13 replies to this topic

[The Prof]

Hi all.

 

Having just completed some work for a small business for the past 6 months, I want to share my experiences.

 

To provide context, the business has achieved AA BRCGS Food Safety certification repeatedly over the past 5 years.

 

What I discovered:

1. Senior managers have never been audited. They were unaware of the senior management requirements in the standard.

2. The business relies on co-packers. One of the co-packed products placed on the market is the biggest selling product! The audit report has repeatedly stated that co-packing requirements are not applicable.

3. A folder of files maintained by the Technical team and set-aside for the audit. Evidently, many of the documents and records in this folder are simply re-dated and presented to the auditor every year.

4. Legal non-compliances in artwork.

5. Supplies of raw materials and packaging procured simply because it is low-cost.

6. Organic gluten free products placed on the market that knowingly contain gluten (adventitious gluten from crops).

7. Cleaning and sanitising verification completed once per annum using wet swabs. No further verification completed.

8. The BRCGS auditor has never engaged with non-technical staff to ask questions.

9. The BRCGS auditor did not select samples of evidence. Instead the technical team selected samples on behalf of the auditor (see point 3 above). 

10. Risk assessments poorly expedited, yet accepted by the BRCGS auditor.

11. Hairnets are only worn during audits.

12. No-one (other than Technical staff) are able to refer to the documented procedures (they do not have access to the computer folder where the documents are maintained) and very few people knew they existed.

 

On a related note, I supported the first ever 3rd party SMETA audit recently. The auditor (not the same auditor as BRCGS nor the same audit body) asked for a list of chemicals used on-site. None of the chemicals on the list had been used for a number of years. The auditor then asked for MSDS documents. None of the MSDS documents related to any of the chemicals on the list of chemicals. The auditor was then shown some COSHH risk assessments. The auditor did not ask about chemicals during the initial factory tour. Why did the auditor not corroborate?

 

I would like to think these are exceptions, but having audited businesses in the food supply chain for over 35 years now, I know they are not and the situation seems to be getting worse. 

 

How might the food industry tackle these issues?

[Kara S.]

Wow. That's crazy. If I was an auditor - everyone would fail because like you already described in your post - we know the loopholes these companies take. 

 

Honestly, I've been through a joke of an audit once before as well. I was really stressed out about it but everyone was like of we're getting so and so - we're fine! and they were right! we managed to get a 98% on our SQF audit. Switched the certification body and received an 87% the following year - almost had to have the check-in. Interesting the variation you can get between auditors and certification bodies.

 

Sounds like there needs to be an audit on the auditor. 

[Scampi]

I have been saying for years that the process is inherently flawed

 

There is no international required accreditation for auditors

 

Only people who are financially secure can afford to become auditors (at least in Canada-you're not getting paid in the beginning and the requirements are too high to work full time as well)

 

NO ONE takes codex seriously anymore

 

Different schemes have different onsite requirements (our auditor told us this year he HAD to spend 1/2 audit time on the floor-hence very little documentation review occurred)

 

Regulatory bodies are starting to accept 3rd party accreditation as part of inspections--this leaves way too much room for shady operators

Edited by Scampi, 31 August 2022 - 03:11 PM.

[Setanta]

Even with GFSI audits, auditor consistency is a myth. I do not mean it as a slam, but things one auditor really cares about will be dismissed by another auditor.
`

[kingstudruler1]

Third party audits are inherently flawed.   Any system where the Auditee pays the auditor is problematic.   Giving low(er) scores or even not passing an organization is not good for business.  CB will be dropped.  Auditors that give lower scores will be asked to not return.    

 

I too have seen companies that probably should not have passed receive a high score / rating.    high scores are now expected and given, it de-incentives improvement.  it gives auditees and customers a false sense of assurance.  

 

 

in this case, I'm not sure if this company didn't not know what they were doing.  I've seen a lot of people put into responsible positions that they had no business being in with no mentoring to get them to where they needed to be.  Or, they were just cheating and didn't care.   sucks either way. 

[Kara S.]

Third party audits are inherently flawed.   Any system where the Auditee pays the auditor is problematic.   Giving low(er) scores or even not passing an organization is not good for business.  CB will be dropped.  Auditors that give lower scores will be asked to not return.    

 

I too have seen companies that probably should not have passed receive a high score / rating.    high scores are now expected and given, it de-incentives improvement.  it gives auditees and customers a false sense of assurance.  

 

 

in this case, I'm not sure if this company didn't not know what they were doing.  I've seen a lot of people put into responsible positions that they had no business being in with no mentoring to get them to where they needed to be.  Or, they were just cheating and didn't care.   sucks either way. 

 

 

You make a great point! 

[Tony-C]

Hi all.

 

Having just completed some work for a small business for the past 6 months, I want to share my experiences.

 

To provide context, the business has achieved AA BRCGS Food Safety certification repeatedly over the past 5 years.

 

What I discovered:

1. Senior managers have never been audited. They were unaware of the senior management requirements in the standard.

2. The business relies on co-packers. One of the co-packed products placed on the market is the biggest selling product! The audit report has repeatedly stated that co-packing requirements are not applicable.

3. A folder of files maintained by the Technical team and set-aside for the audit. Evidently, many of the documents and records in this folder are simply re-dated and presented to the auditor every year.

4. Legal non-compliances in artwork.

5. Supplies of raw materials and packaging procured simply because it is low-cost.

6. Organic gluten free products placed on the market that knowingly contain gluten (adventitious gluten from crops).

7. Cleaning and sanitising verification completed once per annum using wet swabs. No further verification completed.

8. The BRCGS auditor has never engaged with non-technical staff to ask questions.

9. The BRCGS auditor did not select samples of evidence. Instead the technical team selected samples on behalf of the auditor (see point 3 above). 

10. Risk assessments poorly expedited, yet accepted by the BRCGS auditor.

11. Hairnets are only worn during audits.

12. No-one (other than Technical staff) are able to refer to the documented procedures (they do not have access to the computer folder where the documents are maintained) and very few people knew they existed.

 

On a related note, I supported the first ever 3rd party SMETA audit recently. The auditor (not the same auditor as BRCGS nor the same audit body) asked for a list of chemicals used on-site. None of the chemicals on the list had been used for a number of years. The auditor then asked for MSDS documents. None of the MSDS documents related to any of the chemicals on the list of chemicals. The auditor was then shown some COSHH risk assessments. The auditor did not ask about chemicals during the initial factory tour. Why did the auditor not corroborate?

 

I would like to think these are exceptions, but having audited businesses in the food supply chain for over 35 years now, I know they are not and the situation seems to be getting worse. 

 

How might the food industry tackle these issues?

 

Hi The Prof,

 

A number of questions come to mind:

 

Is this business in the UK?

Did you raise any of items 1 to 12 with the owners/senior management?

Why did you continue to work with them for 6 months with all these issues and knowing they were selling illegal and potentially dangerous products?

 

Kind regards,

 

Tony

[The Prof]

Hi The Prof,

 

A number of questions come to mind:

 

Is this business in the UK?

Did you raise any of items 1 to 12 with the owners/senior management?

Why did you continue to work with them for 6 months with all these issues and knowing they were selling illegal and potentially dangerous products?

 

Kind regards,

 

Tony

 

Hi Tony, I hope you are well - I recall working with you at a dairy business in Gloucestershire some years ago :-)

 

Yes, this business is in the UK.

 

Yes, the senior managers are aware and they replied stating this was the responsibility of the technical team (1 person).

 

I am not continuing to work for this business, I have walked away, worried about my membership status of certain institutions and my reputation. 

 

My remit was as facilitator / consultant, but I have tried and failed, simply because there is no interest at owner/senior management level and my efforts have failed to make a difference. I have ended up providing additional technical administration resource. I would add that staff turnover at this business in the last 12 months was 75%, which is an improvement on the year before! The senior leadership team simply needs to start to engage with the team and show they care. The business is starting to venture into retailer own-label and the shortcomings of the business will be discovered sooner or later. 

 

Organization's like these should never be certificated and discredit all the good work that committed, genuine AA grade organization's put in.

 

Best wishes,

 

The Prof

[Tony-C]

Hi The Prof,

 

Wow, Severnside! in the 90’s, long time!      

 

It was a really nice manufacturing facility in its day and great people too, many good memories.

 

I guessed that the business was likely to be in the UK from your location, disappointing really.

 

Walking away is a good idea, sounds like the owners/senior management are a bunch of dinosaurs and this site is a ticking time bomb. I’m sure they’ll get found out, sooner rather than later, if they go down the retailer route.

 

 Good luck in your future ventures.

 

Kind regards,

 

Tony

[Ryan M.]

Well that can be frustrating and those issues need to be remedied.

I don’t have an answer for auditing and making it same standard across all auditors. They are people and people are inherently lazy and inconsistent.

I saw an article about insurance companies taking on a larger role in ensuring food manufacturers are complying. I don’t think this is a bad idea since they have a vested interest and can pull the insurance of the food company in certain circumstances.

I don’t see independent auditors or regulators doing an adequate job, unfortunately….

[Jim E.]

 

 

Different schemes have different onsite requirements (our auditor told us this year he HAD to spend 1/2 audit time on the floor-hence very little documentation review occurred)

 

 

 

We just completed our last BRCGS version 8 audit with a AA score. The comment about an auditor having to spend 1/2 audit on the floor may be a little off.  Our did just that, spending so much time interviewing team members and actually having them go through inspection requirements it was amazing and great.  The team members did well in procedures and knowledge requirements.  So, when we did sit down for document review she did not have to go in-depth as she knew our procedures were good from what she witnessed on the production floor.  Our management team was very impressed with her work and asked for her to return again.  Having her do the heavy work on the floor did not require me to fill in so many gaps with documentation and procedures that were not my specific responsibility as I usually have to.  Try and explain boiler monitoring or temperature monitoring equipment when you are down to the last 5 minutes of the last day.  She asked all the right questions on the floor.

Edited by Jim E., 17 October 2022 - 06:09 PM.

[Miss Frankie]

Even with GFSI audits, auditor consistency is a myth. I do not mean it as a slam, but things one auditor really cares about will be dismissed by another auditor.
`

 

Totally agree, just not with just GFSI auditors.

 

We have quarterly USDC audits. I've only been with this company about 10 months but have known the 2 USDC auditors in the area for several years. The one we had this year is good.  He's very by the book, but fair.  He's seen a lot of improvement since I started, so he will give us a break on something minor, because he knows I won't let it slide. 
Next year, we'll have the other auditor, which I'm dreading.  He's pretty lax and isn't going to notice much.  Which in turn will cause production to think they are doing great and will start to slack off.   To top it off, our unannounced SQF audit is next year, so I've got my work cut out for me next year.

[hello.fizz]

Wow that is crazy to read! We like our SQF auditor as they are very good and we know our system will improve each time they look over it (similar to Miss Frankie). In saying that, the company had been on 6 monthly audits before I started and it was an expensive exercise and it is incredibly stressful in the lead up and on the days they are there auditing, as the lead technical person on site. 

[Charles.C]

Apart from the (obvious) Horror Stories detailed in OP, I did not see two other arguably Critical aspects mentioned - What was the Product ?. How was the micro. Hygiene et al ?

 

I merely wondered if the Risk from both aspects was considered so Low that  Auditors simply thought the Process/Facility was "Insignificant" from a Safety POV. Sometimes, IMEX, Familiarity can breed "Contempt".

 

Might also suggest that people compare the "complexity" of the, IMO relatively User-Friendly, BRC Food Safety Early Standards to the Current ones. Has Net Food Safety operationally changed to the same extent ?

 

The Auditorial "Misgivings"  as illustrated in the OP are presumably as much oriented to "BRC/SEDEX/???" as to their Auditors ??