Missed ATP tests and Environmental Tests

We have an audit coming up in the next 6 weeks and we are seeing we have missed some ATP testing on some production days.  We also missed some Environmental testings for a few months.  I am afraid that these will be counted as majors on our audit.  How can we fix this before our audit? 

Well, what to say: it's serious, but to fix it somehow you could generate corrective action reports explaining why those tests were missing. Don't forget to add preventive measures to prevent issue recurrence in the future. Let's see what other people will suggest...

We have an audit coming up in the next 6 weeks and we are seeing we have missed some ATP testing on some production days.  We also missed some Environmental testings for a few months.  I am afraid that these will be counted as majors on our audit.  How can we fix this before our audit? 

The seriousness of the issue is perhaps going to depend on the products / risk in the production area, how many were missed, etc. As your post is in the BRC Packaging section I'd assume that you're not doing some sort of high-risk chilled RTE food for which the consequences could be most severe, so that helps a bit!

You could ignore it, hope that the auditor doesn't look at those records, and cross your fingers. I wouldn't recommend it though ;)

In your position I'd be inclined to take ownership of it. Don't go out of your way to draw the auditors attention to it, but put everything you possibly can in place to ensure it is covered as well as possible if they do happen to review it while on site. Log it as an internal non-conformance, put in robust corrective action (you need to do this anyway...), build a file of data to show what implications there were etc - hopefully you can pull together copies of subsequent tests, product micro etc to show that it didn't cause a problem? 

You want to close the non-conformance as soon as you can, so go through your root cause process, identify the preventative action(s) to take, implement them, sign it all off, and if possible also have evidence that the actions have worked and that this has been reviewed to verify that it is the case - e.g. completion of all testing on time between now and the audit date, reviewed by the issuer of the non-conformance as part of the final close-out.

No food / packaging sites are perfect, so IMO an issue like this is really all about showing that you've caught the error and you've really gone over and above to make sure it doesn't happen again, and taken any necessary actions to mitigate any risk it may have caused.

We have an audit coming up in the next 6 weeks and we are seeing we have missed some ATP testing on some production days.  We also missed some Environmental testings for a few months.  I am afraid that these will be counted as majors on our audit.  How can we fix this before our audit? 

Well, a logical question might be as to why they were missed ?

It will be a minor, not a major.

From what you said, this is not a trend - in this area as an Auditor I would be looking for a trend.

Best solution is to make it known there was an exception(s) and what your analysis or audit of the situation produced, what training was done and how going forward you will ensure that this does not happen again.

If you did nothing right now, it would be major I am sure of that - but with the above it will go into the minor and could even be a verbal mention or non-gig.

It will be a minor, not a major.

 

From what you said, this is not a trend - in this area as an Auditor I would be looking for a trend.

 

Best solution is to make it known there was an exception(s) and what your analysis or audit of the situation produced, what training was done and how going forward you will ensure that this does not happen again.

 

If you did nothing right now, it would be major I am sure of that - but with the above it will go into the minor and could even be a verbal mention or non-gig.

Hi SQFC,

I don't see how numerous omitted ATP testing could be a minor unless it only related to non-significant contact surfaces and/or the packaging is non-food contact.

Unfortunately zero knowledge as to product/process. Zero in  >>>>>

Hi SQFC,

 

I don't see how numerous omitted ATP testing could be a minor unless it only related to non-significant contact surfaces and/or the packaging is non-food contact.

 

Unfortunately zero knowledge as to product/process. Zero in  >>>>>

HI Charles, well, that was my thought on the non-significant, but I just re-read what Caleb wrote and completely missed the environmental and then saw another posting by Caleb on missing 5 months of pest control inspections.

I need to take a "get out of jail" pass here - my bad, I will change that opinion to Major not minor.

Hi Glenn and SQFC,

This would be a food contact surface.  It is a popcorn type product, low risk. What options would you say I have at this point? Thanks!

Hi Glenn and SQFC,

This would be a food contact surface.  It is a popcorn type product, low risk. What options would you say I have at this point? Thanks!

I assume the popcorn is RTE.

Sorry but RTE is not (haccp) low risk in my book. And same for the packaging.

IIRC, BRC have some elaborate flowcharts over such matters ?

Since I do not know "where" you are located, I will only speak to what we are required to do in the US. Since you chose to do ATP as a pre-op verification and Environmental Testing as a monitoring activity, there must be valid reasons that your Food Safety Plan (HACCP, etc...) identified these two tasks as "Preventive Controls" that are important to your overall food safety program, otherwise you would not be doing them. So by not doing these as mentioned, you have potentially compromised your food safety plan and the safety of your products (in theory). This will be hard to explain. In addition, you mention that you make a popcorn type product that is considered low risk, but what formal risk assessment did you do to form this "low risk" conclusion? Since popcorn is a "ready to eat" product, it is a "high risk" product for this reason and management of "post process" contamination would be mandatory. This is where your Environmental Testing has value, especially if it is targeting Salmonella and Listeria. And if you are applying a flavor or seasoning to this popcorn, that makes the risk even higher. 

Honestly, I have a real problem with these type issues being found at the last minute and right before an upcoming audit. It sounds like someone is not doing their job correctly and that is more concerning to me. Be prepared to answer this question when the auditor asks. Why was this missed for such a long period of time? 

Hi Glenn and SQFC,

This would be a food contact surface.  It is a popcorn type product, low risk. What options would you say I have at this point? Thanks!

Wrong Forum ? i had assumed Packaging ?

First you need to find out exactly why you missed the ATP tests and environmental tests and conduct a risk assessment;

Then raise a Non-conformance to whoever was responsible and provide corrective action or action plan.

Hope it helps.

I'm going to be blunt because that's the only way I know how to be - I think your overall situation between the pest control and the environmental monitoring is unfortunate and I am not sure what has led up to this but it has to have been truly challenging.  Although what has happened is now water under the bridge, you must acknowledge all of your shortcomings before the audit happens if you have hope of potentially getting a passing grade.  Corrective actions and immediate rectification of each situation is a start.  I also would have serious concerns about what you describe as RTE product coming out of a facility with these kinds of issues and shortfalls.  I know financial issues have played a part in this, but doing poorly (or potentially failing) an audit will hopefully open up the eyes of those above you and help them realize the ramifications of cutting corners on food safety and help them prioritize things in the future.  I trust that you are in a good place to get things back into shape for your company and I wish you nothing but the best!  It shows great courage and willpower that you are reaching out for help now.  I hope this community can help you as much as possible as you work to get things back into compliance at your facility.