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Unannounced Audits – The Way Forward

Posted by Tony-C, in Food Safety Standards 30 June 2014 · 6,708 views

Unannounced audits
Unannounced and unscheduled audits are growing ever more popular in the mainstream food safety certification schemes. In March this year the new edition of the SQF Code (7.2) included a requirement for suppliers to undertake one unannounced audit within the three year certification cycle.

BRC unannounced audits are available to sites achieving top grades with two options, a single unannounced two day audit or a one day unannounced GMP audit plus a one day scheduled system audit.

The FSSC 22000 certification scheme requires announced, but unscheduled audits of certified organizations where the certification body participates in a risk based programme of office audits and announced, but unscheduled, audits of certified organizations.

The certification schemes point out that the benefit of unannounced audits is a greater confidence in the systems in place which ‘may’ influence risk rating and audit frequency.

I qualified as a Lead Assessor over 20 years ago and at that time due to our large customer base we had 1 or 2 site audits every week, which is ridiculous and why I believe acceptance of food safety certification schemes frees up huge amounts of resource in the industry which can then be used to focus on food safety and improving quality.

Unannounced audits are not new to anyone who supplies British retailers; some favor this protocol and feel that an unannounced audit gives a better picture of the systems and standards in place for normal day to day operations. To some extent this is true, I have seen from both sides attempted ‘Stage Management’ of scheduled audits where what happens on the day is not a reflection of normal operations. Usually ‘stage managed’ audits aren’t difficult to spot, when you’ve got 6 to 10 managers guiding you round you ‘smell a rat’, I’ve even had one supplier that arranged the opening meeting at a site that was 30 miles from the actual production site so that it reduced the audit time.

So there is something to be said for the format and protocol of the main food safety schemes as I believe they are raising auditing standards with clearly defined guidance on auditing, auditor competency and their food safety requirements which can only help in assuring customers and retailers alike of the value of certification to a recognized food safety certification scheme.

In the past I have had a variety of auditor types and styles that would come to visit:

Document auditor
Wants to sit in the office all day with tea and biscuits reading through every single document you have

Free lunch auditor
Wants to go out for a 2 hour slap up lunch and the day is focused on achieving this

Bin bag auditor
Wants to go round your site picking up bits and pieces which are then an indication of ‘poor sanitation’ or ‘foreign bodies’ even though they are nowhere near product areas

Pest control auditor
Is completely fixated with pest control and spends the day on the pest control procedures and looking for holes in the building

Swab you auditor
Turns up with a box of swabs and spends the day looking for something particularly nasty that they can ‘cultivate’ later

Electric cabinet auditor
Spends the day going round and opening every single electrical cabinet on site

Picky auditor
Nothing is too insignificant, writes down everything, produces a report with 200 points none of which are major or minor non-conformances

Insulting auditor
Nothing is good enough and you look a bit overweight, you should try eating less

Expert auditor
Gives you advice and opinion on everything even though you don’t want to hear it



Having said all that there have also been some excellent auditors over the years and I certainly benefitted from my audit experiences. Now I can only see standards improving generally given that more and more organizations in the food chain are requiring certification to recognized food safety certification schemes.

Next time I’ll go into how to prepare for an unannounced audit but on a final note for this blog, here are my top ten memorable audit moments:

1. ‘Diplomatic Crisis’

Government of supplier complained to the government of a company I represented because I did not approve one of their production sites following a supplier approval audit

2. ‘Faux Pas’

My pest controller tells the auditor (who unbeknown to him is an animal rights freak) that if we start seeing too many pigeons he brings his air rifle in at the weekend and shoots them

3. ‘Bat out of Hell’

A bat which was removed from site and freed returns to put in an appearance flying around in the packaging store during an audit

4. ‘Doh!’

Chart records absent from a process plant – a legal requirement

5. ‘Don’t forget we’ve got an audit today so..’

Auditor spotted note left to operator – rinse with potable water today as we have an IP audit

6. ‘Splash’

An operator stood on a milk polybottle to demonstrate how well sealed it was and the lid popped off drenching the auditor

7. ‘How low can you go?’

Supplier was filling low weights (illegal product) and their weight control system was telling them everything was fine

8. ‘Major Cock Up’

Suppliers packaging found to leak when checked on audit – on investigation packaging design was found to be wrong but several sites were in full production

9. ‘Oops – How did that happen?’

Supplier lost test piece whilst demonstrating metal detection/Metal detector failed to reject test product

10. ‘What food safety policy?!’

A Site Director was asked if he could give an overview of the food safety policy which he had authorized and signed. Dumfounded he couldn’t quote any part of the policy


If you've been involved with an unannounced audit or have a curious audit experience to share...drop us a comment below.

Also please cast your vote in our member poll...Have you experienced an Unannounced Audit?




Oh Tony , if only it were true and the unannounced scheme meant something!

 

I've subscribed (against my better judgement) to the BRC Unannounced scheme, primarily because I've been pressurised by a retailer , who also conducts an unannounced audit AND an unannounced ethical audit (from the most unethical auditor I've ever come across - only wanted to speak to the foreign nationals on site!!). this is in addition to the unannounced Tesco PIU, unannounced TSO & EHO visits, unannounced from Morrison and Lidl. This is without the other surveillance visits I have from customers. I barely get time to take time off! I'm employed as the technical Manager, and it's not right or fair to expect my compatriots to conduct an audit on my behalf because we get an unannounced when I'm off on holidays!

 

If the standards were (vaguely) the same I would help.

As an example , BRC and Morrison, retain records for 2 years. Asda retain for 6! So we retain everything for 6 (even though Asda is less than 1% of our business)

 

 

Last year I had 38 audits, not counting the BRC. and I now think the whole thing has become farcical. One week I had 3 audits on 3 consecutive days.

 

 

I agree with what you say about auditors. I think I've probably had most types too. We had 1 BRC auditor who asked me after a long lunch, what cream cakes we'd be having with our afternoon tea. I've also had auditors who have turned up at 8am, and are still there at 7pm at night. Believe it or not, I have a family, so I want to be gone by 5.30pm in order to feed them and to spend some quality time with them.

 

I've also had the insulting auditor. "are you qualified in HACCP?" ...um yes, are you??? How dare they, my boss employed me on my ability, and its up to him to decide if I have the right credentials for the job! I actually now have my certificates framed on the wall, saves my having to explain, that yes I am qualified, in a lot of things , thank you!

 

Gee Tony, you've made me rant first thing on a Monday Morning, although I have kept it short!!

 

Caz x

I nearly fell off my chair laughing about the operator standing on the bottle and drenching the auditor.  That being said.  I totally agree with Caz's rant.  I am particularly tired of the auditor(s) who feel like they alone are the only thing able to protect the consumer that we the producers are out to kill.  They are not the only the only ones who are concerned with food safety and I take pride in a safe, quality product. 

4. ‘Doh!’

Chart records absent from a process plant – a legal requirement]

 

When I was working at a yogurt plant... our state rep came in to check charts on the HTST.  He was reviewing then when he declared that there was one missing.  The QC manager called me and I grabbed the maintenance techs and floor supervisor and we start looking everywhere including inside equipment (hey you never know).  We searched for hours - including hours after I was supposed to leave.  I go up to the QC manager's office to let her know we had not yet found it and she said "Oh I found it on the stack 15 minutes ago... he already had signed it and forgot".

 

I wanted to do illegal things... so I left work lol.

I think they have to come.  Like it or not.  If the retailers do unannounced audits themselves then surely the main standards owners are bound to follow.  I don't have a problem with it.  My concern with the whole 3rd party audit "system" is the standard of auditors; there are some very, very poor ones indeed; in fact I would go as far as to say there are some complete fraudsters,,,to me weeding these people out and improving the quality and consistency of auditors in general is central to improving the integrity of GFSI standards.

My biggest gripe with auditors is inconsistency.  Our company owns 2 facilities.  Between us we have had 9 BRC audits with 5 different auditors.  All 5 had different interpretations of various clauses.  Our Food Safety programs are as close to identical as we can make them, yet one will get a non-conformance and the other will not.  Prior to our first BRC we had a gap audit at our other  facility.  I corrected all non-conformances in our plant that were found, yet still had 20 minors!

My biggest gripe with auditors is inconsistency.  Our company owns 2 facilities.  Between us we have had 9 BRC audits with 5 different auditors.  All 5 had different interpretations of various clauses.  Our Food Safety programs are as close to identical as we can make them, yet one will get a non-conformance and the other will not.  Prior to our first BRC we had a gap audit at our other  facility.  I corrected all non-conformances in our plant that were found, yet still had 20 minors!

Now that's what you call auditor inconsistency. If the gap audit and proper audit were carried out by the same certification body I would have asked for my money back from the gap audit. Ridiculous!

looking forward to having a BRC auditor come out soon as we get certified, yikes - seems like they always find some little thing

looking forward to having a BRC auditor come out soon as we get certified, yikes - seems like they always find some little thing

 

Ahh they have to find something, so let it very, very minor

Now that's what you call auditor inconsistency. If the gap audit and proper audit were carried out by the same certification body I would have asked for my money back from the gap audit. Ridiculous!

Yes, ridiculous it is.  Our audit follows the other plant by one month.  The same thing happens every year.  We have gotten a lot better...three A's now, but still frustrating for one plant to get a non-conformance on something the other was just audited on and found to be in compliance. 

We do have to remember and I have to concede that an audit is only a snapshot and cannot go into minute depth and detail on every part of the business, so it may be possible that an NC could be picked up at one site and missed at another.

I know you will correct me if I am worng, but this doesn't make sense to me. "BRC unannounced audits are available to sites achieving top grades with two options, a single unannounced two day audit or a one day unannounced GMP audit plus a one day scheduled system audit."

Wouldn't the BRC (or whomever) want to unannouced audits on the lower scoring facilities? The ones with the top 2 grades are already doing fairly well, wouldn't you want the lower scoring facilities to step it up?

Sure there is a possibilty that they would fall flat, but maybe if they had a window to repair major items...

I know you will correct me if I am worng, but this doesn't make sense to me. "BRC unannounced audits are available to sites achieving top grades with two options, a single unannounced two day audit or a one day unannounced GMP audit plus a one day scheduled system audit."

Wouldn't the BRC (or whomever) want to unannouced audits on the lower scoring facilities? The ones with the top 2 grades are already doing fairly well, wouldn't you want the lower scoring facilities to step it up?

Sure there is a possibilty that they would fall flat, but maybe if they had a window to repair major items...

 

I agree Sentana

 

Those achieving BRC Grade A, with few non-conformances, are doing so because their being audited to death! We're what I would call, audit ready at all times.

 

So it makes sense to look at the places that aren't achieving A grades. Help focus their minds.

 

Caz x

Thanks to everyone for their comments and rants!

 

With my vision of the future I believe that sites regularly achieving top grades that have unannounced audits will be rewarded at some stage with a reduction of audits. Those achieving lower grades probably aren't ready for unannounced audits and probably deserve closer scrutiny.

 

There will be inconsistency with auditors and as Simon has pointed out it is a 'snapshot' and there is a lot for an auditor to cover during an audit. The standards do however address auditor competence and even refer to 'calibrating auditors'. If you are not happy with the non-conformances raised or auditor performance you should raise it with the certification body, after all you are paying them.

 

Regards,

 

Tony

If you are not happy with the non-conformances raised or auditor performance you should raise it with the certification body, after all you are paying them.

 

Regards,

 

Tony

 

Just to add...if you do not get a satisfactory response from the Certification Body you can always report the issue to the relevant Accreditation Body who govern (for want of a better word) Certification Bodies.  Or complain directly to BRC, SQF etc.

Horsemeat scandal report calls for urgent and comprehensive reforms - The Guardian

The Elliot report recommendation:
'Supermarket and industry audits manage to be both enormously burdensome and futile in detecting fraud. Audits should be unannounced inspections, whereas the majority are currently pre-announced.'