Of course the human element causes some variance in interpretation however, I don't think it's wise for us to second guess Caz's findings. If Caz can post details of the gaps identified we can look at them in context of the requirements of the standard.
The Auditing Company is approved under UKAS...so here's the first OH Dear!
I obviously can't give too much away, but here are some of the finer points.
The only person on site who had done any formal HACCP training was the Technical Manager. In fact he was the only member of the HACCP team!! The Last time HACCP had been reviewed was in Feb 2005.
3.1.1 A formal hazard analysis had been conducted for physical contaminations, but only in part! They had carried this out for potential glass contamination but omitted to include such items as metal swarf's and engineering debis, which was concerning as there were a number of in place knives in their equipment. no analysis was carried out for micro contamination or chemical contamination. The analysis was last reviewed in 2004!
3.5 Monitoring of critical process steps should be included in internal audits. However, they did not carry out internal audits!
4.3.1 Records - no internal auditing, no hand back records from production, no cleaning schedules, no control of sharps.
4.4.3 Work instructions had ammendments that were not dated, countersigned or communicated to supervisor.
4.6.1 No Incident reporting procedure / documentation.
4.9 no internal audits!
4.10 complaints were trended but no investigations/ close out.
4.13.4 external labs accreditation had been withrawn, but continued to be used.
5.4.5 no planned maintenance programme
5.4.11 no hand back procedure, no one could tell me if knives were checked for metal fragments after being sharpened. was just assumed that they were free from contamination.
5.5.9 No record or schedule for cleaning.
6.1.8 no control of sharps although broken blades were disposed of in a sharps container. no documented incident report.
7.3.4 Hand washing only at one entrance. rest of entrances covered by alcohol gel!
7.7.4 Controlled laundry. staff couldnt agree what PPE they'd been issued. But they all agreed that they took it home to wash!!
7.8.2 Half the staff had not done any formal basic hygiene training, and those that had, were done more than 3 years ago.
I could go on and on. As a company we are concerned that this company has BRC/IOP accreditation, and we're now formulatinfg a plan for auditing all of our packaging suppliers. Our first point of reference is to audit everyone who used this UKAS accredited company.
Id be interested to hear what packaging companies and CB's experiences are.