Well Charles, the Validation/Verification piece was not tested (yet) as the discussion around CCP determination left me feeling well....concerned that they may not have determined the CCP's in an objective and consistent manner. I therefore halted the audit. I was concerned that the whole FSP may just be a reflection of how management saw risks in their business last year, and if a different group moves in, the new group could see things differently. (I might add that I was conducting a 2nd party audit here, not 3rd party certification).
Laying my cards on the table, I believe it is important to understand clearly how an organisation determines important HACCP steps such as CCP determination, and I have difficulty accepting a group of managers getting into a room, discussing the process, and then deciding where CCP's need to be after necessary discussion. I am not saying that they are not capable; I think they are. It's more that the outcomes (at least in my view) are less predictable, and vulnerable to influence by more 'senior' people.
I am encouraging them to review this practice and think about having a more structured and objective process in place; one that can be clearly articulated to anyone from the outside. I however only can reflect on my views and hence my desire to get other opinions from my learned colleagues.
