9 replies to this topic

[JWebster]

Hello All,

 

This is my first time posting on this forum, but I've used it for years to help develop and improve my Food Safety plan.  I had my first BRC version 8 audit this week, and it went worse than I had hoped.  One non-conformance really frustrates me and I wanted to get other opinions on it.  During review of section 3.7-Corrective and Preventative actions, the auditor asked to see an example of non-conformances found and corrected over the year.  In one example, we had a staff member retire, and as a result, there was a gap in the completion of a documented check he completed (For section 4.9.2).  We had found this issue internally, corrected it and put in a plan to prevent the issue moving forward.  We had all the documentation required for this corrective/preventative action.  However, due to there being a gap in the completion of this record, the auditor issued a non-conformance on clause 4.9.2.1.  Stating "The site did not have records of knife inspections from 12/16-12/20".  

 

My question is, can a non-conformance be issued for something we have already found and corrected on our own?

 

Is this something we should appeal?

 

Thanks,

 

Jerod

[The Food Scientist]

Not a BRC user but I would imagine all GFSI is similar when it comes to this. hmm I mean that's strange. You found the issue and corrected it with Corrective actions. (I mean isn't that the point of corrective action?) It is not like you did not correct it and made a preventive measure. 

 

But I guess the auditor would still issue a Non-conformance for the records not being there. Because during that time they would've been a food safety issue affected by lack of records.

 

Did you discuss with your auditor about this? I would've definitely discussed it during the closing meeting.

[SQFconsultant]

when you say you corrected the issue did not involved filling out for those dates, or were they still left open?  Did you paperwork to show knife inspections prior to and after the gap?

[JWebster]

We did not go back and fill in the gap. There were records of checks before and after, we documented the non conformance and correction.

[Charles.C]

Hello All,

 

This is my first time posting on this forum, but I've used it for years to help develop and improve my Food Safety plan.  I had my first BRC version 8 audit this week, and it went worse than I had hoped.  One non-conformance really frustrates me and I wanted to get other opinions on it.  During review of section 3.7-Corrective and Preventative actions, the auditor asked to see an example of non-conformances found and corrected over the year.  In one example, we had a staff member retire, and as a result, there was a gap in the completion of a documented check he completed (For section 4.9.2).  We had found this issue internally, corrected it and put in a plan to prevent the issue moving forward.  We had all the documentation required for this corrective/preventative action.  However, due to there being a gap in the completion of this record, the auditor issued a non-conformance on clause 4.9.2.1.  Stating "The site did not have records of knife inspections from 12/16-12/20".  

 

My question is, can a non-conformance be issued for something we have already found and corrected on our own?

 

Is this something we should appeal?

 

Thanks,

 

Jerod

 

Hi Jerod,

 

I speculate this may not have been a purely Documentation Issue albeit marked against 4.9.2.1.

 

Just as a (HACCP) example, it is not unheard of that, due to "human/equipment error", validation of a metal detector is occasionally omitted as stated in its associated Procedure, eg every hour/beginning of new lot etc.

The result is often a loss of control for a CCP which is an immediate Safety Issue.

 

The typical haccp Corrective Action for above includes -

 

(1) an operational requirement to segregate all the material produced in the relevant time span and

(2)  re-inspect the material in (2).

(3) appropriate training/maintenance/whatever  to prevent further similar errors (eg Root Cause factor{s])

 

Perhaps  yr Corrective Action may have either textually omitted activities such as  (1,2)  or, if present, such actions were operationally  not carried out, ?? 

 

Hence perhaps the auditor NC although was maybe better positioned as against 3.7

 

PS - assuming this issue did involve a CCP, also sounds like yr HACCP Verification Procedure may have have broken down or has an excessive delay time ?.

 

PPS -  from a purely Documentation aspect  some previous "omission" posts here (SQF IIRC)(although not  associated with an actual incident) were recommended to be handled by an internal correction procedure similar to yr own methodology.

Edited by Charles.C, 19 January 2020 - 02:01 PM.
amended

[FurFarmandFork]

Ditto Charles. If at the end of the day your NC said "oh this is why it happened so it won't happen again" but did not provide evidence that you ensured the absence of those records did not pose an unacceptable food safety risk, it is really just evidence you found missing records and said "yep, they're missing".

 

Often when I had missing records I would file away blank ones that referenced the non-conformance so that they were "there" and referenced why they were incomplete and the justification or reprocessing used to make sure it was okay. Thus, "records are available".

[AHJ]

You should appeal it anyways. That is one thing I have learned in my last audit, the appeal process was not as difficult as I intended it to be and it certainly worked out far better than I intended it to.

 

We filed an appeal for the first time this past year and even we didn't completely agree on every point we made in the appeal but senior management insisted we attempt to appeal as many as possible because our score was 12 points lower than the previous year and even lower than our original score on our first audit. We have only gotten better at our SQF programs, every aspect of our company seemed to have improved over the past 3 years there was no way we scored so low. Senior management was completely right we got 9 points back, every point we contested on the appeal was granted back to us. (I think this says more about the auditor than our company... there seems to be such drastic fluctuations between auditors as far as interpreting the code) 

 

In general, there's only good to come from an appeal, it can't be held against you if you win or lose as far as the CB goes. If you win you get a higher score and if you lose you have a second opinion; if there are more people declaring the finding a problem the company has more motivation to fix it sooner and allocate sufficient funds to fix it properly. 

Edited by AHJ, 21 January 2020 - 12:28 PM.

[SQFconsultant]

What AHJ said...

 

"In general, there's only good to come from an appeal, it can't be held against you if you win or lose as far as the CB goes."

 

... is absolutely correct and there is a general feeling that if a person appeals an Auditor finding that it will come back to get them in the future - this is so not true.  

 

As a former SQF Auditor I had a couple of challenges and I saw them as opportunities either for my own improvement or for the company improvement and never once did I nor any other Auditor I worked with see a challenge as something to be held against the challenger win or lose.

 

As to the original poster - you have grounds for challenging the finding, I find the Auditor to be very much over the top here, this was truly a miss-call.  You had a situation, you identified the issue, you instituted a corrective action and you monitored going forward - everything is perfect there.

 

So, please do challenge the finding - it will lead to an Auditor being improved as well as your company getting this one back.

[Hoosiersmoker]

Isn't there a "5 strikes and you're out" policy for auditors??? I can see confusion over one or two areas of concern but 9 in one audit seems more than excessive to me. That seems to hinge on irresponsible or uneducated in auditing. An SQF practitioner has to be able to demonstrate proficiency and knowledge of their specific code... doesn't an auditor?

[Bo16]

I agree, but one of the issues addressed in all our non-conformance documents (we call this an unplanned deviation) is the effect on any product manufactured during the excursion from standard practices and the disposition of each lot/line.  We also put a copy of the deviation (if possible) or  at minimum a entry of the deviation number into the document/logbook etc. where the documentation should be.  This way there is never "missing" documentation.