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Should Food Auditors Play God?

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masculinie

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Posted 22 October 2004 - 12:36 PM

Thought the part of deciding yes/no is supposed to be a decision tree effort.... again scientifically conducted?!

Masculinie



Charles Chew

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Posted 22 October 2004 - 12:58 PM

Sure thats where the justification kicks in with the support of scientific support / ind standards or historical incidences ????. Whats the difference between saying yes or no to high medium or low anyway? Is it or is it not scientifically supported if warranted in the area of microbial save for certain circumstances!

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masculinie

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Posted 23 October 2004 - 11:26 AM

Too simplistic to say yes.... even if supported scientifically or with industrial standards or historical indicences.... or no - if not....

It is still wise to follow a consistent set of methodology and criteria.... to apply activity by activity - to prevent subjectivity....

For each activity.... it is still wise to be given a choice to decide the likelihood and severity for a specific activity - leading to a judgement in significance.... - with or without supports.... and apply it consistently throughout the assessment....

It is a boring exercise.... but it is consistency and less subjectivity that matter....

To answer the question 'does this hazard required to be addressed in the HACCP plan'.... it is a matter of a decision tree and not more columns of 'likelihood.severity.significance' - that I'm sure....

With this methodology and criteria.... even with historical incidence or scientific support or industrial standard.... you still have a choice to feel for your specific activity for 'likelihood.severity' and may end up to be insignificant.... away from all theories.... - or vice versa....

Masculinie



Charles Chew

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Posted 24 October 2004 - 04:01 AM

Sometimes it gets very ironical doesn't it when one knows that a simple yes or no would suffice with the support of justifications that would give weight to the severity, risks and significance in a qualitative approach rather than a quantitative manner and yet, we claim a HACCP Plan is a dynamic and a living set of documents when we continue to choose to remain reliance on old methodologies. :uhm: Gotta inform NFPA (huge food association in the USA) that their method of pursuing Haz. Analysis may be wrong then......would I then be stirring up a hornet's nest?

As a sign of relief, another CB has recently adopted similar method of simplicity but I did not quite agree with their assessment CCPs on ingredients when approved suppliers list as a pre-requisite will do including the fact that Haz Analysis will take into consideration these issues at the raw material stage anyway.

A classic example - how does one evaluate pesticide residue in a hazard analysis for CCP identification at the ingredient stage. Do we reply on a simple COA or do we take every in-coming goods for laboratory tests to appease ourself that it is not "severe" nor significantly risky enough to pose an adverse food safety issue during production? Sounds simple but would like to hear your comments on this anyway.

A good discussion so far. Great!

Charles Chew


Edited by charleschew, 24 October 2004 - 04:07 AM.

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masculinie

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Posted 24 October 2004 - 06:45 AM

There is no old or new methodology.... there is only good or bad methodology.... - and any methodology simplistic as it may be yet could land a situation into that of confronting or contrasting opinions.... or expression of nothing but an opinion - will just have to be avoided.

To prevent subjectivity.... consistent methodology and criteria well stipulated beforehand and discipline in sticking to them activity by activity.... - is just a good evaluation practice....

And the process could well be executed by a HACCP team rather than an individual - who could be too product safety oriented.... or at the other extreme a sales personality.... - to strike a balance between the various opinions.... and come to a less subjective outcome....

Back to the pesticide residual.... sales may think that it is of low likelihood and medium severity.... since nothing as such has happened to his past 20 years experience from a single source....

Into the hand of a food-safety specialist.... the answer is likely to be 'yes' straightaway....

So.... the methodology allows the team to come to a less subjective outcome by ranking....

the RA approach will just have to be pragmatic.... to take into considerations of also commercial and business and law requirements.... other than that of a food specialist....

That 'obvious' yes or no as a matter of opinion - will just have to be avoided.... and there is no room for pride and prejudice....

A one-time baseline test for the pesticide residual may be good enough to prevent the initial challenge against the company experience....

Masculinie



masculinie

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Posted 24 October 2004 - 06:58 AM

Further to the above elaboration.... let me add further that....

There is no such thing as obvious yes or no.....

What is obvious to me may not be obvious to you.... to us.... to them.... to all....

One shall not fall into the trap of 'taking things for granted'....

And the last thing we want to do is to claim superiority over our subjective opninion.... as against others.... - and refuse to admit each other's opinion....

Any methodology that could prevent such scenario.... is a good methodology....

Masculinie



Charles Chew

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Posted 24 October 2004 - 04:29 PM

I guess subjectivity is really a result of the outcome of how people evaluate things. Theories and talks are fine but in reality it is not as simple as what is written if another party have a different opinion more importantly an auditor who is really going to decide whether he/she thinks one is correct or wrong or in your term good or bad methodology.

Well, as we are taking this case up with the auditor this week and HQ at Houston, Texas, onew thing is for sure, a professional opinion on this matter will be given.

Thanks for your input. We will let sleeping dog lie for now.

Charles CHew


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masculinie

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Posted 25 October 2004 - 06:49 PM

Yes... let the matter rest.... pending your outcome with best hope....

Since you are the party setting up a scenario of an opinion against others.... allow me to say.... you should not arrive at a subjective opinion of 'auditor trying to play God'....

Auditor is just doing his part of a paid job....

And when you are trying to prove your technicality as a matter of your opinion.... just make sure that your client does not suffer commercially.... - and that's only professional....

Good luck,

Masculinie



Charles Chew

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Posted 26 October 2004 - 03:50 AM

If you are a food auditor making a statement here thats fine. But it is exactly the reason that my client suffered as a result of imcompetency that resulted in this topic being raised. Sure, you cannot put one bad apple in a basket and claim all are bad but it is a fact that the lack of clear audit standard has put clients at risk.

Surely following NFPA's methodology cannot be wrong and if it is, I have nothing to add becos an institution in the forefront of HACCP is then being questioned.

I have removed auditors before for the sake of my clients and i will continue to do so if any signs of imcompencies are shown (You really have no idea how rediculous some of the auditor's findings are). Respects are mutual between clients and auditors and that is why we have a right to challenge food auditors to maintain standards. Are food auditors so jaded that they can be so afriad to be judged by others? Common.....

You have raised your point and I have mine........and the subject has probably benefited many in the light of looking at auditors in a way where they are just humans and are likely to err (and I know a lof have erred before) so lets just allow this matter to rest. I know for sure that i will post the outcome of my meeting with auditor / CB hopefully next week.

Charles Chew


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masculinie

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Posted 26 October 2004 - 02:49 PM

Peter Druker is not always right.... neither is NFPA.... and no golden rule is perpectual to inhibit new learning - when there is a confusion.... always go back to the first principle.... of 'why HACCP'....

You are respected for who you are.... not what is your background or who is behind you.....

To expect Food Auditor to maintain standard.... is different from battling him since he is of different opinion.... or to canvass crowd support to overturn him.....

Will be interested to know the outcome of your battle.... - to see if the CB stands by the first principle.... or buckles under normal commercial pressure....

All said.... let me also clarify that I'm always at the other side of the Auditor.... supporting the industry from being abused like you....

But I'd prefer to keep an open mind to listen first.... and get back to first principle to rationalize things out.... ready for either party to unlearn and relearn any a time....

Masculinie



Charles Chew

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Posted 26 October 2004 - 04:34 PM

Thanks for your contribution. You have been a great participant.

Charles Chew


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Charles Chew

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Posted 30 October 2004 - 10:39 AM

Thought I will post this before I go out of town on Monday. Yes the meeting with the auditor was good with interesting issues raised. CODEX was unquestionably the point of audit reference despite whatever is going on "out there" and both had reinforced our past approach that the HACCP development process and format should be practical and simple for the HACCP Team particularly when in their 1st - 2nd year of HACCP engagement as well as meeting audit compliance to expected requirements.

It was a good meeting achieving mutually conclusive directional path on our new approach to making HACCP implementation as pragmatic as possible. Thanks to an understanding auditor who has a brilliant food safety background and applying a realistic approach with a good understanding of the commerical problems. We hope all food auditors can be like that ..........

Charles Chew


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Edwina Chicken Currie

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Posted 12 November 2004 - 11:56 AM

Here's a thought guys...

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

Well ..... I'm HERE!!!

For this topic, I face a lot of troble of EGO Auditor mostly low emotional Quotient and full of square head.

:angry:

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.

:angry2:

I think you'll find that many auditors have 'been there, done that, got the t-shirt'.

If you followed auditing protocols you wouldn't be griping on!

All audits should be performed against a documented standard.
The scope of the audit should be clearly defined and agreed by both parties.
If during the audit, non-conformances are identified, these should be discussed at the time (no surprises at the end).

It is the responsibility of the auditee to demonstrate (and properly explain) any elements of their system designed to meet the requirements of the standard.

Non-conformances can only be raised against the documented standard. Any points raised by the auditor (from their 'experience', or in their 'opinion'), which cannot be justified against a clause in the standard, may be documented as 'recommendation' only.

Auditees have opportunity to discuss non-conformances during the audit, and present additional information if required to resolve the issue, however moaning after the event is bad form.

Audits are systematic assessments - personal opinion shouldn't come into it.

I DO however agree with Simon comment re: personality and sense of humour.... it makes the audit a little more enjoyable.

Please note though: this is a 2 way thing - we auditors dread the defensive auditee who demonstrates a low level of tolerance to auditors, and who cannot see the benefits of a fresh pair of eyes.

:doh:


NEXT PLEASE...............................


Charles Chew

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Posted 12 November 2004 - 01:21 PM

  If you followed auditing protocols you wouldn't be griping on!


Agree with all that has been said. My usual auditor and us have a great relationship that puts all audit jobs on fair game and recommendations often viewed with respects. Thats why we see no need for another pair of fresh eyes when we already have one good pair.

Don't get me wrong but from our experiences, naturally not all auditors have equal "qualifications" especially you mentioned "experience" and sure, a fresh pair of eyes would do good for all but only if the viewpoints are truly beneficial.

BYW, the problems I am highlighting here is not about auditors per se but rather we seem to be coming across a number who seem not to know what they are talking about - and it is deteriorating...............how can that be and if you really truly know what we have to deal with over here....very sad.

Charles Chew

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SpiceGenius

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Posted 12 January 2012 - 02:52 PM

Good Day everyone, I'm a little late posting on this subject but I thought it would interest everyone to know that the "Food Processors of Canada" (http://foodnet.fic.ca/) have put a coalition together to review/discuss food safety auditors competencies.
I think there is nothing wrong with questioning the competencies of an auditor/inspector specially since these people are in such a position of power over our industry.



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Posted 12 January 2012 - 08:58 PM

Good Day everyone, I'm a little late posting on this subject but I thought it would interest everyone to know that the "Food Processors of Canada" (http://foodnet.fic.ca/) have put a coalition together to review/discuss food safety auditors competencies.
I think there is nothing wrong with questioning the competencies of an auditor/inspector specially since these people are in such a position of power over our industry.

Totally agree SpiceGenius, it's vital that the whole chain of certification can stand up to scrutiny if it is to have any integrity.

Regards,
Simon

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