GFSI audit grumbles

Let's put this here for everyone!  A vent and grumble page re: GFSI and customer audits

I'll start--we all pay an exorbitant amount of money into GFSI audits and STILL have customer audits (e.g. the new Costco annual unannounced requirement)

This is getting out of hand-------I did not sign up to have my life put on hold for a 2 month minimum every year til the end of time because 1 company has decided internationally benchmarked certification isn't good enough for them

Are we audit ready 365-I'd like to think so--------but that doesn't make it ok!  

Wow...I'm glad that at this time we do not have material for Costco...that is maddening.

One of my grumbles is how there are still certain companies out there that put on a 'dog and pony' show for the auditors and get good scores, when there are obvious issues.  I understand an auditor cannot catch everything, but it drives me crazy.  For example, I know of a place that uses Contract Manufacturers and have been saying for the past 3-4 years they do not have any and they haven't been caught.  That is pretty serious, especially knowing they are not evaluating the ones they currently use.  I get it, there isn't enough time to dig deep over everything in the audit, but it just strikes a nerve that this company keeps getting excellent scores while not fulfilling one of the clauses.  Could end up becoming a food safety issue for them.

Seriously... :glare:

We only sell one product to Costco, not even a huge amount, but now I can just never plan a summer vacation as long as I work here?

Seriously... :glare:

 

We only sell one product to Costco, not even a huge amount, but now I can just never plan a summer vacation as long as I work here?

RIGHT!!!!!  My child will only be small for a short time------I will never be able to take ANY of march break off  Apparently Costco couldn't care less  and the small business exemption is NUTS!  We sell a ton of volume but 2 sku's only and very very very low risk product.  If my legal regulator feels my facility passes inspection-that SHOULD be enough for everyone

Thanks for the warning. I know the company I work for will be branching out and looking for new customers this fall. I will warn them about the work/headache.

GFSI was being marketed as the end all be all to customer audits.  They're sending in a professional, non-affiliated party to provide a genuine evaluation of a business that everyone is supposed to be able to trust.  Then came along all of the supplier approval requirements one must put into place to actually approve a vendor, and they added so many requirements that it becomes difficult to avoid self-auditing your suppliers (right back to square one!).

Nothing to mention how the various GFSI schemes decided to squabble with one another:  "you have a SQF certified supplier, that isn't strong enough to meet BRC standards," and vice versa.

One has to ask:  if marking that my supplier is GFSI certified and compliant isn't satisfactory enough to use them as a supplier, doesn't that indicate that GFSI bodies as a whole aren't even confident in their own system of standards???

RIGHT!!!!!  My child will only be small for a short time------I will never be able to take ANY of march break off  Apparently Costco couldn't care less  and the small business exemption is NUTS!  We sell a ton of volume but 2 sku's only and very very very low risk product.  If my legal regulator feels my facility passes inspection-that SHOULD be enough for everyone

A few of the firms I consulted with ran cost/benefit analyses of sustaining Costco standards vs the amount they actually sold to them, and more than one decided to terminate their accounts with Costco over it.  They're happy to maintain their certs otherwise, but the additional amount of hoops Costco is willing to put people through wasn't worth the extra costs for them.

And meanwhile, I refuse to let my wife buy most of our fruit and vegetables from them.  Too many times I've had a bag of snap peas or clamshell of raspberries mold two days after purchase...  Somehow I don't have that problem with the "sub-par" fruits and vegetables I buy at other grocers.

I feel your pain.. a small company or even a large one.. can have 5-6 audits per year.. and honestly I don`t know how to plan my holidays anymore.. we have Tesco, Morrisons, Asda, M&S, Aldi unannounced , and they are not happy with the annual unannounced BRC.. as every single retailer believe to be better and different to others with a brand new book of requirements every 2-3 years.  :angry2:

The new Costco Food Safety & Quality Audit Expectations document (effective April 1st, 2023) says this:

"All manufacturing operations must have a properly installed and calibrated X-ray detection device for finished product.."

Then lists three exceptions:

1. When product texture, density or chemical composition limits the performance of X-ray technology.

2. Shell eggs, whole raw agricultural commodities, whole roasted coffee beans, whole muscle meats and packaging products.

3.Operations that utilize a physical barrier (screen, filter, sieve) that's appropriately sized and placed.

Facilities that have not installed a detection device by the time of their Costco anniversary audit will receive an automatic audit failure.

So, unless you are exempted, you have just been required, by your customer, to purchase a ~$150,000 piece of equipment.

Marshall

 

Facilities that have not installed a detection device by the time of their Costco anniversary audit will receive an automatic audit failure.

 

So, unless you are exempted, you have just been required, by your customer, to purchase a ~$150,000 piece of equipment.

 

Marshall

No problem. That just means the price of the product Costco is buying will go up to compensate.

That said, I think it's crazy to not have anything in place to deal with foreign materials that are not metal, so it's not exactly an unreasonable requirement.

Wow...I'm glad that at this time we do not have material for Costco...that is maddening.

 

One of my grumbles is how there are still certain companies out there that put on a 'dog and pony' show for the auditors and get good scores, when there are obvious issues.  I understand an auditor cannot catch everything, but it drives me crazy.  For example, I know of a place that uses Contract Manufacturers and have been saying for the past 3-4 years they do not have any and they haven't been caught.  That is pretty serious, especially knowing they are not evaluating the ones they currently use.  I get it, there isn't enough time to dig deep over everything in the audit, but it just strikes a nerve that this company keeps getting excellent scores while not fulfilling one of the clauses.  Could end up becoming a food safety issue for them.

If such a thing persists for more than a year, they obviously have no intention of fixing the problem. I would go straight to their auditing body and report the company you're talking about if I was aware.

No problem. That just means the price of the product Costco is buying will go up to compensate.

That said, I think it's crazy to not have anything in place to deal with foreign materials that are not metal, so it's not exactly an unreasonable requirement.

I would agree, except X-ray technology is not a magic bullet. It may work fine on some products/materials, but not so well on others.

Marshall

I would agree, except X-ray technology is not a magic bullet. It may work fine on some products/materials, but not so well on others.

 

Marshall

Which is why Costco had exemptions and why there are multiple ways to deal with foreign material.

Unfortunately, I've seen too many companies say "We've got a metal detector" and leave it at that. Then, when we came back with a glass complaint, they were unable to handle it, because there was no glass policy, filters or other ways to deal with it in place. You don't need an X-ray detector per se, but you need something.

Which is why Costco had exemptions and why there are multiple ways to deal with foreign material.

 

Unfortunately, I've seen too many companies say "We've got a metal detector" and leave it at that. Then, when we came back with a glass complaint, they were unable to handle it, because there was no glass policy, filters or other ways to deal with it in place. You don't need an X-ray detector per se, but you need something.

Except Costco is DEMANDING x-ray unless you fall into one of the categories they have exempted

If your annual PROFIT is less than the cost of purchase/installation/maintenance over a reasonable ROI of 5 years-most companies will just drop them as a customer 

... PROFIT is less than the cost of purchase/installation/maintenance over a reasonable ROI of 5 years-most companies will just drop them as a customer 

That's really the only thing that will change their tune.  

Costco operates with a different mentality than most grocery or general goods businesses, but if they can't provide the goods their members want they're still answerable.

Maybe we need a Costco audit grumbles thread for me to go off on...

After the stress of our first Costco audit (unannounced with two Costco food safety execs shadowing our contracted auditor), we received our initial purchase order a few days later. The expected delivery date was a week away with a one hour delivery window on a Saturday before the sun comes up. We scrambled to finish everything and a second PO comes in before we even deliver the first one with again, a week to complete and deliver.

While dealing with moving our production schedule around to ensure we finished the orders, our Production Manager was scrambling to find Costco approved pallets for our product to go out on. We should've dug into the pallet situation before, but wanted to wait until the first PO came in since we had no idea how many pallets were going to be needed and hadn't expected the allowed time for production to be only a week.

Costco only allows pallets to be used from Costco-approved pallet suppliers, most of which have huge minimum order quantities (the ones we found were around 20,000 pallets per year, where we needed 9 for our first order). The pallets have several requirements, which make sense since the pallets sometimes go directly onto the warehouse floor for customers to pick off of, but this was just another hoop for us to jump through.

Okay, I'll end my rant here. Costco might be a great opportunity for us, but there were definitely a lot of obstacles (and I'm sure there will be more down the road) in order to start selling to them.

Which is why Costco had exemptions and why there are multiple ways to deal with foreign material.

 

Unfortunately, I've seen too many companies say "We've got a metal detector" and leave it at that. Then, when we came back with a glass complaint, they were unable to handle it, because there was no glass policy, filters or other ways to deal with it in place. You don't need an X-ray detector per se, but you need something.

Of course you need "something". Robust PRP's and a culture of awareness go a long way to ensure you don't have chunks of wood or plastic or glass in your products.

If you are actively ensuring those items that are NOT metal are NOT in your products, a X-ray is perfectly fine if you choose to install one, but to have a customer DEMAND one as a requirement to do business is a bit much.

Marshall

If such a thing persists for more than a year, they obviously have no intention of fixing the problem. I would go straight to their auditing body and report the company you're talking about if I was aware.

I was not aware you could do this.  So, you can do this?  Would it be kept confidential if I did?

I was not aware you could do this.  So, you can do this?  Would it be kept confidential if I did?

At your request, yes.  You can contact the FDA, or the GFSI scheme in question (or both) or the certifying body

GFSI was being marketed as the end all be all to customer audits.  They're sending in a professional, non-affiliated party to provide a genuine evaluation of a business that everyone is supposed to be able to trust.  Then came along all of the supplier approval requirements one must put into place to actually approve a vendor, and they added so many requirements that it becomes difficult to avoid self-auditing your suppliers (right back to square one!).

 

Nothing to mention how the various GFSI schemes decided to squabble with one another:  "you have a SQF certified supplier, that isn't strong enough to meet BRC standards," and vice versa.

 

One has to ask:  if marking that my supplier is GFSI certified and compliant isn't satisfactory enough to use them as a supplier, doesn't that indicate that GFSI bodies as a whole aren't even confident in their own system of standards???

On the supplier side AND the customer side it is such a pain now. Every customer has their own web portal or mayyyybe if you're lucky a couple will use the same service, but even then they want their own questionnaires all asking for the same info.

Some of the bigger companies can just say "Here is our supplier document packet, we don't do personalized questionnaires. Take it or leave it." but I haven't had that luxury yet...

On the supplier side AND the customer side it is such a pain now. Every customer has their own web portal or mayyyybe if you're lucky a couple will use the same service, but even then they want their own questionnaires all asking for the same info.

Some of the bigger companies can just say "Here is our supplier document packet, we don't do personalized questionnaires. Take it or leave it." but I haven't had that luxury yet...

I recently had a supplier that said that and basically got away with it, even though the package was wholly insufficient in providing all the information you'd expect.

That said, they were the only ones who actually provided updated documentation annually instead of providing all the information ones and never looking at it again unless asked.

Hi everyone,

If you have one certification audit and one customer audit every year then in my view that is a good situation to be in. Historically every Tom, Dick & Harry customer wanted to audit sites. With GFSI benchmarked standards many customers now accept an appropriate scope/certification.

I agree with the comments regarding Costco demands for X-Ray equipment but this is similar to what happened with BRCGS making foreign-body detection and removal equipment compulsory:

4.10.3 Metal detectors and X-ray equipment

Metal detection equipment shall be in place unless risk assessment demonstrates that this does not improve food safety. Where metal detectors are not used, justification shall be documented. The absence of metal detection would only normally be based on the use of an alternative, more effective method of protection (e.g. use of X-ray, fine sieves or filtration of products).

One may take the view that if X-Ray Detection Equipment improves food safety of your products then maybe it isn’t a bad thing that Costco are pushing this?

If I owned such a business I would want to clearly and loudly communicate back to relevant Costco representatives the cost implications.

Kind regards,

Tony

I understand the need for a document control program.  We selected one that sent an email request with our questionnaires and for documents and stated that company documents are acceptable in lieu of our questionnaires, but that some documents were required.  All the vendor has to do is attach the document(s), add the expiration date (if applicable) and hit send.  Once the system receives the documents, the administrator is notified and an approval is requested prior to accepting the document for compliance measurement.  We will still have to review and accept or deny all documents as they come in.... some are really easy, Halal/Kosher/GFSI Certification, others not so much like Food Safety Plans/HACCCP and flow charts, these require review by a PCQI/HACCP trained employee.  Many of our vendors will not send GFSI audit reports, so they must send other documents with their certification...  it is always a little confusing and still requires people to make judgements and QA to constantly review and make sure everything is in place. 

We are a small company that has added 2 additional QA employees..... in the last 3 years and we still have difficulty getting all the trending, provider reviewing and internal auditing completed.

As far as unannounced audits..... what vacation?   But over the years I have learned that we are able to do things our way, name things our way and as long as it meets the standard you can explain/argue with them.  I love auditors that take the guidance section of the audit and tell me I have to do it that way.  That is not the standard and it is a guidance, not a standard/rule/law/regulation.  After 23 years in the business go ahead, ague.  I am the subject expert.

I understand the need for a document control program.  We selected one that sent an email request with our questionnaires and for documents and stated that company documents are acceptable in lieu of our questionnaires, but that some documents were required.  All the vendor has to do is attach the document(s), add the expiration date (if applicable) and hit send.  Once the system receives the documents, the administrator is notified and an approval is requested prior to accepting the document for compliance measurement.  We will still have to review and accept or deny all documents as they come in.... some are really easy, Halal/Kosher/GFSI Certification, others not so much like Food Safety Plans/HACCCP and flow charts, these require review by a PCQI/HACCP trained employee.  Many of our vendors will not send GFSI audit reports, so they must send other documents with their certification...  it is always a little confusing and still requires people to make judgements and QA to constantly review and make sure everything is in place. 

 

We are a small company that has added 2 additional QA employees..... in the last 3 years and we still have difficulty getting all the trending, provider reviewing and internal auditing completed.

 

As far as unannounced audits..... what vacation?   But over the years I have learned that we are able to do things our way, name things our way and as long as it meets the standard you can explain/argue with them.  I love auditors that take the guidance section of the audit and tell me I have to do it that way.  That is not the standard and it is a guidance, not a standard/rule/law/regulation.  After 23 years in the business go ahead, ague.  I am the subject expert.

Probably veering a little OT here, but in a recent customer audit they wanted to see evidence that we were aware of, and took actions regarding any employee that possibly had a "food borne illness".

My response was that we had no such evidence, because the situation had not happened.
"So, you have not had any employees that went home sick"? was the question.

My response was of course we have, but we can't legally inquire about the nature of their illness nor can we require a return to work attestation from a doctor that says anything about the nature of their illness.
I said if an employee is vomiting on the line or suffers a bout of gastrointestinal "distress" while working on the line, that would be a different situation and our current policy/procedure explains what we would do in that situation.

Because that has not happened, they were unable to "verify" that our current policy was acceptable.

I believe this is called a Catch-22. I can't provide records of something that has not happened, but because I can't provide records, our policy is somehow lacking.

Go figure.

Marshall