10 replies to this topic

[Ian R]

We have just had an EHO visit and the EHO has asked (more realistically insisted) that we take the following actions:

• Confirm by telephone with the accreditation body evert BRC certificate that we receive from a supplier
• Confirm in writing with the relevant authorities that all overseas suppliers are in fact genuine companies
• Document on our internal procedures any relevant EU UK or Industry related legislation. e.g. we have procedures to micro sampling these must refer to any legislation that relate to micro in our industry
• Remove from all engineering procedures the term 'clean tools' as he has never heard of any one micro swabbing engineering tools. We tried to make him understand clean did not mean sterile, and this refers to tools being free from grease, food residue etc, but no no avail.
• The Quality manual must be crossed referenced so that he can view the manual without needing to ask us for any information.
• All section of the HACCP must be referenced to the relevant sections in the Codex.

Has anoy else had similar requests from an EHO?

[cazyncymru]

We have just had an EHO visit and the EHO has asked (more realistically insisted) that we take the following actions:

• Confirm by telephone with the accreditation body evert BRC certificate that we receive from a supplier
• Confirm in writing with the relevant authorities that all overseas suppliers are in fact genuine companies
• Document on our internal procedures any relevant EU UK or Industry related legislation. e.g. we have procedures to micro sampling these must refer to any legislation that relate to micro in our industry
• Remove from all engineering procedures the term 'clean tools' as he has never heard of any one micro swabbing engineering tools. We tried to make him understand clean did not mean sterile, and this refers to tools being free from grease, food residue etc, but no no avail.
• The Quality manual must be crossed referenced so that he can view the manual without needing to ask us for any information.
• All section of the HACCP must be referenced to the relevant sections in the Codex.

Has anoy else had similar requests from an EHO?

Doesn't want much does he!!!

lets see if i can help, at least with some of them.

1> Does he want you to check that each certificate you request is genuine? you can check on the BRC website a companies certificate and grade. you could just print that off and keep with the certificate.
2> Chances are that any international company that you are dealing with have some sort of certification. that should suffice. again you can check if a company has accreditation by checking either BRC/ ISO websites. Aso it should be part of your supplier approval.
3> As part of my HACCP i refer to all legislation that is relevant to my industry. That's just good practice.
4> In your engineering procedure add the term "visually" clean tools and that tools are cleaned on return to the workshop.
5> Cross reference what in your QM? My QM is cross referenced with the clauses in the BRC. It's a nightmare cross referencing because if you alter a document, or insert an appendicies, you have to remember to change them all.
6> I have referenced my HACCP against the relevant clauses in BRC, which is in fact Codex.

Hope this helps Ian

caz x

[Ian R]

Thanks for the comments

We have suggested using the BRC web site, he was not aware of this hence he feels we should be phoning the actual auditing body.

We request supplier questionnaires and BRC or equivalent certificates from all suppliers, that along with some auditing (based on risk analysis) is part of our supplier approval. His question was "How do we know this company actually exists?. Yes you have a questionnaire and a certificate but they could be fraudulent."

With regard to legislation, we have all relevant legislation referred to in the HACCP, as you say, that's good practice.
He wants the legislation referenced on the actual procedures. So, for example, any procedure that involves micro testing or sampling should refer to the legislation that relates to micro standards or testing for our industry sector. We have argued that this is already covered in the HACCP but no joy.

He wants the quality manual structured so that he can use it without having to ask us where a document, record or policy is stored. This is to be more than a simple index. Basically he wants the manual structured for his ease of use not ours. He has not commented on any of the contents he wants to be able to sit in a room on his own and go through the manual without having to ask questions.

Our terminology in the engineering procedures was, All tools should be clean and free from contamination before being used. All tools should be cleaned after use.
It was the term clean and cleaned he didn't like. We will try visually clean.


I have never had requests like this from an EHO.

[cazyncymru]

Thanks for the comments

We have suggested using the BRC web site, he was not aware of this hence he feels we should be phoning the actual auditing body.

We request supplier questionnaires and BRC or equivalent certificates from all suppliers, that along with some auditing (based on risk analysis) is part of our supplier approval. His question was "How do we know this company actually exists?. Yes you have a questionnaire and a certificate but they could be fraudulent."

With regard to legislation, we have all relevant legislation referred to in the HACCP, as you say, that's good practice.
He wants the legislation referenced on the actual procedures. So, for example, any procedure that involves micro testing or sampling should refer to the legislation that relates to micro standards or testing for our industry sector. We have argued that this is already covered in the HACCP but no joy.

He wants the quality manual structured so that he can use it without having to ask us where a document, record or policy is stored. This is to be more than a simple index. Basically he wants the manual structured for his ease of use not ours. He has not commented on any of the contents he wants to be able to sit in a room on his own and go through the manual without having to ask questions.

Our terminology in the engineering procedures was, All tools should be clean and free from contamination before being used. All tools should be cleaned after use.
It was the term clean and cleaned he didn't like. We will try visually clean.


I have never had requests like this from an EHO.

he sounds like a knob! is he newly qualified???

i'd arrange a meeting with his boss, his demands are unreasonable.

As a matter of interest, what are you producing?

caz x

[Anne Z]

Sometimes it all depends on the officers mood. And clearly he wasn't in a happy understanding mood when he visted your company.

I don't know the BRC that well, but the cross reference is a thing every auditor or inpector wants. Iit makes their job a lot easier. I'm not sure it is obligatorily. In my QM (ISO 9001 and GMP) there isn't a cross reference as things change and as Cazyncymru said it is a nightmare to keep that up to date.

Good luck!

[Tony-C]

Thanks for the comments

We have suggested using the BRC web site, he was not aware of this hence he feels we should be phoning the actual auditing body.

We request supplier questionnaires and BRC or equivalent certificates from all suppliers, that along with some auditing (based on risk analysis) is part of our supplier approval. His question was "How do we know this company actually exists?. Yes you have a questionnaire and a certificate but they could be fraudulent."

With regard to legislation, we have all relevant legislation referred to in the HACCP, as you say, that's good practice.
He wants the legislation referenced on the actual procedures. So, for example, any procedure that involves micro testing or sampling should refer to the legislation that relates to micro standards or testing for our industry sector. We have argued that this is already covered in the HACCP but no joy.

He wants the quality manual structured so that he can use it without having to ask us where a document, record or policy is stored. This is to be more than a simple index. Basically he wants the manual structured for his ease of use not ours. He has not commented on any of the contents he wants to be able to sit in a room on his own and go through the manual without having to ask questions.

Our terminology in the engineering procedures was, All tools should be clean and free from contamination before being used. All tools should be cleaned after use.
It was the term clean and cleaned he didn't like. We will try visually clean.
I have never had requests like this from an EHO.

Hi Ian

Sounds like a jobsworth

Can I ask if he put these requests in a report or inspection summary?

In these cases I always think it is best to put things in writing so I would write to him to tell him what you plan to do in repsonse to the points he has made. This is after deciding which is best for you and covers you adequately. If you get an inadequate response from him then take to a higher level in the local authority.

Checking on the certification bodies website is a reasonable check to see if an organisation is genuine.
I would reference all relevant legislation only once and refer to where this is documented if necessary.
With regards to the QM I would say it is designed to work as a system within your organisation and as such you feel your index is sufficient.
I would reference CODEX in my HACCP and keep a copy in the HACCP file but not reference every section.

Regards,

Tony

[Ian R]

To answer some of the questions
We are in bakery but not high risk.

The EHO has said he will not be putting any of the requirements in writing but will be back in 3 months to make sure we have done them.
Interestingly this was his second visit, but at no time has he actually been on the shop floor.

A couple of additional points I didn't mention in the first post.
The risk assessment carried out by the pest control contractor wasn't signed. This is the RA for visiting the site. Yeah - we missed that one.
The EHO felt this was "totally outrageous, extremely serious and illegal, we could be prosecuted for this"

Our HACCP has been accepted by BRC auditing, Tesco, Asda, Mossisons, Lidel and Netto.
It is a comprehensive and complete HACCP system, you can always improve but the EHO feels it is unacceptable and he told the MD he is on verge of prosecuting us.
But he won't put anything in writing, strange!

And my personal favourite
When the engineer goes to do any work on a machine or in the factory he needs to record how many bolts, nuts, washers etc he takes out of the workshop with him. And then record how many he brings back. This all needs to be formally documented.
As the auditor said "in the aircraft industry you can't afford to have nuts and bolts floating about"

Maybe they should fit metal detectors, no wait ... perhaps we could have those in food factories!

The EHO is, not surprisingly, ex aircraft engineering

[GMO]

Interestingly this was his second visit, but at no time has he actually been on the shop floor.



I suggest you contact the food safety team at the council, after all you're not likely to make the situation worse!

There are two things I kind of agree with though. I do cross reference documents from our Food Safety and Quality Manual (I don't put in revision numbers though, that would just be crazy). I think that's sensible but it's not a non conformance.

As for the counting out and back in; I disagree it should be part of taking items out of a store but it is best practice for the start and end of a job. That said, getting our engineers just to sign off that something is clean and tidy at the end of the task is job enough in itself. I could imagine the looks of incredulity I would get if I suggested this lol!

His point about cross referencing HACCP to codex is anal but easy to do. You could even put it in your introduction, e.g. section 1 references... . Likewise with "clean tools" you could easily change the wording to "tools with no visible soiling". That might be the way round it actually, knock of the "easy to do but annoying" things he's suggested and then contact the food safety team to say "I don't agree with his points, however, I have adopted some of them but disagree with these others because I believe they would put undue pressure on my business." I'm sure if you ask to speak to his boss and point out how he's never been into a manufacturing area you may find things change...

Tell me how many Tesco stores call up every certification body to ensure their BRC certificate is real lol! What an eejit!

[Soda]

<LI>Confirm by telephone with the accreditation body evert BRC certificate that we receive from a supplier

Since when has BRC been a legal requirement anyway? Our EHO/DARD have never asked for our third part accreditation.

[Charles.C]

Dear Ian,

Sorry for yr woes.

I don’t wish to appear over-cautious and I hv no direct experience of visiting EHO practices in UK but this scenario appears to me to indicate that some particular “incident” has occurred which has triggered off a firestorm, either from a personal affront type situation or some, perhaps as yet unstated, other factor.
I am also aware that the “due diligence” parameter is of considerable weight in the UK Food Regulations.

I hv encountered all kinds of auditors, official and invited, and hv certainly been offended by a small number of them due, IMO, to their professional (in)competence, uncooperativeness and occasionally personal characteristics, eg air of infallibility, automatic distrust of every statement, but the characteristics of both sides of this situation , with all due respect, seem peculiar to me.

Pro-inspector –

I have never encountered a system of Quality manual / Quality procedures which avoids cross-referencing. I am guessing that it is not obligatory but I would hv thought it impossible to construct without such although I am perfectly willing to be convinced otherwise. This was really accepted by BRC ?? The expected ability for auditor’s to smoothly traverse document manuals in isolation of the writer is legendary of course and quite unjustifiable IMO. Nonetheless, the opposite extreme is guaranteed to evoke hostility IMEX.

As far as documenting work utilities goes, I hv previously had to sign out for every biro and pencil I hv used at one employer !. I think most stores including engineering functions demand exact records of all items for legal accounting purposes in addition to safety logics (even if the subject is perhaps not on the missing knife scale of risk unless, for example, an ammonia compressor self-destructs due failure to apply unrequested new bolts).

The “clean tools” phraseology is usually inappropriate, eg non-objective. As you say, “visually” clean clearly excludes any microbiological connotations, hv used this myself without objection in an engineering context.

Con – inspector –

1.The telephone aspect would be unique IMEX. Seems unbelievable if no specific reason given, ie scope of visit.
2. Seems equally absurd if no specific reason given.
3. Seems like nit-picking. I would hv expected one or perhaps two demonstrable linkages but again, unless perhaps for some specific reason.
4,5. See above.
6. Similar to 3.

Equally I don’t quite understand what the prime function of this “inspection” was if no written assessment was to be provided. Surely these auditor comments are made by reference to some specific standard ?? I hv seen a few EHO evaluations published on the Internet (including some NCRs) and these all seemed quite professionally done and included statements of expected requirements.

I would very much like to see an example of the kind of document which produced such strange (to me) responses. I am curious if you used consultants in the construction of yr documentation manuals etc.

Rgds / Charles.C

BTW, Welcome to the forum !

[Esther]

We have just had an EHO visit and the EHO has asked (more realistically insisted) that we take the following actions:

• Confirm by telephone with the accreditation body evert BRC certificate that we receive from a supplier
• Confirm in writing with the relevant authorities that all overseas suppliers are in fact genuine companies
• Document on our internal procedures any relevant EU UK or Industry related legislation. e.g. we have procedures to micro sampling these must refer to any legislation that relate to micro in our industry
• Remove from all engineering procedures the term 'clean tools' as he has never heard of any one micro swabbing engineering tools. We tried to make him understand clean did not mean sterile, and this refers to tools being free from grease, food residue etc, but no no avail.
• The Quality manual must be crossed referenced so that he can view the manual without needing to ask us for any information.
• All section of the HACCP must be referenced to the relevant sections in the Codex.

Has anoy else had similar requests from an EHO?

Dear Ian R

According to the majority of comments of the other members I would remind an old saying which fits here:

Ignorance can be very imprudent or Ignorance has not limits ( or something similar )

I am not quite sure about what EHO stands for but by reading all the mails I think that it is about " official inspections" isn't it?

I would like to share two experiences.

Once I read an official requirement wrote by an official inspector, It was about labelling. There was a high sanction running. I asked the CEO of the food company for permission to appeal against it. He accepted. It is a long story but finally the sanction went down more than half because the inspector was wrong in many things.

And again, a client called me urgently because the inspector had been in his company and the inspector had observed a lot of non cnformities. I went there, he explained to me all the non conformities and when ask for the writting requirement ! surprise! none of those were put in writting. Finally only one of the non conformities was addressed and everything is OK. The inspector never came back.

I hope this can help for the future for all food operators.

BEst regards
Esther