35 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