The unreasonableness I perceive (and remember) from our GMP audit was related in large part to an older building and absolute statements. One issue in specific, we have wood floors in a dry facility and all we were told about it was "This will never make it". We investigated replacement of the floors and coatings that were not cost effective. Under the tutelage of an experienced consultant, we were able to implement cleaning, maintenance, inspection and testing protocols. There were other less unreasonable and even legitimate corrections that were pointed out. Since then we have been able to maintain safety AND achieve certification.
Absolute statements like that are not conducive to encouraging newly implemented FSQM systems to pursue continuous improvement cycles. If we were not committed enough to find a way to make it work we would have stopped in our tracks and missed out on the last 4 years of continuous improvements.
On one hand, we needed to know where the gaps were, but on the other hand a push to improve is better than NEVER going to make it.
Thks for clarification. It's certainly a reality that not all auditors are created "equal".
In the (US) Literature the acceptability of "wood" for floors in Food Manufacturing facilities seems contentious, eg some Local Regulatory bodies are totally negative, others may offer flexibility such as -.
The type of flooring material varies with different processing areas and the amount and type of foot traffic. Food processing areas require flooring which can be readily cleaned and in good repair. Materials such as well-sealed hardwood may be suitable for some areas of a bakery where dry clean-up methods are appropriate.
Food processing areas that require flood-type cleaning (such as a fish plant), need well-sealed concrete floors with cove base and adequate drains. Heavy use areas with large, moveable equipment require more durable flooring.
Unfinished wood floors are NOT suitable in any plant areas.
In general, vinyl linoleum or tile floor covering may be satisfactory for very small operations where vacuuming and wet mopping provide sufficient clean up. Larger operations, particularly those processes that are "wet" in nature (e.g., fish, fruit, vegetables, beverages, tofu) require an easily drained, well-sealed concrete or tile floor.
(rather surprised no mention of epoxy etc)
I would certainly anticipate (require?) that an auditor should have acquired a working knowledge of the acceptability of flooring material in respect to relevant Standard, Product, Process, Environment etc. Just as 2 examples, here is BRC -
The floors in areas handling raw materials and preparing, processing, packing or storing product must be
kept in a sound condition and be easy to clean and, where necessary, to disinfect. Floors must be
constructed of materials that are impervious, hard-wearing, repairable and resistant to chemical attack so
that they can withstand appropriate cleaning procedures.
and SQF -
184.108.40.206 Floors shall be constructed of smooth, dense impact resistant material that can be effectively graded, drained, impervious to liquid and easily cleaned
Both the above seem to exclude untreated wood although certain wood species might perhaps pass ?
I certainly agree that the Inspector should minimally have pointed out why it could not pass against the Standard. This was apparently not done.
Most factories IMEX would have (immediately) challenged such a deficiency ?.
I'm curious as to the means whereby acceptance was ultimately achieved ?.
PS - there is a vaguely floor-analogous case here -