Auditor Dispute: Sampling Technique Competency vs. Test Procedure Effectiveness
As a trainee auditor for FSMS (ISO 22000:2018), I recently conducted an audit where I observed that water samples for chemical and microbiological testing were being collected by an employee who had not received specific training in sampling techniques. I identified this as a non-conformance related to competency; however, my senior auditor disagreed, stating that the concern relates instead to the effectiveness of the test procedure rather than personnel competency.
I am seeking clarification on this distinction from the forum, as I am uncertain about how such an observation should be categorized. Thank you
Does it matter? It needs fixing...
You could raise it as a failure of leadership to assign a job to an untrained employee...
Perhaps you need to understand the root causes and fix it and that be the priority?
I even had to learn and pass the 'sample preparation' subject in uni.
https://chem.librete...ple_Preparation
IMO, if there's no personnel with a degree supervising the testing processes, NC should be issued for this big competence doubt.
If you can find anyone whose major is related to lab jobs, you can leave a recommendation about training the operator.
Hi rams,
Some ISO training for auditors can be quite anal about selecting a clause for a non-conformance. This could fall under competence or verification if the method doesn’t include sampling techniques (see below). As GMO has posted, I don’t think it really matters which clause you categorise if as non-conforming against, it needs fixing and that is the main aim of your audit, identify issues or areas for potential improvement and then the organisation taking appropriate actions.
ISO 22000 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
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.
ISO 22000 8.8.1 Verification
The organization shall establish, implement and maintain verification activities. The verification planning shall define purpose, methods, frequencies and responsibilities for the verification activities.
The verification activities shall confirm that:
a) the PRP(s) are implemented and effective;
Kind regards,
Tony