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Auditor and FST Member – potential conflict of interest


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Jus'me

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Posted 04 December 2014 - 02:37 PM

I have a bit of a dilemma in that not only am I the SQFP at the facility that completes the internal audits and inspections, but am also the head of the Food Safety Team that is responsible for the Corrective Actions found in the audits.  So not only am I responsible for uncovering the deficiencies, but also correcting them.  to me this seems like a conflict of interest.  How do I remain an objective auditor and also a consultant for the problems I uncovered?  Most of the revisions of SOP's ultimately fall on me to correct when a deficiency is uncovered during the audit that I myself conducted.  Any suggestions? 



Mr. Incognito

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Posted 04 December 2014 - 02:46 PM

You do all of the internal audits?  An internal auditor doesn't need to be an SQF Practitioner they just need internal auditor training.

 

An example of possibilities is how we run.

 

We have an internal audit team that does internal audits.  After the IA is complete they are brought by the Office Manager to the next Food Safety Team Meeting and we (I) read them over to the team.  The team decides if there is a food safety risk that needs a CA or a PA (Corrective Action / Preventative Action).  The Maintenance Manager is part of the FS Team as well as the Milling Superintendent.  The Milling Sup makes out a work order and typically the Maintenance Manager or his assistant fixes the issue and the Milling Sup closes the work order.

 

During our FS team meetings I have an agenda item for open CA PA items where we review any open or recently finished items.

 

So while I'm the team leader I'm not the be all end all of CA PA items.  The Office manager is the one who keeps the log of CA PA items. 

 

In my own internal audits I don't directly identify if something is a food safety risk I identify things as discrepancies and the team decides if that discrepancy is a food safety risk and the team tracks it together.


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Mr. Incognito

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Posted 04 December 2014 - 02:50 PM

also for revisions of SOP's, forms, etc you could make a mock up of the change and bring it to the food safety team for review and approval.  That way there is a check against your work.


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Jus'me

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Posted 09 December 2014 - 03:10 PM

Thank you Mr. Incognito, you surely know where your towel is.  Unfortunetly we are a small company so I am required to wear many hats.  Presently I am the only individual in the plant that has formal training on both SQF Practitioner and Internal Auditing, and am head of the Food Safety Team.  And nobody else really wants to be trained, so yes I am often in improbability drive trying to do everything, including not only my SQF and Auditing duties, but also my QA duties.  I still feel though that it is a conflict of interest if I am auditing the system and then drafting the recommended changes from my own audit for the Food Safety Team to approve.  And anticipating what you woudl say next, I have tried to delegate responisbility for rectifying audit results to other members of the team but have had limited success.  Basically though, the question is:  Is it a conflict of interest for me to not only audit the system but then make or suggest changes based on the audit findings?



RMAV

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Posted 11 December 2014 - 09:09 PM

"Basically though, the question is:  Is it a conflict of interest for me to not only audit the system but then make or suggest changes based on the audit findings?"

 

It is, in my opinion, a conflict of interest.  I am in a similar situation at least in terms of responsibilities for internal audits.  The standard makes provision for this, as you might know, 2.5.7.3, "Where possible staff conducting internal audits shall be independent of the function being audited."

 

I received an OIP (to which I whole-heartedly agree) for being the sole-internal auditor.  Also of note, internal auditors need to be trained, yes, but you can do the training provided you can demonstrate or provide evidence you are competent to do so and meet the intent of the code.  But it sounds like, unfortunately, a management commitment issue in your case.

 

EDIT: to be fair, it is possible your management is committed but just doesn't have the resources to put more auditors on the floor.  If your system is effective the way it is, you'll be fine (but hellishly busy)


Edited by RMAV, 11 December 2014 - 09:10 PM.


trubertq

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Posted 12 December 2014 - 11:55 AM

I have been in that position ( I am an external technical support, I dislike the title consultant) and it has never been an issue up til this year when during the BRC audit the auditor gave us a NC for having me on The HACCP Team and also carrying out HACCP internal Audits.I was delighted to remove myself from said team , although I still attend HACCP meetings, as external support.

 

WRT the document revision I have been doing that for 3 or 4 years for all my clients as I find that most Q Ms don't have time to do it. I make the changes send them via e mail to the relevant managers and get approval and then QM  issues the doc. My name is not on any of the docs I put the Manager of the relevant area as author and approval has to be the QM. 

 

All I do is act as secretary for the people, they tell me the information, I type and format, they check and sign off, and then QM issues...

 

I am the sole Internal auditor in all the facilities I visit and it hasn't been a problem , but I only deal with BRC.

 

As for implementing Corrective actions, well until the system is bedded in and people get used to being handed things to do and a time scale for doing them, I'm afraid you'll have to do that too...otherwise it'll not be done. I instigated a system of monthly Quality meetings where we discuss outcomes of Internal, Structural, Hygiene and GMP audits, customer complaints for the previous month, and internal Non conformance detected by the QC team. It took about a year for the penny to drop and people would volunteer to take charge of an issue but it did happen.

 

 

Personally I don't see a conflict of interest as you are finding non conformances in the system and then managing the corrective action,fair enough someone else in an ideal world should be doing it QM f. ex but we don't live in ideal worlds with loads of people. I'm in small companies and it is my mission to make raising their Food Quality standards as easy for them as possible with the teams they have, if that means I have to chase people with a big stick to get things done, I can show you pictures of me doing it!!  :rock:

Don't worry you're doing fine.


I'm entitled to my opinion, even a stopped clock is right twice a day

Mr. Incognito

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Posted 12 December 2014 - 12:39 PM

I don't think it's a conflict of interest to perform an audit and also be a part of the team to suggest changes but it shouldn't just be all one person just doing everything.


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