We received an A in January of 2012 - Shortly after this audit ( the QA manager became very ill ( he was older). This is where we started to lose control of the system, due to his health, much of his responsibility to keeping up the BRC standard declined along with him. He decided to retire at the end of the year, passing the baton onto the Micro Manager ( The current QA manager). Our current manager did not see it necessary that we make up what had been missed from the previous year, several audits, annual review of the documents, senior management meetings, Review of the HACCP plan, etc....
So at our annual re certification...
We received a C in February of 2013 - because of this we were required to re-audit in 6 months to maintain certification
However in that 6 months leading up to the second audit, he spent more time fighting fires in the QA lab, (between you and me, probably because all of the systems were failing) than working on following through on the things we were sighted for in February so...
We then received another C in July of 2013. This time we were hit hard (and like I said - rightfully so) because many of the NC's were sighted in the previous audit in some way or another... concluding this monstrosity, (not to mention on the verge of losing accreditation [and therefore 90% of our customer base] I was "Promoted" to manage all audit / regulatory compliance. If we had waited 6 months we would have lost accreditation, so....
We decided to re-audit again (the third time in a single year) In October of 2013 - this meant I had 6 weeks as acting "Quality Systems Coordinator" to fix (or attempt to fix) essentially the whole system.
In October, we received only 1 minor NC. A lot of this was chalked up to an auditor that did not 100% understand our process (Aseptic beverage packaging), but if you ask me, it was because I busted my ass (And everyone else's) to get the shit we weren't doing done. We set up an internal audit program, Trained 30 internal auditors, set up a corrective action program and got it rolling, set-up a document control program and established a "gate-keeper", brought in Randolph's to train the entire management team on HACCP and PRP's, Installed new training software, Spent every weekend on GMP and Allergen training for the employees, Fired our old Pest Control company and brought on a company that knew what they were doing.... all in 6 weeks. Essentially, started over. And because of having evidence that we were committed to these changes, I believe that is why we got the grade we did. The auditor saw where we were in July and compared that to the progress we'd made since then.
Now a year later, these major programs are alive and doing well. My role is to monitor these systems and improve them where and when I can - the continuous improvement aspect. The QA manager essentially just runs the lab now. (where audit compliance and managing the lab had been only one job in previous years). My concern now is secondary programs. Its been a TON of work just to keep all of the major elements alive, so I've tackled the secondary programs through internal audits and as time allowed.. however, I know that there are still some that aren't anywhere near where they need to be. This is where my anxiety is coming from - We have a new auditor this year, and I want to be able to show that we are still committed. As a company however, I can only do what resources allow (and for me that may mean letting us fail in areas to get the resources because mgt does not understand the importance of GFSI accreditation until it is on the verge of being gone. While these will most likely only be minor NC's - i was looking for a way to mitigate some of them through documenting the plan towards compliance.
For example, Our raw material inspection process. We have a written program now, we have started to inspect materials, but due to the large (and I mean LARGE) number of raw materials and the limited amount of capable staff, we do what we can right now. I have a plan, submitted to mgt, the explains the need for more resources to really be compliant to the standard, I have a RA for the type of monitoring we are currently doing, versus maybe what we should be doing, I have a year long plan to develop this program...
But how many of these WIP programs is an auditor going to be ok with? Is having a written plan enough to dodge a NC? I guess at the end of the day, all we can do is keep working on it and take what ever the auditor gives us, but I'd sleep better at night knowing I have all of the solid evidence I need to show we are committed. Unfortunately, the manufacturing plant is owned by a Corporate Entity (that does mostly sales work) and they pull the purse strings. (we are sort of treated as a co-packer) I make my case for the importance of food safety, but usually my hands are tied until an auditor gives them the same news.
Sorry for the lengthy explanation, but Im sort of at my wit's end! What's a girl to do!?!?!
) I am starting to really dig into the gap analysis and am finding that some of our programs (majorily secondary programs, like fill weights, record completion,product inspection, identity preserved, etc.) are a WIP program.
