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What is the correct process for appealing audit nonconformances?

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Kim88

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Posted 05 June 2013 - 07:17 PM

Our last audit had 9 non-conformances. Two of these we have not done corrective actions yet due to the cost of the corrective actions. I recently attended a SQF training in which the instructor (whom is also an auditor) informed me that because we are a low risk facility we should not have received non-confomances and I should appeal these. We are a small wholesale bakery. One of the N.C.s was that hand wash stations in production areas be converted to hands free operation the other requiring ATP testing. My question is how do I appeal these?, and am I required to do risk assesments? Thanks for your time. Kim88



Bill78

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Posted 06 June 2013 - 10:18 PM

Kim88,

First of all, nice job on only having 9 NC's. All of us involved in this forum and GFSI audits know that is a great accomplishment. 

 

Section 3 of the BRC manual gives instructions for appeals..."must be made in writing within 7 days of the receipt of the certification decision".

 

Hands Free Hand sinks are covered in 4.8.6 and it is a requirement and as I read it, whether your facility is low or high risk. 

 

I don't see a requirement for ATP testing in the Standard but it is mentioned as a possible option for how you define "clean", in section 4.11.2

Did you have a clear definition/procedure of how you determine when something is clean? 

 

Your risk assessments form the basis for the decisions you make within your policies, programs and procedures. When an auditor finds an issue with your programs, often they will ask to see the risk assessment so they can see your decision making process/thoughts. 

 

Every class we took in preparation for the BRC said that risk assessment must be done. 

 

Hope that helps. 



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Philips

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Posted 07 June 2013 - 09:25 AM

Conglats for only 9 NCs;this is wow! I suggest that you do not go ahead and appeal; remember once this is done, the follow-up audit might be more stringent than the previous, more so on the risks and consequences;

 

Consult again your risk assessment and hazard analysis table and how you determine the fulfillement of the standard requirements prior to making a decision to appeal

 

Great day

 

Philip



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Posted 07 June 2013 - 09:55 AM

Was the SQF auditor carrying out the training a BRC auditor and fully familiar with the requirements of BRC Version 6. 

It may be different in SQF.  Maybe someone can provide a direct comparison to see what it say's abou the two areas in SQF and BRC for your type of product.


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Posted 08 June 2013 - 10:46 AM

Our last audit had 9 non-conformances. Two of these we have not done corrective actions yet due to the cost of the corrective actions. I recently attended a SQF training in which the instructor (whom is also an auditor) informed me that because we are a low risk facility we should not have received non-confomances and I should appeal these. We are a small wholesale bakery. One of the N.C.s was that hand wash stations in production areas be converted to hands free operation the other requiring ATP testing. My question is how do I appeal these?, and am I required to do risk assesments? Thanks for your time. Kim88

 

Hi Kim,

 

Was your audit against BRC or SQF? when was your audit? & were all the non-conformances minor?

 

Regards,

 

Tony



Charles Chew

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Posted 09 June 2013 - 11:05 PM

Our last audit had 9 non-conformances. Two of these we have not done corrective actions yet due to the cost of the corrective actions. I recently attended a SQF training in which the instructor (whom is also an auditor) informed me that because we are a low risk facility we should not have received non-confomances and I should appeal these. We are a small wholesale bakery. One of the N.C.s was that hand wash stations in production areas be converted to hands free operation the other requiring ATP testing. My question is how do I appeal these?, and am I required to do risk assesments? Thanks for your time. Kim88

Hello Kim88, You may want to offer the Auditor by using alcohol sanitation as your last point of decontamination measure and an alternative corrective action and have the effectiveness validated.


Cheers,
Charles Chew
www.naturalmajor.com

MCIAN

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Posted 10 June 2013 - 01:43 AM

Hi Kim88!

 

It doesn't take much cost to have a hands-free hand wash station. We converted our faucets to foot pedals - just takes a little engineering manipulation. Our previous sensorized faucets broke down easily unlike the foot pedals.

 

Regards.



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Posted 10 June 2013 - 06:34 AM

If you would like to dispute any non-conformances that you received in an audit, you need to liaise directly with the certification body of undertook the audit. I would suggest you review the particular part of the standard for which the non-conformance was raised to ensure that your appeal is justified (based on the evidence that the auditor reviewed during the audit and what the standard actually states).

 

As far as I know (and for how I audit for both BRC and SQF) - if the standard states 'shall', 'will' or 'must' - it is mandatory and a CAR can then be raised. If the standard states "should" this is optional, and the auditor should not be raising a CAR.

 

CARs are also not based on risk. If it is mandatory in the standard for whatever you're being audited against, your business is required to comply. The only buffer for this is with SQF, you are allowed to provide a risk assessment to show how non-compliance with a certain requirement will not be detrimental on the product that you product and supply.


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