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Audit Interpretation for HACCP Step Not Operating During Audit

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NPE Produce Consulting

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Posted 17 September 2018 - 06:24 PM

I work in the fresh produce industry and have clients with apple and peach packing lines that have many many drops, e.g. different sizes, different pack styles, etc.

 

I have an auditor down scoring a HACCP audit due to a bagger not operating (the bagger is one out of approximately 20 options for the peaches to drop to) at the time of the audit.

 

There is not a CCP in the plan so the HACCP questions are so few that a major down score has a big impact on the audit score.

 

Any thoughts on how this situation should be scored from an auditor's perspective?

 

Any insights are appreciated.



012117

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Posted 18 September 2018 - 09:10 AM

Depending on what I saw during the audit. If the missing bagger entail higher risks that what is supposed to be during its presence that it could be agreeable with the lower score. If there is not so much (e.g. if its only paper trail or the method of opening and conveying is the same(, then it is another story. Always associate with risks involved.



Scampi

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Posted 18 September 2018 - 04:29 PM

what impact does a machine not operating at the time of the audit have on the haccp plan?  Machines break or are not needed all the time

 

I'm trying to understand your question better

 

Can you elaborate?

 

We are seasonal and were not running when my auditor arrived so if I follow what you're saying, i should have taken a hit because my machines weren't running??


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NPE Produce Consulting

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Posted 19 September 2018 - 06:07 PM

Specifically a line was running in which 15 drops were sending various size peaches to hand packing stations.  1 drop going to a bagger was not operating at the time of the audit because they were not packing bags.  The bagger is a process flow step.  The auditor took points off of the audit because the bagger was on the flow chart but it was not running the day of the audit.  It is bolted to the packing line.



Scampi

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Posted 19 September 2018 - 08:04 PM

crap crap crapity crap

 

If the auditor had any understanding of HACCP (done correctly) or manufacturing of food they never would have even mentioned it

 

So your auditor would be telling me that as of today I would have no process flow because we are seasonal and not currently running???

 

Sorry, but your auditor sounds like an imbecile to me

 

Come on, you're smarter than this----


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Charles.C

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Posted 20 September 2018 - 02:23 AM

It depends.

 

FS Standard = ??

 

Clause = ??


Kind Regards,

 

Charles.C


Brendan Triplett

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Posted 20 September 2018 - 01:02 PM

NPE,

 

It appears to me that the auditor was getting you on a technicality.  He is saying that he sees the bagger on your flow as a permanent step that must be followed through on your HACCP Plan.  When he saw that an entire step was skipped then he questioned the accuracy of you product flow and therefore the accuracy of your plan.  It is a big leap but as an auditor you are kind of pushed in the direction of following a fault to its source and I believe that he believes that the source was the inaccuracy of your plan versus what the actual flow is in your plant.  It is VERY convoluted and mostly incorrect.  Mark on your process flow (in the section for the bagger and any other areas that apply) that they are seasonal and are not operated at all times.  It should be marked to the side as a possible step that does not always occur.  This way he wont mark it as inaccurate.

 

As for HACCP, I agree with Scampi, if it does not have an impact on the product or the food safe operations than it should not be an issue otherwise we would all get marked for not running all of our equipment at the same instant an auditor walks through a room.  It is just not practical.  The auditor got you on this one for something goofy.  The upside is that it should be an easy fix and quick to get a corrective action plan together to fix it.


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Brendan Triplett


Scampi

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Posted 20 September 2018 - 01:45 PM

Charles

 

This doesn't depend........if a piece of equipment wasn't being used on that day but will be tomorrow then why should it be removed from the flow????  Under what standard would this actually be a requirement?

 

I stand firm on this one............the reason we are all getting frustrated with auditors is auditors like this one not fully understanding basic HACCP and talking without thinking.......

 

The crux of this matter is a step wasn't being missed.........it simply wasn't being used.....and to even hint at a non conformance is ludicrous


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Timwoodbag

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Posted 14 May 2019 - 09:03 PM

Under SQF 7.2 we had Opportunities for Improvement for things like this, where you forgot to put the word (optional) under bagging, and you can add it in later that night.  Our auditor said he is unsure under SQF 8 if he will be giving out more minors, or stop helping people with small errors like that, because then he would have to mark them if he mentions them.  



John_E

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Posted 14 May 2019 - 09:08 PM

Auditors cannot and should not expect every product or line to be running during an audit.

 

You should contest the finding higher up in their organization.



Charles.C

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Posted 14 May 2019 - 09:53 PM

IMEX (not SQF) if the flow chart is not matching the actual process it has been a NC, simple as that.


Kind Regards,

 

Charles.C




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