Unannounced Audits - Small Company

Hi all,

I've never had an unannounced audit before. Two questions: (1) do all companies need to have 2 people with scientific backgrounds on staff so there is always coverage for an unannounced audit? (2)  Am I allowed to be called on Teams for help with questions about the HACCP plan or some of the more difficult topics (for example - how did we set the limits for the environmental tests for what is and isn't acceptable)? 

I work and live near the headquarters of our company. We have a daughter company a 4 hour plane ride away. The daughter company has 4 office staff and 4 people in production. I've been working with the whole staff providing trainings for the last year on our programs and they attended the last planned audit. I flew there for the audit to take the lead. A person from the office and the lead in production sat in on the whole audit to participate and also to observe and learn how an audit works.

I plan on doing mock audits with them to prepare them for the unannounced audit. The staff is well trained on the GMPs, CCPs and regular operational procedures. Safe food is prepared without my presence. One office worker and a couple production people have taken several external trainings in the past year about HACCP, FSSC, etc. I'm most worried about the scientific info behind the HACCP plan if they are questioned by the auditor.

What do other small companies do in this case? 

is your HACCP plan or plans so complicated that someone with a scientific background is needed to review with an Auditor??

I am the SQF Practitioner and QCM for a small company; I have been in this field for 3.5 years...long enough to get us certified and to go through 3 SQF audits (including the unannounced one just last month.) I have found that the auditor wants to know that I understand the code and how it applies to my situation. However, there has also been an understanding that I cannot know everything. In those cases, I pull in someone (usually the president, who has been here 40+ years and does know everything, except maybe all the code details!) and let him explain some of the more technical processes. I've never had an auditor bat an eye at tag team. But I would think this would be no different than larger companies that have several people working within a larger QC department. 

That being said, I have full understanding of HACCP and can explain how it works and why. And president is here, not a plane ride away. What is it that the people on ground would not be able to explain to auditor?

Having someone on site with a scientific background is not required.  Having someone present who acts as the SQF practitioner and understands the processes is what they're after.  And there's nothing wrong with having various members of the team, even a leader in the company, be present via phone during the audit.  I handle supplier approval for 8 of our corporate facilities, and when it comes to the section on suppliers I call in via Teams to answer questions.  We've done full audits on video with Teams running in the background and various VP's jumping in and out as they want to observe.

Hi All depents on the complexity of you HACCP plan or plans you have to cover. For example I work as a Quality manager in an industry making flatbreads in Greece so I have only one HACCP plan that includes all of my products. I do not need any other assistant to do the job. 

Never the less in you work in a catering you will definetly need assistance ... I think .....

Hi Fatsquirrel,

With the FSSC Certification Scheme you should be given a time window for the unannounced audit which is typically 30 days.

Contrary to a couple of the previous posts, with the FSSC Certification Scheme there is no requirement for an SQF Practitioner, the term used is a Food Safety Team Leader.

If you are regarded as the Food Safety Team Leader, for your contribution to this audit if you are not going to be present on site you should ask the certification body to follow FSSC 22000 Additional Requirements Version 6 - 5 Planning and Managing Audits Section - 5.2 Multiple Functions across more than One Site and for a call on Teams to be included as part of the audit.

5.2.1 Head Office Functions (have a look at this section as I have only quoted the most relevant part and other parts may be useful)

1) In all cases where functions pertinent to the certification of the site (such as procurement, product development, supplier approval, quality assurance etc.) are controlled by a Head Office (part of the same legal entity or part of the same larger organization), the Scheme requires that these functions be audited and included in the certification of the site, including interviewing the personnel described in the FSMS as having the (delegated) authority and responsibility for these functions. This Head Office audit shall be documented.

There is also no requirement for a scientific background but there are requirements for the food safety team to be competent on the basis of appropriate education, training and/or experience. I personally would expect at a minimum some sort of basic HACCP training for food safety team members. See below for requirements stipulated by ISO 22000.

ISO 22000:2018 Food safety management systems - requirements for any organization in the food chain

5.3.1 Requires top management to assign responsibilities and authorities including: 

c) appointing the food safety team and the food safety team leader;

5.3.2 The food safety team leader shall be responsible for:

a) ensuring the FSMS is established, implemented, maintained and updated;

b) managing and organizing the work of the food safety team;

c) ensuring relevant training and competencies for the food safety team (see 7.2);

d) reporting to top management on the effectiveness and suitability of the FSMS.

7.2 Competence

The organization shall:

a) determine the necessary competence of person(s), including external providers, doing work under its control that affects its food safety performance and effectiveness of the FSMS;

b) ensure that these persons, including the food safety team and those responsible for the operation of the hazard control plan, are competent on the basis of appropriate education, training and/or experience;

c) ensure that the food safety team has a combination of multi-disciplinary knowledge and experience in developing and implementing the FSMS (including, but not limited to, the organization’s products, processes, equipment and food safety hazards within the scope of the FSMS);

d) where applicable, take actions to acquire the necessary competence, and evaluate the effectiveness of the actions taken;

e) retain appropriate documented information as evidence of competence.

NOTE Applicable actions can include, for example, the provision of training to, the mentoring of, or the re- assignment of currently employed persons; or the hiring or contracting of competent persons.

HACCP Application is more complicated with the FSSC 22000 Scheme because of the need to assess hazards/control measures and decide if they are to be managed as prerequisite programmes, operational prerequisite programmes or as critical control points.

Your site food safety team members should understand and be able to answer questions on the following requirements in particular.

ISO 22000:

8.2 Prerequisite programmes (PRPs)

8.5 Hazard control

8.7 Control of monitoring and measuring

8.8 Verification related to PRPs and the hazard control plan

8.9 Control of product and process nonconformities

ISO/TS 22002-1 Prerequisite programmes on food safety — Part 1: Food manufacturing

FSSC 22000 Additional Requirements Version 6:

Section 2.5.9 Quality Control

Section 2.5.11 Hazard Control and Measures for Preventing Cross- Contamination

Kind regards,

Tony

Phone a friend is a valid option during the audit - don't be afraid to have Teams, Text, etc. open and send regular commentary to the "expert". 

Make sure the person onsite can explain the basics - Facility tour, HACCP plan, Regulatory Documents, Traceability/Mock Recall, etc. 

      I run through the audit before hand, and write out Policy names/numbers so I have a ready reference. 

Make notes throughout of questions that need to talk with someone else, then bring them in (phone, Teams, in person, etc). This can be anyone who has the answer.