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Sense check my auditor on non-conformance relating to our TACCP and VACCP plans

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Drams

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Posted 10 May 2022 - 07:21 PM

Hi folks,

I have recently joined a company which is still working to ISO9001+HACCP accreditation from a CB who I will not name.

In a recent audit we were cited for a non-conformance relating to our TACCP and VACCP plans. The auditor will not cite a clause requirement but insists that these plans are a part of Codex requirements and our simple HACCP scheme.

Now I'd argue that our company is on a journey to upgrade to a more comprehensive, GFSI scheme, but until we upgrade, there are technically no TACCP or VACCP requirements to conform to.

Sanity check please!

Are they correct, even the most simple of HACCP based FSMS must have these elements?

Or should I stand my ground and request that this NC is not upheld?



kingstudruler1

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Posted 11 May 2022 - 12:57 AM

I'm not familiar with ISO9001+ HACCP

 

However, HACCP is pretty uniformly regarded as not designed for and ineffective at controlling acts of intentional adulteration.   It seems like he is wrong but maybe I'm missing something.   It seems like they would have to assign the NC to a specific clause.   

 

Taccp and vaccp / intentional adulteration should make up a food safety program and can be regulatory requirements (I'm not familiar with UK)


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Charles.C

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Posted 11 May 2022 - 01:15 AM

Hi folks,

I have recently joined a company which is still working to ISO9001+HACCP accreditation from a CB who I will not name.

In a recent audit we were cited for a non-conformance relating to our TACCP and VACCP plans. The auditor will not cite a clause requirement but insists that these plans are a part of Codex requirements and our simple HACCP scheme.

Now I'd argue that our company is on a journey to upgrade to a more comprehensive, GFSI scheme, but until we upgrade, there are technically no TACCP or VACCP requirements to conform to.

Sanity check please!

Are they correct, even the most simple of HACCP based FSMS must have these elements?

Or should I stand my ground and request that this NC is not upheld?

Hi Drams,

 

The Scope of the audit is typically based on the Standard to which you are seeking certification.

 

As I understand GFSI's vision of a FSMS, the components HACCP, VACCP and TACCP are separately distinguished as per the following structure - 

 

Attached File  GFSI - FSMS.png   334.35KB   0 downloads

 

The current Codex document containing Codex HACCP is attached below. There are no mentions of VACCP or TACCP within it.

 

Attached File  Codex Food Hygiene,2020.pdf   502.07KB   27 downloads

 

Any specific NCs should be relatable to Clauses in the audited Standard (unspecified in the OP).

 

PS - Note that some (at least one) GFSI-recognised Standards do include VACCP/TACCP related items within their interpretation of HACCP


Kind Regards,

 

Charles.C


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beautiophile

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Posted 11 May 2022 - 02:01 AM

ISO9001 is so generic and opens to a myriad of interpretations. 

GFSI can be a specific application of ISO9001 in food industry. if the HACCP, TACCP and VACCP influence the products/services, they stay under ISO9001 umbrella. 



Drams

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Posted 11 May 2022 - 07:46 PM

Thanks for the replies folks,

For the sake of one minor NC, we're moving on however I'm not wholly satisfied with the way the audit process and my query was handled. It's a learning moment for me.

I think their link between TACCP, VACCP and the scope of our audit is tenuous at best, but arguing the case isn't going to be worth the effort frankly!



Charles.C

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Posted 11 May 2022 - 08:07 PM

Thanks for the replies folks,

For the sake of one minor NC, we're moving on however I'm not wholly satisfied with the way the audit process and my query was handled. It's a learning moment for me.

I think their link between TACCP, VACCP and the scope of our audit is tenuous at best, but arguing the case isn't going to be worth the effort frankly!

 

Hi Drams,

 

Was this a BRC8 audit ?

 

(BRC for reasons best known to themselves decided to create an "Omnibus" version of "Codex" haccp).


Kind Regards,

 

Charles.C


Drams

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Posted 12 May 2022 - 12:54 PM

Not BRC, no.

We only hold accreditation for ISO9001 at this time. In the future we would like to attain accreditation to a GFSI scheme such as BRC or FSSC but this is a 2-3 year objective.



Charles.C

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Posted 12 May 2022 - 03:13 PM

Not BRC, no.

We only hold accreditation for ISO9001 at this time. In the future we would like to attain accreditation to a GFSI scheme such as BRC or FSSC but this is a 2-3 year objective.

I don't understand why an iso9001 audit would involve haccp since afaik the former's scope is only quality, not including safety.

 

I suggest you ask the auditor where Codex refers to vaccp/taccp in a haccp context.

 

(JFI BRC's Safety Standard also implies that Codex haccp includes vaccp/taccp which afaik is equally BS).


Kind Regards,

 

Charles.C


Kara S.

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Posted 12 May 2022 - 04:49 PM

Thanks for the replies folks,

For the sake of one minor NC, we're moving on however I'm not wholly satisfied with the way the audit process and my query was handled. It's a learning moment for me.

I think their link between TACCP, VACCP and the scope of our audit is tenuous at best, but arguing the case isn't going to be worth the effort frankly!

 

Did they provide the audit report yet? You might not get a minor for it if they cannot write it up under any portion of the code you are being audited against. You could easily dispute the non-conformance as well. 


Kind regards, 

 

Kara

Food & Beverage Industry Consultant

IFSQN Business ListingLinkedIn  |  Webpage

 

 


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Drams

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Posted 12 May 2022 - 06:11 PM

Yeah this has been an odd one for me.

My past experience of FSSC led me to believe that the TACCP and VACCP pillars were quite separate from HACCP, and it's preferable this way in my opinion.

The audit we've just received was for ISO9001 and HACCP as an unaccredited add-on. I feel we're really at the behest of this auditors opinion on a lot of things, since they aren't working to a structured standard for FSMS.



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Charles.C

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Posted 12 May 2022 - 11:50 PM

Yeah this has been an odd one for me.

My past experience of FSSC led me to believe that the TACCP and VACCP pillars were quite separate from HACCP, and it's preferable this way in my opinion.

The audit we've just received was for ISO9001 and HACCP as an unaccredited add-on. I feel we're really at the behest of this auditors opinion on a lot of things, since they aren't working to a structured standard for FSMS.

Hi Drams,

 

I'm not quite sure what you mean by "unaccredited add-on". Google gives - The meaning of UNACCREDITED is not recognized as meeting prescribed standards or requirements. = in this case "just a matter of auditor's opinion" ?

 

You initially mentioned that the auditor's NC was based on his/her/their interpretation of  haccp as including taccp/vaccp. If Codex was claimed as the sole basis of auditor's opinion, the NC is IMO challengeable. However if, for example,  auditor's basis was BRC Standard then probably not.

 

Take your Pick. :smile:


Kind Regards,

 

Charles.C


beautiophile

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Posted 13 May 2022 - 01:22 AM

I don't understand why an iso9001 audit would involve haccp since afaik the former's scope is only quality, not including safety.

 

I suggest you ask the auditor where Codex refers to vaccp/taccp in a haccp context.

 

(JFI BRC's Safety Standard also implies that Codex haccp includes vaccp/taccp which afaik is equally BS).

 

A broad definition of quality in the ISO9000s world is "fulfilment of customer's requirements", both implicitly and explicitly. By that, FS is a criterion of product quality, and HACCP or ISO2200 or Codex is a mean to resolve it, in the other words: contributing to the conformance with Clause ISO9001 8.2.

 

In here and food industry, 'quality' has a separate/narrower meaning which is only about physical/mechanical properties. 

 

As I have seen, those two different interpretations cause the confusion about quality while adopting ISO9001 into food industry.


Edited by beautiophile, 13 May 2022 - 01:30 AM.


Charles.C

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Posted 13 May 2022 - 01:46 AM

A broad definition of quality in the ISO9000s world is "fulfilment of customer's requirements", both implicitly and explicitly. By that, FS is a criterion of product quality, and HACCP or ISO2200 or Codex is a mean to resolve it, in the other words: contributing to the conformance with Clause ISO9001 8.2.

 

In here and food industry, 'quality' has a separate/narrower meaning which is only about physical/mechanical properties. 

 

As I have seen, those two different interpretations cause the confusion about quality while adopting ISO9001 into food industry.

Hi beautiophile,

 

Yes, it's indeed a time immemorial discussion, eg -

 

https://www.ifsqn.co...safety-of-food/

(Predictably all the links are long gone bar Wiki)


Kind Regards,

 

Charles.C




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