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BRC Internal Auditing Query

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Pratikgore

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Posted 01 April 2024 - 07:53 PM

Hi All,

I hope you all are doing great. I am currently working as a QA Manager at small scale ready to eat meat manufacturing facility in Ontario Canada. Our facility is BRCGS certified facility. Currently, I am working on risk based BRC Internal audit schedule. I Considered pervious external audit non conformances and customer complaints in the internal audit risk assessment. Now there are almost 6-8 BRC clauses where the internal audit frequency set at 4 times a year, some of them are 2 times a year based on risk.

We do have external auditor coming every year who performs internal audit covering all the clauses per year.

 

My question is: If I have revised and updated all the policies and procedures which are refereeing and complying all BRC standard clauses, then am I still eligible to to perform internal audit myself on those clauses for which the frequency set at 4 times / 2 times a year the internal audit schedule ? I do have the past internal auditing experience in SQF.

 

 



kingstudruler1

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Posted 01 April 2024 - 09:04 PM

The clause states "Auditors shall be independent (i.e. not audit their own work)".   You could run into an issue with this with policies, procedures, programs that you have written or updated.  Ive seen auditors lt it slide for pretty small companies but there is no gaurantee.   

 

You would need to have some kind of documented training can be internal company provided or third party.  IFSQN  has an inexpenisve class that is quite good.   

 

When the you pay someone to do the audit is it spread out over at least 4 dates througout the year?  or how are you currently complaint with this clause?


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Pratikgore

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Posted 02 April 2024 - 02:22 PM

Hi kingstudruler1,

Thank you so much for replying. Last year only I joined this facility as a QA manager, so, I could perform the internal audit last year because food safety programs, polices

and procedures were written by previous QA managers.

But throughout the year I revised and updated a lot of programs, polices, and procedures. I do have a technical manager who is also back up for my position.

She do not have any internal audit certification but she performs monthly GMP audits and  if I can train her on the internal auditing  then Can she perform the internal

audit of few clauses? I do have the BRC lead auditor certificate.

Although only high risk clauses needs to be audited 4 times a year internally. We pay external auditor who just conduct one internal audit a year who covers all the clauses once a year.

 The rest of the BRCGS clauses (High risk and medium risk) needs to get audited 2 times or 3 times a year which I spread it through out a year, can my technical manager 

perform the internal audit on these clauses  twice or thrice a year depends the risk based internal audit schedule?

Thanks.

 



kingstudruler1

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Posted 02 April 2024 - 03:18 PM

She do not have any internal audit certification but she performs monthly GMP audits and  if I can train her on the internal auditing  then Can she perform the internal audit of few clauses?   

 

Absolutely, there needs to be a record of training and i would keep a copy of what the training was.  Honestly, for about $100, the ifsqn is course is just easier than developing in house training and delivering IMO.  The training is very well done.     

 

I have never seen the training requirement waived for those doing only GMP audits.  They should have the training regaurdless.  

 

When I say the 4 times per year, I am referring to the following:   "At a minimum, the programme shall include at least four different audit dates spread throughout the year."    You may be in compliance with, I might not be understanding your program.  It sounds like you are doing the entire program at one time.   Then doing the higher risk causes 2/4 times throughout the year.   Im not sure this is compliant.   


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GMO

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Posted 02 April 2024 - 05:35 PM

Remember the four dates per year is intended to spread internal audits out not a prescription that each clause needs to be audited four times. Could you get your consultant to do two half days and then cover other clauses in the team, perhaps wth other functions where you can't be independent? Especially clauses where you do decide they need to be audited more than once.





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