I have a question regarding this topic.
The element reads as follows: 22.214.171.124 On-site personnel that conduct environmental or product testing shall participate in an applicable proficiency testing program at least annually to ensure accuracy of results.
One of the plants that I oversee, received a non-conformance against this element. I did not agree with the auditor and of course he did not even give me the opportunity to argue/debate the issue. Basically he said, that is what the code says, therefore we must comply.
The point I was trying to make: we are certified for the food safety part of the code and not quality. So, all of our testing, environmental, peanut testing, allergen verification is being tested by accredited external labs. The only testing we complete in house are: moisture and bricks. They are strictly for quality and not food safety. I should say the product is hard candy with a very low water activity.
This was not mentioned in any of our other plants because there are allergen tests that we actually do in house and they are being validated annually via proficiency test. I don't believe this should have been a non-conformance due to the fact it is a quality test and we were not going after the quality certification. Truth be told, to correct this non-conformance would have taken likely less time than it took me to write this message but it is the point and I am interested in other opinions.
Any insight anyone can provide would be appreciated.