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Are corrective actions required for facility inspections?

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Don Haines

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Posted 28 April 2016 - 08:33 PM

We currently do an internal BRC audit annually but we do monthly facility inspections.  In a recent 3rd party audit we are being told that the facility inspections are audits and a CA needs to be entered for everything found.  I currently do not plan on entering corrective actions for a missing container label or some weeds too close to the building.  The inspections are sent to all supervisors and they are required to take care of the noted issues and report back as completed prior to the next inspection.  I am looking for others perspective on this issue.

 

Thanks,

Don



Watanka

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Posted 28 April 2016 - 09:04 PM

Don,

 

We are in the SQF scheme but as both SQF and BRC are bench-marked to the GFSI there should be more similarities than differences.  The relevant SQF section says:

2.5.7.1 The methods and responsibility for scheduling and conducting internal audits to verify the effectiveness of the SQF System including facility and equipment inspections, pre-requisite programs, food safety plans, food quality plans and legislative controls shall be documented and implemented. The methods applied shall ensure:
i. An internal audit schedule is prepared detailing the scope and frequency of internal audits;
ii. Correction and corrective action of deficiencies identified during the internal audits is undertaken;
iii. Audit results are communicated to relevant management personnel and staff responsible for implementing and verifying corrective actions; and
iv. Records of internal audits and any corrections and corrective action taken as a result of internal audits shall be maintained.

 

So corrections and corrective actions need to be documented.  The SQF guidance document defines the difference between corrections and corrective actions this way:

Corrections are considered a short term fix, i.e. a quick action taken to remediate a specific problem and make adjustments to regain immediate control. A corrective action is a long term fix designed to identify the root cause of the problem and to take actions that will prevent recurrence. This process is designed to minimize the risk that the situation will occur again.

 

It is likely that the vast majority of issues you find require corrections and should be handled in that way.  Logged into your monthly audit with a simple one sentence description of the issue, the correction, the date the correction was completed and by whom.  Trend analysis of issues or serious non-conformances can lead to corrective actions which require an in-depth investigation.  Simple GMP corrections should only require simple, concise documentation. 



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Don Haines

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Posted 28 April 2016 - 09:18 PM

Thanks for the quick response.  I agree with the above as it relates to internal audits 100 percent.  This auditor is saying facility inspections are audits and should be handled as such. SQF 2.5.7.1 as stated above makes a distinction between the two. How do you handle you facility inspections?



Watanka

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Posted 28 April 2016 - 10:12 PM

In order to slay two dragons for the price of one our facility inspections are conducted as an audit.  An interdisciplinary group (typically department managers or their designee) at each facility is gathered together monthly to inspect the facility.  While we inspect the facility I also take the time to audit the facility and its processes.  The essential difference, at least for me, is that an inspection is a set of observations of things and an audit is a review of procedures, processes and associated documentation.  I do not have time to conduct separate visits to our plants - one for an inspection the other for an audit. 

 

Hope this helps.



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Posted 04 May 2016 - 02:57 AM

I've always included facility inspections as part of a monthly GMP audit which then becomes part of a corrective action. True, the majority of minor site issues result in quick fixes and not corrective actions, at least it's then documented properly and can graphed if need be to show any ongoing problems. I personally agree with your auditor but that's just based on my own experiences


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GMO

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Posted 04 May 2016 - 05:00 AM

We had it raised on a recent BRC audit that we weren't doing root cause analysis on the issues found in facility inspections so over and above your corrective action point!  What we've decided to do, as we score our audits is that anything above a 1 point issue (which is a minor poor practice thing) will have root cause analysis.  We're trialling this now in one area to see how it goes.  Now I've got my head around it I actually agree with our auditor.  At the moment we do weekly inspections which we're thinking of reducing to monthly but doing them better.  Fact is, it is only monthly, is it really that much effort for them to tell you what they've done?  And even though we weren't doing it, is it really that much effort for people to think about root cause?  If they don't, how on earth are the corrective actions they do put in place going to be effective?



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Posted 04 May 2016 - 08:57 AM

FWIW, Corrective action does not have to be a big deal.

I do my facility inspections weekly (facility divided up into four areas, so entire facility is done once per month).

Findings are listed on the attached. Responsible department managers update me on completions weekly.

I have been using this form for years and years with never a raised eyebrow from any type of auditor.

 

Marshall

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Don Haines

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Posted 04 May 2016 - 01:25 PM

FWIW, Corrective action does not have to be a big deal.

I do my facility inspections weekly (facility divided up into four areas, so entire facility is done once per month).

Findings are listed on the attached. Responsible department managers update me on completions weekly.

I have been using this form for years and years with never a raised eyebrow from any type of auditor.

 

Marshall

Thanks to all, I guess to sum it up in my mind there are "actions" and there are "corrective actions" most of the things on our facility inspections we take "action" on but do not do a "corrective action". We do document when they are done.



GMO

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Posted 07 May 2016 - 12:59 PM

FWIW, Corrective action does not have to be a big deal.

I do my facility inspections weekly (facility divided up into four areas, so entire facility is done once per month).

Findings are listed on the attached. Responsible department managers update me on completions weekly.

I have been using this form for years and years with never a raised eyebrow from any type of auditor.

 

Marshall

 

Our BRC auditor would have raised an issue due to lack of root cause analysis on it.





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