HACCP System Audit

If a company has Prerequisite Programs and a HACCP Plan in place, does it need to be audited by a 3rd party? With HACCP itself not being a certification, I was curious if it should still audited by a 3rd party just for validity purposes? I'm guessing that potential customers would want to see some kind of proof that your HACCP system has been evaluated by a 3rd party?

If a company has Prerequisite Programs and a HACCP Plan in place, does it need to be audited by a 3rd party? With HACCP itself not being a certification, I was curious if it should still audited by a 3rd party just for validity purposes? I'm guessing that potential customers would want to see some kind of proof that your HACCP system has been evaluated by a 3rd party?

It certainly would not hurt, but I don't know that it's a requirement.
That would all depend on what your potential customer wants.

Marshall

Marshall is correct in general. In the EU there is no legal requirement to have a HACCP plan to be independently audited or certified by a 3rd party. The regulatory bodies will most likely inspect the HACCP plan and this might be considered an audit of sorts. You may well have a customer who requires GFSI (e.g. Wal-mart) and this will require certification of the food safety system including your HACCP and PRP's. And under GFSI there is a specific requirement that audits are conducted by someone independent of the area.

FSMA makes things a little more complicated. There appears to be requirement for certification of food safety plans, particularly for foreign plants and it remains somewhat up in the air on how this will ultimately shake out. Regardless, it is probably best practice to have some external expert who is part of your HACCP team who can assist and advise with its development and provide independent audit and review of the system on a scheduled basis. Remember, this is not an absolute requirements but if your operations are high risk it may be a wise investment.

George

If a company has Prerequisite Programs and a HACCP Plan in place, does it need to be audited by a 3rd party? With HACCP itself not being a certification, I was curious if it should still audited by a 3rd party just for validity purposes? I'm guessing that potential customers would want to see some kind of proof that your HACCP system has been evaluated by a 3rd party?

Hi there,

A 2nd/3rd party audit and/or certification to a recognised food safety management system scheme are pretty much standard customer requirements these days. Most organisations use GFSI Recognised Schemes such as BRC Global Standard, SQF Code, FSSC 22000, IFS etc.

The other thing that makes this worthwhile from a company's perspective is it may provide a 'due diligence defence'. The defence of due diligence is a method of defence you can use in prosecution proceedings to demonstrate that you took all reasonable steps to prevent the offence from occurring. Example and more details here from an Australian authority perspective and from an American supplier view of certification benefits here.

Regards,

Tony

Dear SKREDSFAN:
I have to assume that you are processing FDA regulated products, as you otherwise would have probably already had a USDA FSIS Food Safety Assessment, which looks at all parts of your HACCP and overall food safety system. FDA has not figured out which way they are going, but they have thrown out the idea of using 3rd party auditors to conduct some inspection activitities - given the repeat peanut butter issues, I'm not sure that is the best option... Also, depending on your taget market, all the big companies (WalMart, Target, Kroger), and increasing numbers of smaller ones, are requiring GFSI-based audits as a condition of doing business.
I agree with Tony-C's comments regarding due diligence.