7 replies to this topic

[GCV]

Hello,

 

I work in a consulting capacity for a small flour mill. I help them keeping the procedures up to date, carry out the internal audits and assist with the management review. I have received certified training as an internal auditor in the past and worked as a consultant for GFSI certified companies for 6 years at this point. 

 

During the FSSV V5.1 audit a non-conformity was noted by the auditor as for the quality manager and myself as the internal auditor no proof of a FSSC specific training could be demonstrated. It is true that both us have not received such a training, but the quality manager has over 13 years of experience in his current position and I myself can demonstrate my experience with GFSI certification audits and their standards. It is important to state that this is a simple single site company so any multi site requirements are not applicable.

 

For this non-conformity the auditor pointed to requirement 7.2 from the ISO22000:2018 standards, but in my interpretation this does not conclusively state that any specific FSSC training is required? From our reading it requires companies to define the requirements to declare a person competent for a specific position and species taking into account their academic formation as well as work experience and any relevant training they received.

 

Has anyone else had problems with uncertainty concerning this requirement?

 

Thank you in advance for any advice you can offer.

[SQFconsultant]

I find it much more advantagous to just go and buy a trainng program, take the test and get a certificate.

 

You could always list experience, etc as your come-back, but trust me, it is way easier to just take the training - which you can give to each other inhouse and then be able to show proof of it. 

[GCV]

Understandable, but FSSC training is very expensive here in Europe and the amount of companies going for FSSC has been dwindling for years now. If training is unavoidable it would not be worth it financially to continue with FSSC audits at all unfortunately.

[SQFconsultant]

Well, I don't know what "expensive" means for you - means different things for different folks, we offer one for 777 for up to 7 people and take all XRP on cross border payments, however this site also has there own IAT so I'd start there first.

[Tony-C]

Hi GCV,

 

 

Welcome to the IFSQN forums.       

 

As part of ISO 22000 7.1.6 Control of externally provided processes, products or services, the company should have established and applied criteria for the evaluation, selection, monitoring of performance suppliers of services such yourself.

This would include: retaining documented information of these activities and any necessary actions as a result of the evaluations and re-evaluations.

 

So the company should have had documented evidence from you that you are competent to carry out the contracted services, so CV, experience, qualification, training completed etc.

 

The same applies to 7.2 Competence.

 

I personally would expect a person contracted to complete Internal Audits as a consultant to be a qualified Lead Assessor having completed a relevant ISO or FSSC Training course. Clearly if you had completed the FSSC 22k Lead Assessor Course then you would not have been included in the non-conformity.

 

The alternative is to document the level of experience that both you and the Quality Manager have in implementing FSSC 22000 systems and decide if it is really adequate.

 

Kind regards,

 

Tony

Edited by Tony-C, 09 February 2024 - 04:46 AM.

[MOHAMMED ZAMEERUDDIN]

It is expected that a person fulfilling the role of a consultant for Internal Audits should be a qualified Lead Auditor who has successfully completed a relevant FSSC Training course. This will help to demonstrate your expertise and ensure compliance with the standards.

[Jacqui]

We are FSSC certified in Australia and do not have any FSSC certified training.  I am the QA Manager with Lead Auditor training, although quite a few years old.  I have formally trained and signed off others conducting internal audits and re-assess this each year.    We also have documented in our procedure that the QA Manager is deemed competent by nature of the role.  We have never had an issue.

 

The standard lists the following in Part 1 - 9.2 Internal Audits: c) select competent auditors and conduct audits to ensure objectivity and the impartiality of the audit process. No mention of FSSC training.

 

In addition, as a consultant you would be considered a Service Provider.  Therefore 7.1.6 and 7.2 in Part 1 would also apply.  Again, no mention of FSSC training, only appropriate education, training and / or experience.

 

Has the company documented in procedure how they meet these requirements? 

 

You could query the CAR with the auditor.  If it only relates to FSSC training I would ask where this is in the standard.  If it relates to other required documentation, this can then be addressed.

Edited by Jacqui, 15 February 2024 - 01:06 AM.

[GCV]

Yes, the necessary requirements were documented in a procedure and verification that these requirements were met for all relevant personnel was also available and demonstrated at the time of the audit. Unfortunately the CB has come back to me that even with all the provided evidence they stand behind the non-conformity and have stated that the only acceptable solution for them would be FSSC specific training. They also admitted that this is not written as is in the ISO22000 standard. But seeing as the auditor has the support of the CB I don't think there would be anything to gain in arguing this point further with them. 

 

Thank you to everyone for their advice and experiences in this matter!