45 replies to this topic

[Bo16]

We had an auditor tell us our Listeria monitoring program was not valid because we did not find Listeria,  couldn't be because we did full break down, foam wash, scrub and sanitize every batch?  Nope.  We needed to swab the whole plant until we found it.  (Oh, by the way we do not make a Listeria sensitive or high risk ingredient, the whole program is for customer requirements, not because of risk to product)

[Scampi]

We had an auditor tell us our Listeria monitoring program was not valid because we did not find Listeria,  couldn't be because we did full break down, foam wash, scrub and sanitize every batch?  Nope.  We needed to swab the whole plant until we found it.  (Oh, by the way we do not make a Listeria sensitive or high risk ingredient, the whole program is for customer requirements, not because of risk to product)

 

WOW  sounds like your auditor was on a huge power trip and/or really doesn't understand a sanitation process (and how it's supposed to prevent Listeria for gaining a foot hold)

 

I have zero faith in auditors WITHOUT 1 centralized certification body that they are qualified and tested under----one of our auditors is "certified" for every category and is not very old-----so pray tell me just when you became an "expert" in all of those categories without 50 years of combined experience????

[Marloes]

I am currently working on a new plant, and for the certification audit to take place a minimum of three months production data should be present. However many of our customers are adamant that they cannot receive products from a ''uncertified'' plant. It feels a bit like the chicken and the egg....what comes first?

 

And off course I don't expect companies to accept a new supplier without adhering to their quality system. But some are so rigid that they are actually not improving on food safety.

[jfrey123]

We had an auditor tell us our Listeria monitoring program was not valid because we did not find Listeria,  couldn't be because we did full break down, foam wash, scrub and sanitize every batch?  Nope.  We needed to swab the whole plant until we found it.  (Oh, by the way we do not make a Listeria sensitive or high risk ingredient, the whole program is for customer requirements, not because of risk to product)

 

I had a customer audit once where the gentleman stopped basically one word short of calling us liars when we had zero rodent captures in our plant over the previous year.  Kept using the phrase "I find these records a little hard to believe..." and that sort of thing.  Drives me crazy when an auditor looks at a program that's well in control and decides that it must be impossible, that there must be some shenanigans afoot or something.

 

At the same time, I know when monitoring trends in the 8 plants I provide oversight for now, sometimes a plant looks "too good" on paper.  We send in a corporate quality director to do a fresh audit and suddenly overlooked things get found.  It goes both ways I guess, but it's just frustrating when you're having to defend a good program in those circumstances.

[mgourley]

It just stuns me that some customer audits are so specific that you end up having to prove a negative. After a rather (perhaps unprofessional rant on my part) I said to the auditor "I don't know what to tell you here. I can't provide you with records that do not exist, because the scenario you state has not happened. Just give us the NC and we will deal with it later. Provide me with an audit approved policy from another one of your External Manufacturers in the USA and we will use that going forward".

 

Marshall

[Tony-C]

We had an auditor tell us our Listeria monitoring program was not valid because we did not find Listeria,  couldn't be because we did full break down, foam wash, scrub and sanitize every batch?  Nope.  We needed to swab the whole plant until we found it.  (Oh, by the way we do not make a Listeria sensitive or high risk ingredient, the whole program is for customer requirements, not because of risk to product)

 

Hi Bo16,

 

I think this probably stems from BRCGS Global Standard for Food Safety Issue 9 Clause 4.11.8.3:

The company shall review the environmental monitoring programme at least annually and whenever there are:

………

• consistently negative results (e.g. a site with a long history of negative results should

review its programme to consider whether the correct parts of the factory are being tested, whether the testing is being conducted correctly, whether the tests are for the appropriate organisms, etc.).

 

BRCGS Guidance:

In most situations, negative results are seen as good news and lead to an assumption that continued all systems are operating correctly and within permitted parameters. However, if results are continuously and consistently negative and there is a long history of negative results, this may be indicative that the site should review its programme to consider whether the correct locations are being tested, in the correct way, for the correct organisms. The aim of the programme is, after all, to identify areas of concern.

 

Kind regards,

 

Tony

[Bo16]

Understood, but our program swabbed all zones including all floor drains, used positive and negative control with all runs in the laboratory.  We swabbed warehouse, rest rooms, office doors, shipping and receiving areas, coolers, freezers and about 400 different sites (rotating) in a small production batch production plant that uses complete break down of all equipment, foam, scrub, rinse and sanitize in between ALL batches......  sometimes it's just not there.

[MDaleDDF]

I also have an extremely clean enviro book, and have had an auditor get sassy about it.    I didn't know what to tell her.   I thought doing well at passing these tests was the whole point?   (I understand the point of it is to find weak spots, but I buttoned those all up in the last 15 years...) I welcomed her to swab anywhere in the plant she wished right now.   We're a very low risk place, and we've been in business a long time, as well as having been fssc 22k a long time.   Our place is clean, sorry not sorry.

 

Luckily I had a coliforms hit on finished product last year, lol.... so now I have a big red spot on my book.  That oughta make um happy!

Edited by MDaleDDF, 17 May 2023 - 12:27 PM.

[olenazh]

What about the presumption of innocence? Innocent until proven guilty: the auditor expressing distrust must prove otherwise. From my experience, when an auditor or inspector ask me how come I haven't had any positive Listeria for years I say "It is what it is".

[MDaleDDF]

I'm going to have some grumbles with V6 of fssc 22k coming soon.   Like a requirement to have a kill step instruction set on every label.   We manufacture for certain customers who consider the actual prep a trade secret, and we don't have anything on their labels other than legalities.   And if it's not required by the feds. how can GFSI set such requirements?  

I see a few things already in V6 that is GFSI/NSF getting a little big for their britches....

[Scampi]

MDale------can you post the actual element?  I'm curious about the language

[KarrieC]

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!  

 

No kidding!  We are a small company but have several customers we handle food product for. (storage, distribution, and co-pack)  between customer audits, self audits and yes the Costco addendum I haven't been able to take a vacation since Aug 2017!  My back up is the inventory manager he's too busy too.  Why can't the audits be 3 yrs or when we make a change?  Another complaint is the ambiguous language they use! We've been doing this work for over 30yrs and have never had a recall/withdrawal. Obviously, we are following an effective food safety plan.  I got a minor for not having a "no animals" sign.  If a driver has a seeing eye dog we've got bigger problems. Venting helps. 

[TimG]

 I got a minor for not having a "no animals" sign.

Can you recall what standard and line code they cited? Or was that a customer audit?

And yeah, we just had a thread where we discussed a threshold for customer audits. Setting a realistic threshold for audits is the way to go.

[G M]

...  I got a minor for not having a "no animals" sign.  If a driver has a seeing eye dog we've got bigger problems. Venting helps. 

 

Mr. Fluffykins was unwilling to sign the GMP and non-disclosure forms so he was not allowed to enter the production areas.  

[Buttercup]

Latest from Waitrose is that you have to have an annual SEDEX audit!

 

We make a seasonal product for them, where production lasts about 8 hours.

 

a complete mockery

[GMO]

Latest from Waitrose is that you have to have an annual SEDEX audit!

 

We make a seasonal product for them, where production lasts about 8 hours.

 

a complete mockery

 

SEDEX audits cover a completely different area of ethics to food safety.  It should be led by HR in my view with support from EHS and Operations and minimal support from Technical.  It shouldn't be signfiicantly extra workload for you.

 

To be honest, having been in a site which didn't take the ETI base code seriously, I valued having a SEDEX auditor push for change.

 

Audits overall though, once you have decent basic standards on paper reveal very little about whether stuff is food safe or not.  But has been thus for years.  It was more than 10 years ago when I was supplying everyone in UK and some international retail and felt the pain.  The thing is nowadays "dedicated" retailer sites are becoming the rarity rather than the norm in the UK so you guys who used to get away with it don't any more.  

 

But I was raising this years ago.  Just saying...

[Buttercup]

I appreciate that Sedex is not a Food Safety audit. As a site we are BRC (unannounced) and audited by every UK retailer, as well as B2B customers. I probably have 30+ external food safety audits a year. 

 

I was just trying to show how this has now spilt into other aspects of auditing. 

 

I wouldn't mind, but we recently had a Pillar 4 Sedex audit, which turned out to be farcical.  Whilst they preached to us about the "Standard" they were quite happy for us to potentially breach "GDPR" and pouted when staff didn't want to show pay slips. We ended up with a critical non-conformance because of this. It was only when another retailer got involved that this non-conformance mysteriously disappeared. Ironically, this auditing body is no longer approved for that retailer. 

[GMO]

I appreciate that Sedex is not a Food Safety audit. As a site we are BRC (unannounced) and audited by every UK retailer, as well as B2B customers. I probably have 30+ external food safety audits a year. 

 

I was just trying to show how this has now spilt into other aspects of auditing. 

 

I wouldn't mind, but we recently had a Pillar 4 Sedex audit, which turned out to be farcical.  Whilst they preached to us about the "Standard" they were quite happy for us to potentially breach "GDPR" and pouted when staff didn't want to show pay slips. We ended up with a critical non-conformance because of this. It was only when another retailer got involved that this non-conformance mysteriously disappeared. Ironically, this auditing body is no longer approved for that retailer. 

 

Ah that old chestnut.  

 

The problem is that there are some sites which will hide behind GDPR when actually having unethical practices.

 

I did an internal audit in readiness for a Sedex reaudit after one site had a mare.  One of the supplier companies refused to show any pay slips to me, not even redacted so I couldn't see names just so I could check that they were paying above minimum wage and overtime according to contract.  When eventually they agreed to show me, I can be persuasive... Guess what?  They were not compliant.  They were claiming to pay overtime and minimum hours but were actually zero hours no overtime.  

 

I agree though that Sedex as an organisation and the CBs need to get their heads around the GDPR issues with the auditing process because there is both genuine risk in auditing if done badly but probably even more risk being hidden by unscrupulous people using it as an excuse.  Likewise anything a food safety auditor looks at is a restricted or confidential document and some of them will be covered by GDPR too but it's only Sedex people get their knickers in a twist about.

 

So I kinda get my nose put out of joint too.  But also I know by my work, I actually got people onto the contracts they signed.  So I get to feel all warm and smug because of that and my nose mysteriously straightens.

 

Welcome to the forums by the way.

[AZuzack]

Holy Moly Scampi! What have you started?!  I love it.  I am seeing new names post.  Lots of good discussions and support across industry.  

 

I can chime in on X-RAY.  With bird flu screwing up the age (SIZE) of the chickens being slaughtered, and large scale chicken productions using mostly machines to process/cut/de-bone the chicken, my previous company saw a very LARGE uptick in bone findings.  We had no way to find or identify the bone contaminated chicken.  We attempted to send out the finished goods 40-80k pounds at a time to an outside company called Flexray.  To be clear, I have no issues with Flexray and was even impressed with what they were able offer.  But even their technology and process could not find all the bones in the product.  Then we had a gasket go missing.  Due to density issues, the gasket could not be distinguished from the product. At one point, my former company had Mettler Toledo bring their X-ray trailer on site to get demos of all the equipment.  So here's the thing, X-ray is great in dry foods like cereals and pastas.  And it sucks for meat products.  It absolutely does not make sense to require X-ray across the board.  Some people think it's ok to force every supplier to hire a company to prove that the x-ray technology doesn't work on that specific line of products.  

 

So while I can appreciate the intent of the GFSI and customer standards, there has to be intelligent thought applied to implementation and valid exceptions.  

 

I also think it is completely unreasonable and disrespectful for a customer to think they have the right to show up at anytime for audit.  It also shows a lack of understanding of the supply chain.  

[AZuzack]

I am currently working on a new plant, and for the certification audit to take place a minimum of three months production data should be present. However many of our customers are adamant that they cannot receive products from a ''uncertified'' plant. It feels a bit like the chicken and the egg....what comes first?

 

And off course I don't expect companies to accept a new supplier without adhering to their quality system. But some are so rigid that they are actually not improving on food safety.

Yes they can.  My previous employer had the same thing.  Some of the customers granted a temporary approval that's why there's management of change procedures and Risk Analysis and Customer audits (even virtually).  But really we just didn't produce much (like 10% capacity) the first 3 months.  Product can be donated.  There's distributors that will buy small batches for their small customers.  

[AZuzack]

I'm going to have some grumbles with V6 of fssc 22k coming soon.   Like a requirement to have a kill step instruction set on every label.   We manufacture for certain customers who consider the actual prep a trade secret, and we don't have anything on their labels other than legalities.   And if it's not required by the feds. how can GFSI set such requirements?  

I see a few things already in V6 that is GFSI/NSF getting a little big for their britches....

We have a very generic kill step statement.  "For Food Safety, cook until product reaches a safe minimum internal temperature of 160F or above."  

Keep in mind that 160F is for Beef/Pork.  Poultry would be 163 or 165F.