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gregi86

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Posted 16 January 2015 - 10:06 PM

Hi there,

 

Could anybody please advise.

 

What hapens is a BRC standard is not clearly specified and uses unmeasurable guidelines using words as satisfactorily, appropriately, suitable etc.

 

As this is open to interpretation auditor no.1 says you need A and you are complying. Auditor no.2 says you need A** to comply.

 

Well who is right and how to stick to A? We all want food safety but clearly there should be sufficient cost effective measures in place.

 

If you need a Jaguar to do your job you will by cheapest of the Jaguars; not the top of the range only because your company can afford it...

You can see my point...

 

Any advice on how to effectively tacke such an instances?

 

Many thanks for your inputs!

 

Regards



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Posted 16 January 2015 - 10:39 PM

:welcome: to the forum.  Without specifics it is hard to give specific advice as to how to counter this as the "devil is in the details". But auditors having different opinions is a challenge for most of us in food safety and responsible for a fair amount of alcohol that is consumed. 


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mgourley

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Posted 16 January 2015 - 11:55 PM

I like to push back. "Can you show me, specifically, where in the Standard that is stated?"

 

Marshall



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mgourley

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Posted 16 January 2015 - 11:57 PM

If you are wrong, you learned something..if the auditor is overstepping, I want justification,



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Charles.C

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Posted 17 January 2015 - 09:07 AM

Dear greg,

 

It is a reality that many of the BRC requirements have alternative responses although it is of course the auditor's responsibility to validate why yr input is unacceptable.

 

As per previous posts it depends on your specifics.

 

I agree with mgourley, always challenge unless you are the positive beneficiary or there is a known "skeleton in the closet" waiting to pop out. :smile:

 

Rgds / Charles.C


Kind Regards,

 

Charles.C


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gregi86

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Posted 18 January 2015 - 11:11 AM

Dear greg,

 

It is a reality that many of the BRC requirements have alternative responses although it is of course the auditor's responsibility to validate why yr input is unacceptable.

 

As per previous posts it depends on your specifics.

 

I agree with mgourley, always challenge unless you are the positive beneficiary or there is a known "skeleton in the closet" waiting to pop out. :smile:

 

Rgds / Charles.C

 

 

If you are wrong, you learned something..if the auditor is overstepping, I want justification,

 

 

I like to push back. "Can you show me, specifically, where in the Standard that is stated?"

 

Marshall

 

 

:welcome: to the forum.  Without specifics it is hard to give specific advice as to how to counter this as the "devil is in the details". But auditors having different opinions is a challenge for most of us in food safety and responsible for a fair amount of alcohol that is consumed. 

 

 

Hi All,

 

Thank you for your replies.

 

This question was linked to my previous post "drinking/eating allow or ban?"

 

Certainly now we can have a risk assessment in place as per your comments/advice as well as challange.

 

I like your comments "auditor's responsibility to validate why yr input is unacceptable" & "Can you show me, specifically, where in the Standard that is stated?".

 

Many thanks and I shall apply and drill this into our audit handilng procedures....



Charles.C

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Posted 18 January 2015 - 01:06 PM

Dear greigi,

 

I like your comments "auditor's responsibility to validate why yr input is unacceptable" & "Can you show me, specifically, where in the Standard that is stated?"

 

As I mentioned earlier, the options may relate to the specifics of any disagreement.

 

But, in general, how can it not be the case ? It rules to competency.

 

(Auditors seem to prefer the term “justification” rather than “validation”.)

 

For example, from the BRC food standard (v6) –

 

3.1    Calibrating auditors

A key component of the scheme is the calibration of the auditors to ensure a consistent understanding and

application of the requirements. All Certification Bodies are required to have processes to calibrate their own auditors

 

.

etc

 

From a FS viewpoint -

 

Validation (verb; to validate, ratify; valid, sound, defensible of reasonable

objection – Oxford English Dictionary)

Definition: Obtaining evidence that the elements of the HACCP plan are effective.

Explanation: Validation is concerned with obtaining evidence that the elements of the HACCP

plan will be effective; as such, validation should be targeted at the assessment of the scientific and

technical inputs into the HACCP plan. Validation should ensure that the information supporting

the HACCP plan is correct – that the production facility is “going to do the right things” – thus

enabling compliance with food safety policy. Evidence to support HACCP plans can come from a

wide variety of sources.

Validation  provides  evidence  to  support  the  HACCP  plan  and  therefore  takes  place  before

implementation  and  after  alterations.  As  new  scientific  information  comes  to  light,  the

assumptions  on  which  the  validation  is  based  should  be  reassessed.  Where  necessary  such

reassessment must result in the amendment of the provisions laid down. When this is the case,

changes must be validated against this new information. Any change to the HACCP plan should

be fully incorporated into the documentation and record keeping system so that accurate up-to-

date information is available.

Where it is not possible to justify (validate, defensible of reasonable objection) an element of the

HACCP plan, there is only one option: modify the plan.

 

(ILSI 2001)

 

The key word is evidence.

 

And what is the Auditor’s modus operandum ? – “show me the evidence”.

 

What's good for the goose .........

 

Charles.C

 

PS - not saying that auditors expect/like to be challenged, quite the reverse. IMEX, their technical knowledge of your process is often likely to be skimpy. And they know it. ;)

 

PPS - haven't read the other post yet so no comments possible yet. :smile:

 

P3S - Just realized I misinterpreted the top quote, thought the 2nd half of sentence was a follow-up question :oops2: :doh: .


Kind Regards,

 

Charles.C


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Posted 31 January 2015 - 06:20 PM

If we could figure this out mate, we'd all have A***!!!

 

Different auditors have different points of view.

A good auditor should listen to your explanation and should refer to the interpretation manual and explain to you why they think you are not in compliance and then allow you to put forward more evidence of compliance.

 

But I have had the experience of one auditor accepting a system/control and the following year being beaten up for it.... always ask ( politely, through gritted teeth.) " Can you show me where this is stated in the standard".

 

Sometimes auditors have pre-conceived ideas about how things should be done and can't get their head around it being done differently. One of my clients has a chilling step that causes no end of confusion, as [product goes in to chill at a specific time but may not come out in order and may go to any one of 3 or 4 destinations for further processing, so there is no record with time in/time out wrecks their heads it does....

 

Always always ask for a proper explanation, it's an opportunity to learn.


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



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