8 replies to this topic

[michaelgaspard]

Hi all,

I just want to have your idea, I am the QM of a food production company, but for management commitment reason, the part senior management commitment and complaint handling is being tackled by a senior manager himself, so under his responsibility.As such I am responsible of the rest of the manual, I audit the process, I audit the laboratory.

And do training and the HACCP parts is under my responsibility. IN SUCH A CASE, IS IT ok THAT I am the internal auditor??

 

thanks for your feedback,

Michael. G

 

[MWidra]

As I understand it, you could audit the company's compliance with the BRC standard as long as you are not auditing something that you are performing, like the HACCP plan or the training.  Someone else would need to audit your performance of those functions.

 

That is a rule for all internal auditing, not just BRC.

 

Others, please verify.

 

Martha

[Charles.C]

Hi all,

I just want to have your idea, I am the QM of a food production company, but for management commitment reason, the part senior management commitment and complaint handling is being tackled by a senior manager himself, so under his responsibility.As such I am responsible of the rest of the manual, I audit the process, I audit the laboratory.

And do training and the HACCP parts is under my responsibility. IN SUCH A CASE, IS IT ok THAT I am the internal auditor??

 

thanks for your feedback,

Michael. G

 

Dear michaelgaspard,

 

Assuming this is BRC food, then as per previous post, probably not -

 

3.4.2 Internal audits shall be carried out by appropriately trained, competent auditors. Auditors shall be independent (ie not audit their own work).

 

Rgds / Charles.C

[Sharon (Dewsbury)]

I would say some things e.g. Document Control  & HACCP training would have to be audited by someone else because this is part of your function, but auditing the production paperwork , maintenance,  cleaning etc. is ok for you to do. You may maintain the procedures and forms but using them effectively is for others and you can police that they are. Audit the staff facilities, hygiene, pest control etc 

Regards

Sharon

[trubertq]

I'd agree with Sharon, it's probably ok for you to audit the parts of the standard which are not directly under your control. I am an external auditor so I audit everything except document control and Internal auditing which are the two areas for which I am responsible within the FSMS.

[michaelgaspard]

Thanks all for your advice,

kind regards,

Michael G

[MWidra]

I'd like to continue this topic down a side path, if I may.  This question is for all who are currently BRC certified.

 

We are ISO 9001 and our QC manager and controller perform the internal audits for this standard.  Both have been formally trained in auditing, so that's not an issue.

 

Neither of them are very familiar with the BRC, though they are familiar with cGMP requirements and HACCP.  Would they need to take any further training to perform the BRC internal audits, or could they just read the standard and use it as the "standard" and audit strictly against performance of it?

 

I know that it is always optimal for the internal auditors to be knowledgeable about the scheme, but how much depth of knowledge do they need to fulfill the requirements of the standard?

 

Obviously, as the HACCP Coordinator, I can't do any of the auditing, so I'm looking for someone else to tap for the job as we move towards certification.

 

Thanks,

Martha

[trubertq]

As long as they have some Internal auditing training I don't think it needs to be specifically 'BRC' training, all the standard states is 'appropriately trained'. They can take the sections of the standard and audit against them, and I would advise getting a copy of the interpretation guidelines as they can prove very useful when managers start to argue with internal auditors!!

[Charles.C]

Dear MWidra,

 

I know that it is always optimal for the internal auditors to be knowledgeable about the scheme, but how much depth of knowledge do they need to fulfill the requirements of the standard?

 

Unfortunately, I would say "considerable". Not so much from a GMP aspect, or even on "basic" HACCP  but more on the FS sub-topics.But it again depends on the FS knowledge base. I have encountered certified auditors ranging the whole gamut of HACCP awareness.

 

(a) The product / process may be relevant to your query, eg "simple/non-simple".

 

(b) Plus whether the 2 persons referred are familiar with any other, GFSI recognized, FS Standards other than BRC ? I also assume documentation would be included in their audit scope.

 

If the answer to (b) is negative, understanding the BRC expectations regarding Risk Assessment may be a significant problem (and, based on this forum,  even if they are familiar with, say, SQF).

 

The emphasis / viewpoint / philosophy in certain areas for different FS standards is IMO simply different, eg for BRC / SQF / IFS / ISO-FSSC22000.

 

BRC is additionally driven by due diligence considerations (from a UK POV), which IMO sometimes influences the Standard in directions other than Food Safety.

 

But the lucky 2 should at least be faced with a relatively Codex/ISO - friendly interpretation of Validation-Verification.

 

Rgds / Charles.C

 

PS - i particularly base my opinion on coming from a BRC background and observing the miscellany of SQF/ISO/IFS requirements on this forum. Sometimes it's like viewing another world, in both good/bad ways.

Edited by Charles.C, 28 January 2015 - 10:21 AM.
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