BRC 3.4 and ISO 4.14 - Independent Auditor
Good Morning, I have a question concerning BRC 3.4 and ISO 4.14
BRC 3.4.2
Internal audits shall be carried out by appropriately trained, competent auditors. Auditors shall be independent (i.e. not audit their own work).
ISO 4.14 Such audits shall be carried out by trained and qualified personnel who are, wherever
resources permit, independent of the activity to be audited.
As the QA Manager, I do not do any tasks the QA Technicians do and QA Technician don't do what I am doing. I asked the BRC Internal Auditor trainer if I could audit the QA Technicians and she said that I would not be independent. On the other side, I asked the ISO17025 Internal Auditor Trainer and he said that I can audit the QA Technicians. The trainer need to be qualified, which means that they must have some laboratory knowledge. Many SOP are internlink and reflect both BRC and ISO requirements. If I do the audit, BRC might say I am not independent, but as per ISO, I am the only one that could do the audit.
I also have another concern, I don't think that other department will want or take the time to do proper audits.
What are your thoughts?
Thank you
Hi Remi,
The BRC Internal Audit Trainer is correct 'Internal auditors may not audit their own work or programmes they are immediately responsible for' (BRC Guidance).
This is a problem many people encounter. Ideally you need to get Senior Management on board and get more trained Internal Auditors. If they are reluctant to help then point out the requirements of the standard and the risk of being pulled up with a Non-compliance.
Kind regards,
Tony
The issue is that the QA Techs report to you so you are not completely independent.
Hello Remi,
It's valid for the department(s) where you are responsible or working for. That raises some practical questions indeed.
The challenge is to find a good auditor to audit your department. This new auditor, can't consequently audit his or her department.
Kind regards,
Gerard Heerkens
It's tricky. For the HACCP plan, someone who directly or indirectly reports into me does audit that plan but I have no-one else with the skills and independence to do it. I could pay lipservice to it and have someone with HACCP level 2 from production auditing one site and vice versa but in reality what will they pick up? 5 tenths of b*gger all. I've never had anyone raise this as an issue but I could understand if they did. Likewise though I'd need someone at least trained to Level 3 who isn't in the HACCP team already which is a massive waste of money.
That's why people contract ME!!!!!
Can a HACCP Team Member perform the internal audit on BRC sec 2 The Food Safety Plan- HACCP, if they are only listed as backup to the HACCP Manager and haven't performed any of the writing per say or signed off on any of the records for the program?
Thanks,
Hello Remi,
It's valid for the department(s) where you are responsible or working for. That raises some practical questions indeed.
The challenge is to find a good auditor to audit your department. This new auditor, can't consequently audit his or her department.
Kind regards,
Gerard Heerkens
It's tricky. For the HACCP plan, someone who directly or indirectly reports into me does audit that plan but I have no-one else with the skills and independence to do it. I could pay lipservice to it and have someone with HACCP level 2 from production auditing one site and vice versa but in reality what will they pick up? 5 tenths of b*gger all. I've never had anyone raise this as an issue but I could understand if they did. Likewise though I'd need someone at least trained to Level 3 who isn't in the HACCP team already which is a massive waste of money.
Pretty much exactly the same experience here - anyone who is sufficiently trained/experienced reports to me, either directly or through line managers who themselves report into me.
My experience has been that BRC auditors are relatively pragmatic about the application of this clause in the context of the size of the company they're auditing - if you're a large business then it is far more feasible to have someone with appropriate skills and training who is sufficiently "independent", but the expectation seems to be less clear-cut in businesses with fewer staff.
The BRC Internal Audit Trainer is correct 'Internal auditors may not audit their own work or programmes they are immediately responsible for' (BRC Guidance).
I'd argue they are not immediately responsible but ultimately accountable. I've never had an issue with an external auditor with me auditing work of people who work for me. Otherwise you rule out a really valuable resource in auditing.
Can a HACCP Team Member perform the internal audit on BRC sec 2 The Food Safety Plan- HACCP, if they are only listed as backup to the HACCP Manager and haven't performed any of the writing per say or signed off on any of the records for the program?
Thanks,
I would say no. Basically you'd be arguing that you didn't have any material contribution to the HACCP plan to make you independent but then it will look to the auditor like it was a single person who wrote the plan or a limited team which doesn't look good either. To my mind the auditor of the HACCP plan can't be part of the HACCP team as you've been in the room when decisions have been made on the plan. You need independent oversight that those decisions were justifiable.
Just realised this is a zombie thread.... :eek_yello: