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Internal Audit: If CCP Records are unavailable is this a failure?


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#1 dbusch

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Posted 17 June 2020 - 05:40 PM

If CCP records covering several weeks were unavailable to an (internal) auditor, would this be an automatic failure of the internal audit?



#2 Charles.C

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Posted 17 June 2020 - 06:27 PM

If CCP records covering several weeks were unavailable to an (internal) auditor, would this be an automatic failure of the internal audit?

It would mean that the Haccp portion of the FS System has collapsed.


Kind Regards,

 

Charles.C


#3 dbusch

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Posted 17 June 2020 - 06:33 PM

The records were originally completed, but an untrained, previous employee discarded the folder containing the records.



#4 Charles.C

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Posted 17 June 2020 - 06:42 PM

The records were originally completed, but an untrained, previous employee discarded the folder containing the records.

Unfortunately, from an auditorial POV, seeing is believing.

 

It's not a unique situation, there are a few analogous disasters in other threads here, eg metal detector failure so no data records for period XYZ.


Kind Regards,

 

Charles.C


#5 dbusch

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Posted 17 June 2020 - 06:47 PM

Yes, sir! I'm on board with you there. :) My question is, would this be an automatic failure in a BRC Storage & Distribution audit? (I have given a Major in the QMS, Document Management (retrieval), requirement 3.1.3.2, but am wondering if it would be enough to issue a failure of the entire audit?



#6 Charles.C

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Posted 17 June 2020 - 07:04 PM

Yes, sir! I'm on board with you there. :) My question is, would this be an automatic failure in a BRC Storage & Distribution audit? (I have given a Major in the QMS, Document Management (retrieval), requirement 3.1.3.2, but am wondering if it would be enough to issue a failure of the entire audit?

 

I presume the material produced within the period of lost data is unavailable to re-sample/evaluate ?

 

 

It likely depends on BRC's interpretation of a Critical NC, ie "Where there is a critical failure to comply with a food safety or legal issue"

 

I was unable to find any explanation/examples of above in the Standard or I.Guidelines. Maybe there is some  info. on BRC Participate ?.

 

May also depend on what the CCP (or CCPs) was related to ?


Edited by Charles.C, 17 June 2020 - 07:11 PM.
added

Kind Regards,

 

Charles.C


#7 dbusch

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Posted 17 June 2020 - 07:10 PM

Yes, product was blast frozen and shipped last quarter. I have the BRC Storage &  Distribution Standards and Interpretation Guide. Been all over BRCGS websites including Participate. Can't seem to find an answer. Thank you for taking the time to respond. I will leave it as a Major in my internal audit and move on, since there are no Fundamentals wherein a Major would be an automatic failure, unlike the BRC Food Safety Standard.  :spoton:


Edited by dbusch, 17 June 2020 - 07:11 PM.


#8 Charles.C

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Posted 17 June 2020 - 07:32 PM

Yes, product was blast frozen and shipped last quarter. I have the BRC Storage &  Distribution Standards and Interpretation Guide. Been all over BRCGS websites including Participate. Can't seem to find an answer. Thank you for taking the time to respond. I will leave it as a Major in my internal audit and move on, since there are no Fundamentals wherein a Major would be an automatic failure, unlike the BRC Food Safety Standard.  :spoton:

Also see these threads but they do not exactly resolve the quandary. Maybe nobody has ever received a critical NC ?. Hope so.

 

https://www.ifsqn.co...nce/#entry36075

https://www.ifsqn.co...nce/#entry98537

 

( the quoted comments in Post 2 of first link maybe offers a ray of hope although I suspect this was a SQF audit )


Kind Regards,

 

Charles.C


#9 dbusch

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Posted 17 June 2020 - 07:41 PM

Thanks, Charles! This helps. It would fall under Major Non Conformance - Failure of a system or process that could lead to a breach of food safety. I appreciate your responses.



#10 SQFconsultant

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Posted 17 June 2020 - 07:52 PM

I once did an audit at a dairy, well, actually I was to have done the audit, but I was in and out in about 10 minutes.

 

I sat down to review their FSMS/HACCP documentation and the VP of the company indicated their QA Manager walked and took the entire 10 binders with him and was never heard from again... three weeks prior.

 

No backup - only paper.

 

Do you not have backup?


Kind regards,
Glenn Oster
 
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Diverse Organic Microgreens & Two Cows Make Cheese | HempWorx | Internal Auditor Training | Remote SQF-GAP Analysis
 

 

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#11 dbusch

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Posted 17 June 2020 - 08:08 PM

Did the audit only last 10 minutes due to the lack of CCP records? No, we don't have backups, but I'm going to implement a new policy that in this particular CCP they scan their daily records to me.



#12 QM-OS

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Posted 18 June 2020 - 10:56 AM

We got non-conformance at an internal audit when the control scale's computer program malfunctioned when the auditor was going to check the lists of registrered weights.

This is not a CCP step, so I guess it's very likely that your case is also a non-conformance, since it involves a CCP.



#13 SQFconsultant

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Posted 18 June 2020 - 12:33 PM

Did the audit only last 10 minutes due to the lack of CCP records? No, we don't have backups, but I'm going to implement a new policy that in this particular CCP they scan their daily records to me.

 

Good morning --

 

There was no audit, 10 minutes was basically taken to call my company and then call the QA vp at the supermarket chain I was doing the audit for and we all had a cup of coffee - since they had nothing, zip, nada they were suspended by the chain and I went back about 2 months later and conducted the audit and they passed with flying colors.

 

At minimum we tell our clients to have copies of everything electronically backed up and off-site back up such as a food safety software system - lots of stuff can happen, as you have found.


Kind regards,
Glenn Oster
 
GOC BUSINESS GROUP | SQF System Development & Implementation Consulting | eConsultant Retainer
Diverse Organic Microgreens & Two Cows Make Cheese | HempWorx | Internal Auditor Training | Remote SQF-GAP Analysis
 

 

Serving the New Republic of the United States of America - 

www.GlennOster.com

 

 


#14 Charles.C

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Posted 19 June 2020 - 04:48 AM

Good morning --

 

There was no audit, 10 minutes was basically taken to call my company and then call the QA vp at the supermarket chain I was doing the audit for and we all had a cup of coffee - since they had nothing, zip, nada they were suspended by the chain and I went back about 2 months later and conducted the audit and they passed with flying colors.

 

At minimum we tell our clients to have copies of everything electronically backed up and off-site back up such as a food safety software system - lots of stuff can happen, as you have found.

Hi Glenn,

 

So, if you had been doing a SQF audit, what do you think yr conclusion/action would have been ?

 

@QM-OS - I don't understand/agree with the logic(s) of yr final paragraph. Thks input anyway.


Kind Regards,

 

Charles.C


#15 babsbesafe123

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Posted 26 November 2020 - 09:52 AM

Hi I've just read this thread -  as within an audit you are looking for conformance as well as non conformance, had all the records gone or were there just large gaps?  Did you have other evdience to demonstrate that this was a one off rather than a complete breakdown of procedure? I would suggest that if it were the latter, it would be a minor under retention of records rather then a major issue.



#16 Foodworker

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Posted 26 November 2020 - 01:39 PM

Had this been uncovered in a BRC certification audit, then yes, it would amount to critical NC and hence failure.

 

The problem was identified in an internal audit and the key then is what corrective actions have since been implemented.

 

I don't know the time periods involved but if the internal audit were just before the certification audit the critical NC would in my opinion still stand.

 

If it were some time before the certification audit and there was a good root cause analysis, strong corrective action and subsequent good evidence of recent records being available, I would argue that it should not stand.



#17 Charles.C

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Posted 26 November 2020 - 01:54 PM

Had this been uncovered in a BRC certification audit, then yes, it would amount to critical NC and hence failure.

 

The problem was identified in an internal audit and the key then is what corrective actions have since been implemented.

 

I don't know the time periods involved but if the internal audit were just before the certification audit the critical NC would in my opinion still stand.

 

If it were some time before the certification audit and there was a good root cause analysis, strong corrective action and subsequent good evidence of recent records being available, I would argue that it should not stand.

 

It could perhaps equally be argued that commercialised Product orignating from the "black hole" period should have been recalled. ? "No News is Good News" seems a rather optimistic defence.

 


Kind Regards,

 

Charles.C


#18 Foodworker

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Posted 26 November 2020 - 03:31 PM

Possibly, but as the records had at one existed and presumably showed no problems it would be difficult to justify. If there had been a problem with the process, the recall should have been at that point. 

 

It comes down to proving a negative by the absence of a positive or vice-versa



#19 Charles.C

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Posted 26 November 2020 - 05:24 PM

Possibly, but as the records had at one time existed and presumably showed no problems it would be difficult to justify. If there had been a problem with the process, the recall should have been at that point. 

 

It comes down to proving a negative by the absence of a positive or vice-versa

 

aka Guilty until Proven Innocent ?


Kind Regards,

 

Charles.C





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