Rights of third party auditors

Hi, I am new to the forum and to food safety. I have twenty two years experience in the pharmaceutical business and am now QA manager of a cheese factory. My question is this. A number of our vendors have been performing audits on our facility lately and I have been very cooperative as far as sharing information. However they have been looking in employees' lockers and in their desk drawers. Is this legal? What is it exactly that they can look at? I want to be cooperative but at the same time the employees have been complaining to me that they feel violated and are angry. Any thoughts? Thanks for helping!

Dear maryr,

Welcome to the forum !

You do not mention whether the auditor's are surveying to any particular standard ?

I presume you are referring to a production worker's locker room area, usually preceding the manufacturing area.

Many companies (but not all) have a ban on certain items being stored in lockers (eg food). Or the relevant audited standard / local regs may hv specific limitations also. If so, auditor's may ask you to open 1 or 2 random lockers for verification. I once encountered a large knife which was somewhat alarming.! However the auditor should always give a valid reason for the request otherwise IMO it is not their business.

You do not mention where the desk drawers are. If in the production area, it is possible the auditor was randomly checking for inappropriate (eg unsafe) items such as drawing pins ? If in an external office, normally not the auditor's business and an unacceptable activity.

Rgds / Charles.C

Hi, I am new to the forum and to food safety. I have twenty two years experience in the pharmaceutical business and am now QA manager of a cheese factory. My question is this. A number of our vendors have been performing audits on our facility lately and I have been very cooperative as far as sharing information. However they have been looking in employees' lockers and in their desk drawers. Is this legal? What is it exactly that they can look at? I want to be cooperative but at the same time the employees have been complaining to me that they feel violated and are angry. Any thoughts? Thanks for helping!

Under what standard? Are you referring to employee's entire personal files or official files?

I think there are certain information that the company chose to keep entirely confidential to itself. Third-party auditor/s and the company usually sign a Non-Disclosure Agreement. . They do have to have the owner of certain lockers and desk drawers for obvious reasons. (e.g. the one in the control of a document or record, to facilitate the inspection, etc) And make sure that the things the auditor/s is/are going to look at have something to do with the audit.

An auditor has the right to inspect areas of production I.e. lockers and drawer in the facility. Office is out of the question and lockers in a change room would have to have employees permission. As stated earlier they would be looking for non-conformance to GMP policies most likely. We just completed an audit in our plant and he also looked in locker in production areas and they were random inspections. No issue with that as I also do it on my regular interal audits.

Hi, I am new to the forum and to food safety. I have twenty two years experience in the pharmaceutical business and am now QA manager of a cheese factory. My question is this. A number of our vendors have been performing audits on our facility lately and I have been very cooperative as far as sharing information. However they have been looking in employees' lockers and in their desk drawers. Is this legal? What is it exactly that they can look at? I want to be cooperative but at the same time the employees have been complaining to me that they feel violated and are angry. Any thoughts? Thanks for helping

We routinely look into employee lockers and in drawers that are located in offices near the production areas and there are a number of reasons for doing so, It is routine for the food manufacturing concerns that we consult with and audit to do locker inspections and many times drawer inspections. Primary purposes are GMP issues, pest control, allergen introductions, etc.

Standard types depends upon Auditor inspection in lockers, recently we were on AIBI audit and auditor was interested to see lockers for compliance with GMP policy. He inspected two to three lockers at random. Train workers in internal audit as mentioned earlier.


Faisal

Dear GOC,

and in drawers that are located in offices near the production areas

Primary purposes are GMP issues, pest control, allergen introductions, etc.

Do you mean you are checking for pests in people's office drawers? Amazing!
I can see a potential stretch if, for example, a site had a "no allergen on the premises" policy but i would not hv thought even this gave carte blanche to search indiscriminately.

I am curious as to whether within standard audit procedures, there is a defined separation line between what might be considered appropriate auditing practices as against simple "intrusion of privacy" ?.

Frankly, i believe that in some locations this operational concept would simply lose you a customer.
(added) - But maybe I'm in the minority.

Rgds / Charles.C

Site rules have varied where I've worked. I would suggest you would need to talk to your personnel department.

Some sites I've worked in have had a policy where any auditor could look in a locker and it's fine, others have insisted upon the member of staff being present, other sites have just warned people prior to the audit.

I would suggest as an internal audit, you should do so with the person present but it's impractical with a third party audit (and sometimes the person can get really defensive so it's not always the right thing). I suggest you work with the HR / personnel and union if there is one to agree to accompanied checks when auditing internally and unaccompanied externally.

After all, lockers are not their property; they are company property and there are rules regarding what can and can't be contained within them.

As for drawers; anything in production areas or offices which adjoin production areas is 100% fair game. Anything outside is going too far.

Dear GOC,




Do you mean you are checking for pests in people's office drawers? Amazing!
I can see a potential stretch if, for example, a site had a "no allergen on the premises" policy but i would not hv thought even this gave carte blanche to search indiscriminately.

I am curious as to whether within standard audit procedures, there is a defined separation line between what might be considered appropriate auditing practices as against simple "intrusion of privacy" ?.

Frankly, i believe that in some locations this operational concept would simply lose you a customer.
(added) - But maybe I'm in the minority.

Rgds / Charles.C

No, I didn't mean I look for pests, even though I have had cockroaches run for cover upon opening a locker or a drawer. Facility personnel are always present and as to privacy, what privacy issue is there in a company when the drawers in a cabinet or lockers are owned, controlled, and many times inspected on a routine basis by facility personnel..

Normally what I see are intro items such as food that would attract pests for instance and in some facilities there has been product that employees have taken and stowed in their lockers.

Dear GOC,

Thks for illustrative comments / opinions. I guess this may well be a location/case-by-case thing. Some of my opinions / searchings (no experience in USA) below. (didn't check SQF or IFS standards).

drawers in a cabinet ...... many times inspected on a routine basis by facility personnel.

I fear a good catalyst for a formal staff worker protest.

Normally what I see are intro items such as food that would attract pests for instance and in some facilities there has been product that employees have taken and stowed in their lockers.

Not quite sure if yr "lockers" above refers to all employees. I hv personally encountered both (+/-) official factory tolerances (for process worker lockers) during inspections. Some forum support (probably majority ) for yr viewpoint is in searching/threads below and i guess my own "bias" is evident also.

BRC Food apparently partially allows it, the balance ambiguous (no specific mention of lockers at all AFAI could see) -

All food brought into manufacturing premises by staff shall be
appropriately stored in a clean and hygienic state. No food shall be taken
into storage, processing or production areas.

(BRC5, 4.7.7)

Curiously perhaps, BRC Packaging3 apparently did not allow it (at least in 2007, current version no idea) -

Storage of food in locker (6.2.3) Version 3 does not allow it. The current practice does permit storage in sealed containers.

( http://www.ifsqn.com...dpost__p__18006 )

Some thread "debates" here -

http://www.ifsqn.com...dpost__p__38606

http://www.ifsqn.com...dpost__p__28531

Rgds / Charles.C