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