it is arrogant and antagonistic.

The challenge reveals a shameful and distracting reality - some auditors cannot differentiate between personal opinions and facts.

The reason or presumed justification for the challenge is regrettable – Standards purport to be complete when they are not.

The focus of the challenge is wrong – it focuses on the standard and/or the auditor’s interpretation of the standard instead of the issue at hand.

Regards,
Gcse-fhp

Edited by gcse-fhp, 04 May 2012 - 03:38 PM.

[GMO]

I agree the wording of the challenge is wrong. Is it arrogant? Maybe. Is it antagonistic? Well it could be argued raising something outside of standards is both arrogant and antagonistic...

I'm not sure why you insist upon the slightly distracting wording. I'm not sure I'd use the words "shameful and distracting" but it is true that some auditors cannot differentiate opinion from non conformity.

Standards are there for just that to be a "standard" so that audits are fair. Of course they're never 100% complete. I don't think that matters but I also think auditors should be largely held to the standards.

Your last point depends on the issue. Take my example, there was no food safety nor quality risk to our actions but it was still raised. I agree with your point if a food safety risk is raised which is outside the scope then it should be addressed (whether they agree on it as a non conformance or not) BUT it is really important to keep to the general feel of the standard to ensure that it is a genuine concern. I would say it's very rare nowadays to have a genuine pressing food safety concern which is outside the scope of one of the GFSI standards. I'm not saying people should quibble over semantics either. I don't expect every non conformity to be spelled out to me.

[gcse-fhp]

I concede. I could say "disappointing" in place of "shameful". In any case, I will always chastise myself as an auditor, or any other auditor for that matter, wherever judgments are based on opinions instead of verifiable facts.

[D-D]

I would just say something like, "Er...sorry for being a bit dim but in order to respond appropriately to your concern could you please tell me which specific clause we are talking about so I can identify our information that relates to it?". It's the same question.

[gcse-fhp]

Hi D-D,

You are correct. It is the same question but phrased more diplomatically. As such, the focus is still not what it should be. Irrespective of whether or not the standard explicitly says anything about the issue in question, the focus should be on the issue.

What needs to be done is the assessment of the actual concern of risk associated with what the auditor has identified as an issue. A good and collaborative assessment that is free of personal opinions will reveal whether or not the issue in question poses a real concern or risk that warrants remedial action. I say this because it is possible to find a real issue during an audit for which the standard in use does not have an explicit clause. In short, the validity of an issue does not depend on whether or not an audit standard mentions it. The validity lies in the reality that the issue can actually cause or lead to some sort of harm or loss (to a consumer or even the operation/business).

An undue focus on whether or not the standard has a related clause detracts from the expediency of the needed assessment in such instances. Any time spent on searching through the standard is essentially wasted. I say this because both the auditor and the audited party should already have been familiar enough with the standard to know if there is a covering clause or not.

That said, I thank you for your input.

Regards,
Gcse-fhp

Edited by gcse-fhp, 10 May 2012 - 03:48 AM.

[zue_rais]

try be more open then by tactfully requesting question/s posed specifically

[D-D]

Er...sorry for being a bit dim but...

...I am now a bit confused what this thread was about. Are you saying the auditor may raise a concern about something that is not in the standard? If so, are they going to give a non conformance about that and against which clause...?

[D-D]

(deleted due to duplication)

Edited by D-D, 10 May 2012 - 07:36 AM.

[GMO]

...I am now a bit confused what this thread was about. Are you saying the auditor may raise a concern about something that is not in the standard? If so, are they going to give a non conformance about that and against which clause...?

I think that is exactly what this thread is about.

Personally I would be shocked if any GFSI had a genuine food safety issue which was not addressed anywhere, even obliquely within the standard. Audits are no place for 'opinion', they are places for fact. I agree that issues outside the scope should be discussed but to raise them as a non conformance is then unfair. A standard ensures consistency. The assumption of this question is that audits are only there to improve standards; that is part of the aim but not the whole deal. Audits are also there for benchmarking.

[gcse-fhp]

In brief, the salient point of the initial post is getting to the real "core of the matter" with audits. They are opportunities for identifying anything that undermines the effectiveness of programs that are implemented to ensure the safety and satisfaction of consumers.
Essentially, audits are to ensure consumers are safe and satisfied. Anything else is a side interest and somewhat insignificant. This may be shocking for some to read.
Standards are helpful guides but they are not the absolute arbiters of this core focus, nor are they absolutely complete in ensuring that the true objectives of audits are met. It is possible to discover things that are not addressed in the standard being used during an audit.
The issues of fairness of non-conformances raised and the need to benchmark are legitimate in the current model for audits, auditing, the reporting of audits, certifications, etc. However, these essentially detract from the real core focus that audits must have.

Edited by gcse-fhp, 10 May 2012 - 12:14 PM.

[GMO]

In brief, the salient point of the initial post is getting to the real "core of the matter" with audits. They are opportunities for identifying anything that undermines the effectiveness of programs that are implemented to ensure the safety and satisfaction of consumers.
Essentially, audits are to ensure consumers are safe and satisfied. Anything else is a side interest and somewhat insignificant. This may be shocking for some to read.
Standards are helpful guides but they are not the absolute arbiters of this core focus, nor are they absolutely complete in ensuring that the true objectives of audits are met. It is possible to discover things that are not addressed in the standard being used during an audit.
The issues of fairness of non-conformances raised and the need to benchmark are legitimate in the current model for audits, auditing, the reporting of audits, certifications, etc. However, these essentially detract from the real core focus that audits must have.

Yes but if you allow carte blanche, you alienate your customers. I agree with your points for internal auditing, but to say that anything else is insignficant is, IMO naive.


To be honest, you've put forward your rather entrenched position (which is in conflict from training I have received from food safety professionals at Campden for example) and I see your point but it is a point which will not be shared by the majority in the food industry. Food safety and quality does not work in isolation from operations, finance, the politics of it. Being a "this is wrong therefore it's a non conformance" irrespective of the standard is a sure fire way of not improving standards IMO. Being a perceived 'picky' auditor doesn't help your message be heard.

[gcse-fhp]

[quotename='GMO'timestamp='1338443779' post='54287']
Yes but if you allow carte blanche, you alienate your customers. I agree with your points for internal auditing, but to saythat anything else is insignificant is,IMO naive.
To be honest, you've put forward your rather entrenched position (which is inconflict from training I have receivedfrom food safety professionals at Campden for example) and I see your point but it is a point which will not be sharedby the majority in the food industry.Food safety and quality does not work in isolation from operations, finance, the politics of it. Being a"this is wrong therefore it's a nonconformance" irrespective of the standard is a sure fire way of not improving standards IMO.Being a perceived 'picky' auditor doesn'thelp your message be heard.
[/quote]
I see that I predicted correctly when I said “This may be shocking for some to read.”I also see that I left out some key words that may further explain my so-called entrenched position.So let me re-sate that:
“Essentially, FOOD AND PRODUCT SAFETY AND QUALITY audits are to ensure consumers are safe and satisfied. Anything else is a side interest and somewhat insignificant.”

Let me also try to address some of your points specifically:

[quotename='GMO' timestamp='1338443779' post='54287']
Yes but if you allow carte blanche, you alienate your customers. [/quote]

Who are the customers that you have in mind? Are these the CONSUMERS?

[quotename='GMO' timestamp='1338443779' post='54287'] I agree with your points for internal auditing, but to say thatanything else is insignificant is, IMO naive.[/quote]

The purpose of product safety and quality audits is to protect the consumer. Unless you disagree with this, I still hold that anything else (meaning anything else that has nothing to do with consumer protection in the matter of product safety and quality auditing) is a side interest and somewhat insignificant.
[quote name='GMO' timestamp='1338443779' post='54287']
To be honest, you've put forward your rather entrenched position (which is inconflict from training I have receivedfrom food safety professionals at Campden for example) and I see your point but it is a point which will not be sharedby the majority in the foodindustry.[/quote]

If you see my point, why is it not shared by the majority of industry ? However, I know what you mean and I have posted to draw all of us (the industry) back re-assess why we are conducting product safety and quality audits in the first place. I think many things that do not align with the core intent of these audits have crept in and blinded us almost to the point of being enchanted by them. We (much of the industry) have become fanatical adherents to the religion of: “It is how we have always done things and many people are doing it, therefore it is right”.

[quotename='GMO' timestamp='1338443779' post='54287']Food safety and quality does not work in isolation from operations, finance, the politics of it. Being a "this is wrong therefore it's a non conformance"irrespective of the standard is a surefire way of not improving standards IMO.[/quote]
Regarding the point about food safety and quality not working in isolation of operations and finance, these two aspects(operations and finance) meet the criterion of being relevant in consumer protection. All operations that deliver products to consumers must be designed to ensure consumer safety and satisfaction. Operations that are not so designed will fail product safety and quality audits that have the right focus of consumer safety and satisfaction. Operations must also be properly financed in order to effectively ensure consumer safety and satisfaction.

As for politics and political games, these are completely dispensable and should in fact be completely abandoned in the arena of food/product safety and quality auditing.

[quotename='GMO' timestamp='1338443779' post='54287']Being a perceived 'picky' auditor doesn't help yourmessage be heard.
[/quote]
I agree. A “picky” product safety and quality auditor who is blindly picky about things that do not necessarily contribute to the safety and satisfaction of the consumer will incur my admonition in the same way that a lenient auditor who ignores things that could harm the consumer will incur my admonition. Did you know that many food safety audit standards these days are by nature picky as well? By the way, how did you know that I am an auditor? Are you also an auditor?

Here is another statement for you to challenge:
The consumer must be protected at all costs. This is not to be done only when it is profitable to the industry or only when it is politically prudent.

Edited by gcse-fhp, 31 May 2012 - 01:59 PM.

[GMO]

But the customer is protected by decent standards.


Ok, tell me then, give me an example of a potential non conformance which is not covered by, issue 6 of BRC which could cause a food safety issue.

[GMO]

(I'm not all that easily shocked btw and haven't been in this case. If anything, the approach you state is taken by a lot of auditors which then end up in a fight not a co-operation.)

[gcse-fhp]

But the customer is protected by decent standards.


Ok, tell me then, give me an example of a potential non conformance which is not covered by, issue 6 of BRC which could cause a food safety issue.

Your assertion and challenge reflect your conviction that the BRC Issue 6 is a complete and fail safe standard for assuring consumer protection. I beg to differ. First of all, the BRC Audit, irrespective of any version, in fact, any external or internal audit for that matter is an incomplete compliance monitoring and enforcement system by virtue of being insufficiently frequent and ubiquitous.

Some EXAMPLES of things that the BRCissue 6 standard audit does not permit the auditor to raise non-conformities againstare:

• Suspicious metal detector records where numerous false trigger bags were checked with no metal pieces found. So other subsequent triggering bags were let go without being checked but the records showed “all triggering bags were checked.” The auditor was not there and can only suspect – a non-conformance cannot be raised against “mere suspicion” .
• Incomplete consumer complaint records that appear complete because either by design or negligence some complaints were simply not recorded.

Icould not post a longer version of this response because the IFSQN postingsystem appeared to be joining words together that is making the editing of long posts tedious. If this answer is not sufficient, please let me know and I will provide youwith a link (privately) for you to view a longer version elsewhere.

Edited by gcse-fhp, 03 June 2012 - 04:04 AM.

[gcse-fhp]

(I'm not all that easily shocked btw and haven't been in this case. If anything, the approach you state is taken by a lot of auditors which then end up in a fight not a co-operation.)

You are still placing the auditor and the audited parties on opposite sides of the table. Hence your fight predictions. I am calling for auditors and audited parties to work on the same side of the table. There can only be collaboration and cooperation in such an atmosphere irrespective of the issues discussed.

Edited by gcse-fhp, 03 June 2012 - 04:02 AM.