Are stop belt rejection systems allowed in Germany

For metal detection IFS version 4 states:

5.5.3 The metal or foreign body detector shall incorporate both an alarm, and where applicable, an automatic rejection device, which shall either divert contaminated product into a separate area, accessible only to authorised personnel, or for continuously extruded product only, identify via an appropriate mark the location of the contaminant. Only where automatic rejection or identification is not possible will a simple line stop be acceptable.

Our sister company in Germany has stop belt rejection systems and have not had a non conformance for this. However we had one detector with a stop belt and got a non conformance for it (quite right against this clause). Why would a German auditor not give a non conformance against this clause? Have you any ideas Peter?

Hi Yorky,

i've never had an problem to get a confirmation with a stop belt + alarm. How ever, it is very likely, that it depends to the certification company.... did you discuss with the company itself or only with the auditor? And what level of non complience did you get?

Peter

For metal detection IFS version 4 states:
Our sister company in Germany has stop belt rejection systems and have not had a non conformance for this. However we had one detector with a stop belt and got a non conformance for it

<{POST_SNAPBACK}>

Hi yorkshire,
maybe it depends on the position...
Is the arragngement of your detection system the same as in your german factory? Do you produce the same products? Is it possible that you identify the wrong product as source for the stop?
Most decisions depend on special situations and as Peter said, sometimes it depends on the philosophy of the certification company.
They have in-house-trainings for their auditors to harmonize such questions.

Hi Peter and Witch,

Our factory in Germany is making the same products as in the UK. The lines are identical with the exception of the metal detectors on which most of ours have automatic rejection into a locked bin.

The non conformance was a minor at level C. The auditor was unsure as to whether to put it as a major. If we had got a major for it we would certainly have complained to the certification body.

Reading the wording of the IFS the auditor was right to give a non conformance but I think it should have been a B (but who cares) as 97% of the detectors complied with the standard.

My query is why this clause is not read the same way in Germany as it is in England (My German colleagues confirmed that the clause is translated correctly). I suspect that in Germany the custom and practice is for lines to have a stop belt and an alarm (Is this a correct assumption?), therefore if the auditor is used to this type of detector they take it for granted (as I did) that they comply without reading the clauses carefully enough.

What do you think?

I am a IFS aduitor. I don't think you have problem. But some other information might influence auditor's final score. Can you specify your situation in details?

Ding,

The product we pack is a fairly simple, low risk, highly processed product. On the whole that are packed into small bags and pass through a metal detector ( all detectors less than 5 years old ). During our last audit 97% of our detectors had automatic rejection into a locked bin and we got a Minor C. My German colleagues have mainly stop belts and didn't get a non conformance.

What do you think?

P.S. Which country / language are you auditing in?

We recently had our IFS audit (which went quite well) and I asked the auditor about the differences between the UK and Germany on this subject. The auditor stated that if the company just had stop belt metal detectors a non conformance should be raised this clause. They did not say what level of non conformance would be given.

Dear Yorky,

I just cannot resist getting involved here although I am not into IFS but the rule in BRC-Food is almost the same but you do get a choice. However, I read IFS clause 5.5.3 as similar in intention.

BRC-Food allows you to incorporate either an alarm on a belt stop system OR an auto rejection device OR in-line detector.............procedures documented specifying corrective actions if event occurs. IFS 5.5.3 mentioned "where applicable" - an auto device applies.

This is where the Site Auditor should make clear his interpretation of the clause which could be WRONG (I would ask for specific reason on the NCR). IMO, Ding is right to say that you should not have an issue here unless some elements have been factored in on the score.

At the end of the day, have you lost control of your objective to monitor the specific hazard and has the control in place been effective in minimising food safety risk? If your answer is YES - IMO justified to review this auditor for next year's audit

Charles Chew

Charles,

The IFS does not have the BRC's "where applicable" clause in. Their statement is "Only where automatic rejection or identification is not possible will a simple line stop be acceptable."

Yorky,

I have given this a thought and I feel that as dynamic as any food safety systems can be regardless of their "names" it is impossible to be too "dogmatic". Unlike ISO 9000, the standard to follow is pretty straight forward, but the variable elements is completely different for food safety systems.

The risk assessment is done by the food safety team and is based on justifications that they feel, apply. That is the discretion of the team members. Shd the auditor feels otherwise, he HAS TO GIVE a REASON FOR HIS VIEW.

IMO, the auditor is not practical and inteprets the standards w/o considerations on other preceding and following issues that your team members may have. In any case, the main argument is "P. Schnittger - never had problems with his auditor on the stop belt and alarm system he is using" - why shd you?

Personally, I would consider an alternative auditor for next years' audit.

TQ
Charles

Charles,

This clause is not a problem to us as all our metal detectors now comply. What I am trying to do is just highlight the inconsistent way these standards are applied. I think that the BRC standard of "where applicable" is a more reasonable approach as the auditor can then make an informed judgement - if they are not happy with the metal detector system thay can then look at customer complaints, non conformances, etc. to decide if there is a significant risk.

The other point I would like to highlight is the difference in training for IFS and BRC auditors. Please correct me if I'm wrong but an IFS auditor needs 2 years relevant industry experience, whilst a BRC auditor need 5 years. The BRC auditor is therefore, potentially, more likely to be able to make an informed decision. However alot of auditors now audit to both standards which makes my point irrelevant.

Personally, I would consider an alternative auditor for next years' audit.

I think we'll stick to the devil we know rather than one who may focus on different areas.

Yorky,

Inconsistent interpretations amongst different food auditors is a fact of life so long as the standard's specifics are not clear. I face this issue practically every month.

Although, I do some times feel Auditors have their points to make, the implications of their actions or decisions invariably cause a lot of problems along the way.

Personally, I prefer a "microscopic" auditor that turns every stone but remains pragmatic when it comes to audit reporting. Such an auditor would indeed point to the weaknesses of your system when you think its honky dory.

But a smart auditor would consider capitalising the observations for improvement as a buffer giving the client some continual improvement programs as a way to close the gap.

All said - keeping the devil you know is a wise choice!

Regards
Charles Chew

Inconsistent interpretation of Standards appears to be a recurring theme (wooden equipment, metal detection etc.). Now matter how prescriptive the Standard auditors will always emphasise their personal experiences and bugbears. Sometimes this can be useful other times it can be difficult as Yorky has found with the stop belt rejection system. So what happens when there really is an impasse between auditor and auditee - what is the process of arbitration?

Regards,
Simon

So what happens when there really is an impasse

This is very interesting. A week ago I was confronted with such a situation and I had to response as this would greatly affect us.

The relationship is not about two parties but three. I consider the CB to be the co-ordinator and generally the governing party. My conclusion then was that the food auditor (new to me) displayed fanstastic technical competency but thought the lack of report / good business management was detrimental to us. (Hey! a Good Songwriter is Not necessarily A Good Singer)

I called the CB (a renown org.) and urged them to provide alternative auditors for the next audit or face losing out customers from us. Of course it worked - its all about business but most importantly without compromise to quality and image of all parties. We responded because in this case, it affected us not them.

Bottom line was we were able to "pull" the thorn and move forward. Again, I retain the auditor for 3rd party audit which I thought was the person's forte. All ended well

That was my worse case scenario and yes, there may be others to come

CHarles Chew