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GMO

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Posted 27 August 2019 - 10:49 AM

Am I just getting old...?  I'm never one to say I have nothing left to learn but recently there feels like there has been an explosion of inexperienced auditors with a complete lack of pragmatism.  The kind who is not prepared to discuss anything.  The ones who endlessly refer back to the standard rather than thinking "is this genuinely a risk?"  Then you make conversation about experience and find they've spent two years in a mid level graduate quality job then gone straight to auditing.

 

I'm all in favour of a tough audit but a fair one too.  A poor auditor who raises a nothing issue as a major concern yet misses something in front of their face does nothing to improve standards and it devalues the audit in the eyes of the operations teams.

 

I feel like I've spent far too long this year saying "ok I agree with the final score of that audit but not how we got there".  Am I alone or am I just getting grumpier in my old age?



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Posted 27 August 2019 - 11:51 AM

GMO,I don't think you are alone.  I can't answer the second question.  :giggle: I know I AM getting grumpier.

 

I do think there is a level of Certifying Bodies being totally unprepared for the number of locations requiring audits and not doing diligence when hiring. I have heard stories about people walking into auditing roles like yours too many times. Couple that with the auditor's unrelenting schedule, I can see why there is turnover.


-Setanta         

 

 

 


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Posted 27 August 2019 - 01:12 PM

Absolutely not alone!!!  I don't want to have to do my job and the auditors too, and certainly don't want to waste my time arguing (apparently) obvious issues and mistakes..................this is what happens when you put the customers in charge of things they do not understand!! 

 

----my personal opinion of course-----

 

Like the old adage-----those who can do, those who can't teach (or audit in this case)


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Posted 27 August 2019 - 02:18 PM

I totally agree...it can get quite frustrating...especially when your team members start giving you these "glances" during audits...lol



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Posted 27 August 2019 - 02:28 PM

+1 for grumpier with age.

 

Actually not necessarily grumpier just suffer fools less and not afraid to say so. 

 

The kids hate it. 

:sofa1:


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Posted 27 August 2019 - 04:54 PM

Yes, there is an influx of inexperienced auditors, many of the experienced ones have left as the stress level of new requirements and accountability issues for errors have drastically increased.  When CB's focus on degrees more than experience this is what the result is.

 

I was fortunate that all my life's experiences contributed to being a firm but fair auditor, the issue is the current crop of auditors have little to no related or direct experience and many times even lack compassion.

 

The funny of the day for everyone -- I had a terrific work experience background coming into auditing food, packaging and logistic companies - the experiences and the experience in dealing with some nutso QA managers and owners made me an excellent Auditor.... the funny --- it was my FIRST audit that I ever did on my own way back 20 years ago, it was 8:58am and we were sitting in a conference room getting to review paperwork.... the QA Manager asked me when I started doing audits on food companies.... I look at my watch, looked at him and said 9:00am!

 

Yes, it was funny to me - he, on the other hand sat there in silence.

 

You had to be there!


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Posted 27 August 2019 - 07:55 PM

I guess I am lucky in that we basically cycle through two auditors. We get one guy for three years and then the next for three years.
They are both competent auditors that do audits two completely different ways. I'm also lucky in that I am usually present at one or two of the other facilities in our company when they have their audits.
I may see the same auditor two or three times each year, which builds rapport and of course, helps to get an idea on what he is "looking at" this year.

 

I'm hoping these two guys stay around for another 10 years when I might be thinking about retirement LOL.

 

Marshall



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Posted 27 August 2019 - 08:25 PM

I guess I am lucky in that we basically cycle through two auditors. We get one guy for three years and then the next for three years.
They are both competent auditors that do audits two completely different ways. I'm also lucky in that I am usually present at one or two of the other facilities in our company when they have their audits.
I may see the same auditor two or three times each year, which builds rapport and of course, helps to get an idea on what he is "looking at" this year.

 

I'm hoping these two guys stay around for another 10 years when I might be thinking about retirement LOL.

 

Marshall

 

That's nice! When I worked in food, we'd have 10-15 auditors a year with maybe 20-30% of them being auditors we'd see frequently. We had to ban an auditor from our facility, but seemingly not from a lack of experience (I think?). He was rather arrogant though, and would not listen to explanations while asking the same question over and over again. That made for a long and frustrating day.



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Posted 27 August 2019 - 08:28 PM

Of course I am only speaking about annual BRC audits here.
If  FDA walks in, or we are courting a customer that wants to do an audit, that's a whole different ballgame.

 

Marshall



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Posted 27 August 2019 - 09:54 PM

Frustrating, yes, but they have to start somewhere! I suspect if they weren't the ones filling the open jobs, the jobs would stay open. It's the lesser of two evils in my opinion.

 

Although, I suppose I'm biased because I'm a "newbie" myself  :lol2: Nothing I can do about it except learn day by day!



Charles.C

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Posted 27 August 2019 - 10:08 PM

Yes, there is an influx of inexperienced auditors, many of the experienced ones have left as the stress level of new requirements and accountability issues for errors have drastically increased.  When CB's focus on degrees more than experience this is what the result is.

 

I was fortunate that all my life's experiences contributed to being a firm but fair auditor, the issue is the current crop of auditors have little to no related or direct experience and many times even lack compassion.

 

The funny of the day for everyone -- I had a terrific work experience background coming into auditing food, packaging and logistic companies - the experiences and the experience in dealing with some nutso QA managers and owners made me an excellent Auditor.... the funny --- it was my FIRST audit that I ever did on my own way back 20 years ago, it was 8:58am and we were sitting in a conference room getting to review paperwork.... the QA Manager asked me when I started doing audits on food companies.... I look at my watch, looked at him and said 9:00am!

 

Yes, it was funny to me - he, on the other hand sat there in silence.

 

You had to be there!

 

Hi Glenn,

 

You were lucky to find a polite one.


Kind Regards,

 

Charles.C


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Posted 27 August 2019 - 10:17 PM

With all due respect to GMO, if the "standard" says "this", then that is what you have to meet.
If a new, or inexperienced auditor only has the "standard" to go by, well....it is what it is.

Those of us that have been around for a few years understand that "reality" and the "standard" can often be two different things. BUT, if the Standard is not the Standard because of reality for numerous different facilities, it's not really a "Standard" then, is it? It becomes some general guideline, which IMHO, defeats the purpose of a "Standard".

Now arrogance of an inexperienced auditor is a completely different animal.
That being said, If you are complying with the "Standard", then it's really a moot point who or what the auditor is.

I guess I see both points, and am often guilty of rolling eyes and making some comments that I probably should not when suffering through various third party customer audits.

 

Often times I just want to point the customer auditor to that framed cert on the wall that says "BRC Global Standard for Food A"...what more do you really want?

 

Marshall


Edited by mgourley, 27 August 2019 - 10:25 PM.


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Posted 28 August 2019 - 09:44 PM

This is truly a great topic, and some very valid opinions in the mix. Auditing is both a very rewarding, and very challenging choice of career. Yes, there are some less than desirable auditors out there, especially in programs where requirements are weak, and compliance work by both certification bodies and standard owners falls short of effective. Most in the industry have met with great and not so great auditors over our time.

 

Here are some thoughts to add to the mix:

 

- Auditor training, oversight and compliance is expensive. Where a facility seeks out least cost options in certification program and supplier, they tend to get the quality they pay for.

- We all have a role to play. When we are faced with an auditor who has some "opportunities to improve" we owe it to to the certification body to provide honest feedback, giving them the chance to improve the service being offered. There are even times when a site can help to improve an auditors performance. Anonymous complaining isn't being part of a solution.

- If the auditor is truly not qualified, call the certification body. If you aren't getting a valid response, all GFSI benchmarked programs have contact information.  I fully agree that two years experience doesn't cut it for an accredited certification audit. GFSI requires a minimum of 5 years experience for a benchmarked program auditor. If you want a higher level auditor, move to a higher level Standard that delivers.

- Go for quality, and be demanding. Be clear when seeking a certification provider you want a challenging, well qualified and informed auditor.

- Don't be afraid to debate with the auditor. A good auditor appreciates a valid challenge to ensure they are providing value during the audit. If they miss something, they want to know.

 

Limited auditor resources are an issue, no question. It's up tot he industry to help get more people into auditing, and support the development of food safety professionals so we can rely on our audits to deliver what is intended.

 

Great topic GMO, and those who commented.

 

John



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Posted 28 August 2019 - 10:11 PM

John,

 

Thanks for chiming in. It's a big deal getting comments from you.

A few years ago I considered getting into auditing as a change from the daily grind at a food facility.

I decided not only no, but hell no. I could not imagine doing it. Auditors are a rare breed, and I always learn things from the really good ones.

 

Marshall



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Posted 29 August 2019 - 03:10 AM

ISO 17021 clearly states in 7.2.2: "The certification body shall employ, or have access to, a sufficient number of auditors, including audit team leaders, and technical experts to cover all of its activities and to handle the volume of audit work performed".

IMO, it is fine if an Auditor doesn't have enough knowledge or experiences in specific domains as long as she/he's got some wise person to consult during the audit. I've seen that auditors are often overconfident of their ability. They think their training on Standards suffices. Most CBs don't consider this, especially with popular/"mediocre" ISO standards, ex. 9001.

It's ofc all the cases. I admire the competence of BRC Auditor of my company. She's smart and knows herself well. She's also learnt and shared several things while auditing us.

Meanwhile, in our last ISO 14001 audit, the CB sent 2 auditors graduated in electricity and biology. I just facepalmed because our major concern is chemicals. 



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Posted 29 August 2019 - 08:16 AM

This is getting rather OT but, as a corollary to Marshall's post 12,  I suggest that communicative problems with auditors can not only be due to the latter's intrinsic personality characteristics/technical background but may also be driven by external considerations, for example - (a) "other" factors which may have negatively affected (or restrict) the auditor's basic training and subsequent audit activities, (b) the auditee/facility's own limitations. Sometimes (a,b) can occur simultaneously.  A few possible examples -

 

(1) The FS Code/Standard (or the, theoretically, audit-independent Guidelines) has specific "defects", eg ambiguities, incomprehensibilities, known or otherwise. Such defects can readily generate conflict. Numerous threads on this Forum illustrate various examples where well-documented defects have still proven capable to survive the test of time. IMO, this problem is exacerbated by  the Standards themselves becoming, IMO, proportionately more and more complicated with each revision.

 

(2) Particularly for first-time audits, some auditees find themselves placed, knowingly or otherwise, in an audit situation likely to result in numerous, non-minor,  non-compliances. This is often a typical result  where Top Management simply has no clue as to what successful Certification actually demands and has consequently  avoided supplying appropriate Resources. I am amazed that Companies seem to often decline an opportunity to undergo initial "trial" audits.

 

(3) Obtaining a successful Certification has, nowadays, often become a  Critical Business requirement. For the responsible auditee, the consequences of failure can be significant. The result can be a highly stressed/confrontational situation.

 

Apologies in advance for the levity but perhaps this illustrates some of the difficulties of the auditorial profession ?


Kind Regards,

 

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Posted 29 August 2019 - 12:41 PM

This is getting rather OT but, as a corollary to Marshall's post 12,  I suggest that communicative problems with auditors can not only be due to the latter's intrinsic personality characteristics/technical background but may also be driven by external considerations, for example - (a) "other" factors which may have negatively affected (or restrict) the auditor's basic training and subsequent audit activities, (b) the auditee/facility's own limitations. Sometimes (a,b) can occur simultaneously.  A few possible examples -

 

(1) The FS Code/Standard (or the, theoretically, audit-independent Guidelines) has specific "defects", eg ambiguities, incomprehensibilities, known or otherwise. Such defects can readily generate conflict. Numerous threads on this Forum illustrate various examples where well-documented defects have still proven capable to survive the test of time. IMO, this problem is exacerbated by  the Standards themselves becoming, IMO, proportionately more and more complicated with each revision.

 

(2) Particularly for first-time audits, some auditees find themselves placed, knowingly or otherwise, in an audit situation likely to result in numerous, non-minor,  non-compliances. This is often a typical result  where Top Management simply has no clue as to what successful Certification actually demands and has consequently  avoided supplying appropriate Resources. I am amazed that Companies seem to often decline an opportunity to undergo initial "trial" audits.

 

(3) Obtaining a successful Certification has, nowadays, often become a  Critical Business requirement. For the responsible auditee, the consequences of failure can be significant. The result can be a highly stressed/confrontational situation.

 

Apologies in advance for the levity but perhaps this illustrates some of the difficulties of the auditorial profession ?

 

Very true. Sometimes it's hard to see it from both sides. I have done supplier audits for previous companies, but no GFSI or other certification standards. It's nice to see other people's processes, but at the same time, as an auditor I was stressed because I could see the auditees really didn't want to do the audits and it showed in their behavior. On the flipside, as an auditee, It is hard to get a day's work done on a regular schedule; even less when you have to dedicate a full day or more to an audit. It's a part of the business, and I try to show compassion to auditors (within reason). I will become disagreeable when an auditor is not auditing to the letter of the law, and is just auditing to opinions. 

 

To your point #1, Charles. I definitely agree with that statement. We have had auditors that work with multiple standards, and have confused the standards to the point of attempting to give us non-conformances. One technical manager actually had audited to SQF and BRC previously, and was trying to use an SQF standard to audit against, which didn't actually apply to BRC. That was infuriating because he became really argumentative, but then I asked him to show me in the BRC manual where it said we should have any such policy. After glancing he realized he was talking about SQF and did actually apologize (but not after yelling first).

 

Point #3. Absolutely this as well. No one wants to have a low-grade on their certification; or even worse, to fail. So much of our business rides on certification, that people will become confrontational to make something they know is wrong, try to be justifiable when they know they can't even justify it. 



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Posted 29 August 2019 - 03:20 PM

With all due respect to GMO, if the "standard" says "this", then that is what you have to meet.
If a new, or inexperienced auditor only has the "standard" to go by, well....it is what it is.
 

 

That's just really not true. The "standard" doesn't speak for itself. It is merely writing, and it was written by human beings, and must be interpreted by (hopefully competent) human beings. Assuming that "if the standard says this, then that is what you have to meet" regardless of the experience or expertise of the auditor is like imagining that "the law says this" and then there is no need for courts or appeals or actual justice. 


Edited by kettlecorn, 29 August 2019 - 03:21 PM.


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Posted 29 August 2019 - 03:42 PM

That's just really not true. The "standard" doesn't speak for itself. It is merely writing, and it was written by human beings, and must be interpreted by (hopefully competent) human beings. Assuming that "if the standard says this, then that is what you have to meet" regardless of the experience or expertise of the auditor is like imagining that "the law says this" and then there is no need for courts or appeals or actual justice. 

 

This could end up being an interesting debate. The standard does have to speak for itself to some extent (hopefully a large extent). Yes, there are certain items that are open to interpretation (because every process is different and the standard can't 100% account for everything), and for those, you probably have risk assessments or some kind of justification analysis as to how the process meets the standard. If the auditor still feels your process doesn't meet the standard, they have to justify why it doesn't. If there's still a disagreement, sure there can be an appeal. 

 

BRC has an "interpretation guide" because the standard doesn't really speak very well for itself...but interestingly enough, I found out through the forums sometime ago that the interpretation guide isn't even an auditable document. Therefore, referencing the guide doesn't really mean anything to an auditor, and to them, the standard is the standard. The goal is to ensure your procedures meet the intent of the clauses within the standard. 

 

The bigger problem is with auditors auditing to their opinions, and not following the standard. I have a problem when an auditor says "well I think you should do it this way...". Everyone does things their own way, and audits aren't consultations. IF you are seeing an issue with my process which could cause hazard or non-conformance, it can be listed as an observation. If you don't like the way I dot my "i" and cross my "t", that isn't a non-conformance, and we're going to have a discussion.



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Posted 30 August 2019 - 09:00 AM

With all due respect to GMO, if the "standard" says "this", then that is what you have to meet.
 

 

Well it never is though is it.  The standard is always open to interpretation.  Whether or not something constitutes a risk to food is fairly simple to work out (to my mind) yet to some more recent auditors it is not.

 

I remember being the same when I was green around the gills but I cut my teeth on internal audits and had the arguments there.  I look back now and cringe at some of the things I was claiming to be a major issue.

 

I think to say the standard is the standard is very naïve.  I'm sure we've all got into discussions around whether something does or does not meet a clause.  One thing I learned very early in my career (and some of these auditors have not) is that just because it's not the way you would do it, doesn't mean it's wrong.

 

An example.  In one CB there was some pen on some equipment above food contact.  This pen was there to mark where a screw had been removed.  It was permanent pen, no liquid was running over it to result in contamination of the food below but the auditor said this was an issue (and didn't raise it as a minor either).  What standard says that's wrong?  Any takers...?



GMO

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Posted 30 August 2019 - 09:07 AM

BRC has an "interpretation guide" because the standard doesn't really speak very well for itself...but interestingly enough, I found out through the forums sometime ago that the interpretation guide isn't even an auditable document. Therefore, referencing the guide doesn't really mean anything to an auditor, and to them, the standard is the standard. The goal is to ensure your procedures meet the intent of the clauses within the standard. 

 

Ah... I have a story about that.  A BRC auditor once tried to raise something I thought was incorrect.  I showed him the interpretation guideline to explain why we'd taken the action we'd taken, he literally threw his hands up in the air and shouted "I do not audit against the interpretation guideline!"

 

He didn't raise it though (knowing full well we'd appeal...)



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Posted 30 August 2019 - 01:01 PM

Ah... I have a story about that.  A BRC auditor once tried to raise something I thought was incorrect.  I showed him the interpretation guideline to explain why we'd taken the action we'd taken, he literally threw his hands up in the air and shouted "I do not audit against the interpretation guideline!"

 

He didn't raise it though (knowing full well we'd appeal...)

 

I'll never understand why BRC provides a guide we can't use for justification. Just make the standard clear so we don't have to use an entirely separate book to understand the clauses.



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Posted 30 August 2019 - 01:33 PM

I'll never understand why BRC provides a guide we can't use for justification. Just make the standard clear so we don't have to use an entirely separate book to understand the clauses.

I had this debate with a BRC auditor just last week - if the interpretation guide isn't the definitive guide to interpretation then it's got no more value than the ideas floated in an internet forum. Indeed arguably less, given that much of the information shared here is the product of considerable experience.
Thankfully in this case the auditor was sensible (IMO) in the application of the standard, but we all know that getting the pragmatic auditor isn't something on which we want to have to rely...

 

 

I think to say the standard is the standard is very naïve. 

 

I fully agree with this sentiment (it's not dissimilar to the spirit vs. letter of the law differentiation), but alas it isn't a view shared by all auditors IMEX - I distinctly remember an auditor we had for BRC for several years saying at various points in every audit: "The standard says x so show me your document that says 'we do x' or I can't verify conformity". It's difficult to avoid the inference that in his view the purpose of the standard isn't to be interpreted by the site to be applied appropriately for their products and activities, but is instead perhaps just to be copied verbatim with every instance of "the site shall..." being replaced with "The company does..." or equivalent.

 

Whilst I recognise many of the grumbles in this thread and have certainly "enjoyed" my fare share of interesting certification audits, I do have to say it's nothing compared to some of the auditors that customers have sent - the absence of a process to verify the suitability of auditors for a given scope really shows, and just because they're experienced in their industry area really does not mean that can be translated into a completely dissimilar product/process type.

I can think of several examples, but my favourite is perhaps the auditor sent by a very large international brand owner, who said something to the effect of:

I know that you have provided evidence for the basis of your environmental monitoring program, but it doesn't meet the requirements for our own production (a vastly different and considerably higher risk product/process) and I don't understand your products or process well enough to assess it, so I'm giving you a non-conformance and a more knowledgeable colleague will then review your response.

 

If you freely acknowledge that you don't understand the product or the process then what the dickens are you doing auditing it?! :rolleyes:



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Posted 31 August 2019 - 09:21 AM

Hi pHruit,

 

I fully agree with this sentiment (it's not dissimilar to the spirit vs. letter of the law differentiation), but alas it isn't a view shared by all auditors IMEX - I distinctly remember an auditor we had for BRC for several years saying at various points in every audit: "The standard says x so show me your document that says 'we do x' or I can't verify conformity". It's difficult to avoid the inference that in his view the purpose of the standard isn't to be interpreted by the site to be applied appropriately for their products and activities, but is instead perhaps just to be copied verbatim with every instance of "the site shall..." being replaced with "The company does..." or equivalent

.

^ Red. From an auditor's POV,  I think such has always been their basic Objective where "x" is a "specific" request. Unfortunately the Standard(s) is also awash with non-specifically answerable Clauses. iso9001 hit the interp. problem a few decades back. :smile:

I agree in Principle with Marshall however I suggest that  the Standard has now attained such an enormous  Scope/Complexity  that achieving "clarity" in a finite volume has become impossible. Hence the inevitability of an Interpretation Guide. The latter seems invariably interesting to read but IMO remains seriously lacking on certain important aspects. I suspect the latter is sometimes to protect auditors where subjectivity/contention is known to be likely to occur. And maybe also due fears (well-founded ?) of direct plagiarism.

(BRC itself also maybe has it's own "SITC" since afaik  it is also expected to "cover" UK's legal due diligence requirements).

 

PS - skeleton in the closet


Kind Regards,

 

Charles.C


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Posted 31 August 2019 - 10:31 AM

Just staying with BRC for a moment... It's a "Global Standard for Food Safety".

 

How impossible is that given the different types of food manufactured in so many different facilities is so many different countries? 

That being said, I've been audited to the BRC Standard for almost 10 years. I have yet to find anything in the Standard that is egregious or impossible to meet. Thus my statement about if it's in the Standard that's what you have to meet. 
The Standard does not say "how' you have to do something to meet the intent of whatever clause. It just says you have to do "something" to show you are complying.

 

So we come full circle to the OP. Auditors are not supposed to have opinions as to whether or not the things a facility does to comply meet "their" interpretation of the Standard.

Again, the Standard is what it is (as imperfect or ambiguous as it may be). It's the only constant in the equation. Auditors, on the other hand are the variable.

 

Marshall





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