Should Food Auditors Play God?

The client and I decided to "interview" a food auditor recently who had wanted to pitch for an audit/certification job.

We realised he was quick to volunteer information and made some serious suggestions along the way which we thought were somewhat overkill. Basically, we were asked to do "air monitoring and air-particle tests" and the facility is NOT even a clean-room or an aseptic-pack environment.

Wooden pallets were a HUGE NO and in replacement plastic type. Reason, pest harbourages is a problem, as if, the pest shys off plastic pallets.

This to me is a very raw food auditor and has no idea that a HACCP Program would take years to build over time. An inexperienced auditor can be very dangerous. Not only will there be massive "Corrective Action Requests" along with MAJORS, certification will be hell for the client. Shouldn't all food auditors have the same qualifications? Afraid, they are but they all work in mysterious ways.

Questions:
1. Should you as a client be entitled to have the resume of the food auditor whom you are going to have to deal with for the better or worse before engagement.
2. If you think you had a bad auditor last year, would you remain silent if you are allocated the same auditor this year.

CharlesChew

Thankfully the variance in auditor experience, ability and consistency is not such a problem with the BRC Standards; as only Certification bodies who are accredited (or are seeking accreditation) to EN45011 (ISO/IEC Guide 65) with the appropriate scope can carry out Evaluations against the BRC Standards and issue certificates.

For the BRC/IOP Packaging Standard in particular auditors had to pass through an Institute of Packaging (IOP) course, I think it was called Equipped. This was because most of the auditors were predominantly from food backgrounds and did not have much experience of packing processes at the time. I think the theory they gained from the EQIPT course allied with the couple of year's practical experience the auditors have now had, has made the BRC/IOP auditing process as consistent as it can be.

Regards,
Simon

The key disadvantage with the current state of HACCP schemes are that international accreditation bodies have not come up with a harmonised  approval method.

It is good to know that BRC/IOP is in good hands. Sadly, commercial reasons have become the better of professionalism at times. And, this does happen in places sometimes you least expect and from organizations unimaginable.

But it is comforting to know that we have leaders in this field continuosly striving for progress and as Hak had put it nicely, "to come up with a harmonised approval method" which should help promote standardisation.

While, remaining hopeful that the forthcoming WTO will help allign those misguided industrial standards achievers (for what they are worth)..........there is, if I may add, still HOPE.

Regards
Charles Chew

The attached document is Appendix 2 of the BRC/IOP Packaging Standard. It does demonstrates the value of an Accredited Certification scheme, in so much as it adds some control and hopefully consistency to the way the standard is applied by auditors. At least the auditors are audited.

Regards,
Simon

Simon,

Don't get me wrong. I have a lot of faith in the system. I do not have a choice but be also mindful that the auditor is afterall a human being and he is also prone to err in his judgement at times.

If we seek improvements in our system by challenging it then what is wrong with challenging the opinion of an auditor if we feel that an audit opinion does not stand to good logical reasons. Even if an opinion is beyond fairness and is not supported by facts but instead merely a personal view, should we take the "bullet"?

By the way, I do have good relationship with most food auditors where I come from but I do however, have particular respect for those who reciprocate the same.

Regards
Charles Chew

Don't get me wrong. I have a lot of faith in the system. I do not have a choice but be also mindful that the auditor is afterall a human being and he is also prone to err in his judgement at times.

And as human beings they have diverse personalities. In my experience the pragmatic auditor who is willing to share their experience and ideas (without consulting) is an infinitely better auditor than the one who is simply determined to find as many nonconformities as humanly possible. In the latter case the astute auditee can often do well employing a few ego massaging techniques.

'Wow! I can't believe you picked up on that John, that's really going to help us to improve the process - Thanks!'

Because people are people there will always be variability of auditor personality to contend with. My earlier point was, where auditors are required to have specified qualifications and competencies as a requirement of an Accredited Certification scheme, such as BRC, this helps to reduce the variability by a few degrees. It's by no means perfect but it helps.

Perhaps auditors should have to undergo psychometric tests. In which case what qualities and traits make a good auditor?

Regards,
Simon

Hi Simon,

Again, we are on the same page as far as diversed personalities are concerned. Doesn't it sound like striking a jackpot when you get the auditor you wished.....

Thank god, we do have guidelines for these "aliens" coming to site searching high and low for non-conformances. Actually, I have never once seen an audit report that has a clean slate on deviations. No offence meant.......I "audited" two auditors recently and on my scorecards, they have failed to impress me on competency and characters.

Sad!

Charles Chew

An auditor with a decent sense of humour makes such a difference. By sense of humour, I'm not saying they have to wear a red nose and big floppy shoes. I just want them to be able to crack a smile once in a while, and not get too uptight when I play my hilarious flower squirting joke on them. Now wouldn't that be fun?

Regards,
Simon

On that note, I just wish to add that it is extremely courageous for a first timer to face their 1st External Audit let alone managing a system be it HACCP or ISO (and those who had experienced the intensity of it would probably support this assumption.)

I can but only tell you that managing a HACCP program with a vison for continuous improvement is not a simple task at all.......no honeymoon babe!

So, if there are any food auditors out there "listening" in, please spare some kind and encouraging words and same time, be pragmatic.

On that point, I just had a buzz from my regular auditor today and mind you, she is from a huge organization. Told me that base on her research and feedback, she agreed with my challenge and would accept the parameter that I indicated for the impending audit.......thats not what I call a freindly auditor but one that leaves behind a notable impression upon the client that could only be but encouraging.

Regards
Charles Chew

Dear both of you,

For this topic, I face a lot of troble of EGO Auditor mostly low emotional Quotient and full of square head. It really depend on experience and logical thinking as well as deep understanding of Codex intention . Many words in codex eg. if possible and risk assessment skill should be concerned prior to write CAR. As auditor I agree with this point.

Hi Vipatikom,
It is sad that some Food Auditors portray themselves in this manner isn't it. If you look at things in a sensible way, any fools can really find faults amd it sometimes leave me to wonder if these silly auditors were to be asked to develop and implement a HACCP Plan for a company, would they be able to do a decent job.

Fortunate for us - not all are like that.
CharlesChew

[Hi there,

In my point of view, value added auditing can be present by CAR. Good auditor shoud be aware that his CAR must be really agreed by all party. Risk assessment skill of auditor must be shown as one responsibility during the audit. I heard from lot of clients about unresonable CAR cause a lot of investment. Normally historical data should be checked for likeliness of occurence prior to issue serious CAR.

Risk assessment skill of auditor must be shown as one responsibility during the audit.

CARs are subject to disputes at times BUT should be challenged if and when they are unreasonably supported. Auditor's risk evaluations shd be respected as much as being subject to criticism as well. Auditor's risk evaluations have been known to be wrong.

Normally historical data should be checked for likeliness of occurence prior to issue serious CAR.

Personally, I do not condone the practise of Management Review which is more for ISO. There is really nothing to review. In the case of HACCP, revalidation is more appropriate and by doing so, the likelihood of occurrence would have been exposed in this case, CAR :D

Regards
Charles CHew

Personally, I do not condone the practise of Management Review which is more for ISO. There is really nothing to review. In the case of HACCP, revalidation is more appropriate and by doing so, the likelihood of occurrence would have been exposed in this case, CAR :D

<{POST_SNAPBACK}>

It's not often I disagree with you Charles, but IMO it's very important to take a high level strategic view of the system every once in a while. If nothing else it gets the Head Honcho to focus his attention on HACCP and food safety issues for a few moments. It also helps to keep him connected. After all he does hold the purse strings and you never know when you might need him to loosen them.

Is it too much to ask for his undivided attention for an hour or so, once a year, before he returns to do whatever it is that Head Honchos do.

Regards,
Simon

Hi,
one example of risk assessment during audit for clarify my meaning.
about potable water which need to be used in case of food contact. some parameter can not be checked in some country because of huge investment and lack of appropriated laboratory. ABS ,for instance, normally is used for detergent manufacturing. This parameter need to be checked as per WHO drinking water standard. The inherent reason of WHO for this parameter was that in drinking water industry there were bottle cleaning process which detergent must be used before filling.
Anyway, if we can prove during the audit that no such detergent was found in water supply production as well as low quantity of water need because of being food dehydration process. Beside, this substance is now substituted with other chemical in this contry while Drinking water is not updated . ABS may be skipped in this case as CODEX RCP 1999 on preamble said.
some auditor push this problem to auditee, while ABS inspection Fee was almost equal to certification fee.

That is the case,

s it too much to ask for his undivided attention for an hour or so, once a year, before he returns to do whatever it is that Head Honchos do.

I guess not............he is the BOSS.

But Simon, just spare this a thought. The trend for HACCP (at least down under) is moving towards revalidations and by doing so, we are NOT exactly "removing" the presense of the Head Honcho. Revalidation requires Management's Approval anyway. So, nothing has changed with regards to his involvement.....but the terminology has and the impact of revalidation vs M. Review is really quite significant.

For your information, my GMP on this reads as "Management Review & Revalidations ............ I have not entirely removed the whole issue of MR

Charles Chew

An auditor recently was not happy with our hazard analysis on critical control point format. We used a format recommended by the National Food Processors Association, USA - a system which we are impressed with for simplicity and effectiveness and had since adopted it.

Just because an auditor is not familiar with the format, does this justify that it cannot be accepted despite the end result of the analysis being well justified and rightfully should have the same results whichever methods used. Of course it should - the fundamentals and principles of hazard analysis is the same.

At point of writing, we have yet to mutually concur as we are challenging the auditor's remarks. Auditors need to be familiar with changes too.

Charles CHew

Auditor owes you an answer as to WHY he was not happy about your format - scientifically stood on the shoulder of a giant - the NFPA of USA....

If I'm not wrong.... management review refers to continual improvement of system.management and control.food safety performance.... while revalidation refers to the technical aspects of process.product safety as claimed....

Masculinie

management review refers to continual improvement of system.management and control.food safety performance.... while revalidation refers to the technical aspects of process.product safety as claimed....

Yes! Yes!

Charles Chew

Auditor's strong reference to the CODEX was discussed and we have reached a viable solution (a solution we had already done w/o her knowledge) to support the format that we had used following the NFPA approach.

Yet to confirm is whether the information contained in the support documentation would be agreeable to the auditor. We hope so.

Mind you, we are doing away with the matrixes normally used in assessing and justifying CCP identification. So we are really getting into serious "water" here. I believe our challenge will stand out.

Charles CHew

Can I invite people who are familiar with guidebook "HACCP - A SYSTEMATIC APPROACH TO FOOD SAFETY" by Kenneth Stevenson and Dane Bernard (NFPA) to participate in some food safety discussions with regards to hazard risk assessment methods as suggested in that book.

I find the book simple to understand and it presents a unique and clearcut approach to assessment of hazards and so forth. It has changed my entire outlook on HACCP and the ways that it suggested to effectively deal with it. This request concerns some differences in opinion with an auditor that did not quite agree to the fundamentals as described in this book. So I hope the administrator will not move this topic to another section.

We could have good thread here if participations are willing.

Charles Chew

Matrixes.... you mean the decision tree ?!

Yes - through assessment of identified potential hazards via degree of severity, risks and likelihood where common to find different types of matrixes used for evaluation like 1 to 10 or High, Medium and Low which most of the time can be difficult to qualify or quantify. We found this book and liked it and of course used it. Codex does not mention use of specific matrixes so any format that justifies is okay.

If you are familiar with the format, opinion or comments on compliant to the codex standard is appreciated using this method of CCP identification i.e. a need to address the potential hazard in the HACCP Plan and why it must be addressed via written justifications and NOT by giving quantitative justifications normall done.

Comments please
CHarles CHew

Should the statement - "Does this potential hazard require to be addressed in the HACCP Plan? - Yes / No" be replaced by the 3-Column Risk Assessment Structure "Severity" "Risk" and Significance" when a simple "Yes or No" under the former approach would simply suffice.

My argument is - The crux of it all is in the justification written/supported in words and NOT in the 3-Column Assessment Structure which seems rather questionable at times with regards to the matrix applied and the quantitative support.

Comments on this appreciated.

Charles CHew

You could justify all you feel in words.... with subjectivity.... but opened yourself to big challenge.... - and always ended up your opinion against the auditor's opinion....

The purpose of the structured RA is to render the judgement more systematic with less subjectivity.... though may still be with subjectivity.... but to a lesser degree....

Applying consistent RA methodology and criteria.... acitivity by activity.... can be more 'scientific' than supporting by qualitative arguement.... out of empirical basis....

Note the quantitative support has to be to a set of defined criteria as well.... though there may still be subjectivity.... by individual feel....

The end product of the RA is less variance by individual feel.... though it may not assure no variance by individual feel - but better consistency as an outcome is a nearest result one could get.... away from expression of opinions without structured support....

I will not risk into narrative support of my RA effort....

Masculinie










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