Missing Audits and Validations

I recently (May 2017) started as the QA Manager of a small food manufacturer.  They told me that became SQF Level 2 in September 2016.  What I didn't realize was that their former QA Manager quit in October 2016.  So from September 2016 to May 2017 nothing has been done.  I've picked up doing the monthly audits and validations but what am I to do about the past?  How great of a risk are they at not having their certification renewed?

Any help would be greatly appreciated.

Patrick

Hi Patrick

Are you referring to the internal monthly inspections of the facility or the internal audits of the SQF programs?

I would also ask the same question as Patrick.  However you could write a corrective action based on the (lack) of information found.  This at least shows evidence that you have addressed the concern and the issues  as well as having put measures in place to assure completion going forward.  Even is this is you being in the position and addressing the SQF System as an effective Practitioner full time.  This is to say that you may still get a non-conformance for certain elements not being met routinely but this could make the difference between and major and minor NC with auditor.  In a previous manufacturer I worked for there we a great amount of things that did not match up due to a previous QA Manager and I made this transparent. I then put corrective actions in place and documented the process, some were noted on the audit report and some were observations. It all depends on the auditor but I always like transparency as this keeps it honest rather than trying to hide the issues.      

I would also ask the same question as Peaches.  However you could write a corrective action based on the (lack) of information found.  This at least shows evidence that you have addressed the concern and the issues  as well as having put measures in place to assure completion going forward.  Even is this is you being in the position and addressing the SQF System as an effective Practitioner full time.  This is to say that you may still get a non-conformance for certain elements not being met routinely but this could make the difference between and major and minor NC with auditor.  In a previous manufacturer I worked for there we a great amount of things that did not match up due to a previous QA Manager and I made this transparent. I then put corrective actions in place and documented the process, some were noted on the audit report and some were observations. It all depends on the auditor but I always like transparency as this keeps it honest rather than trying to hide the issues.    

Sorry Patrick meant Peaches.  

Hi Patrick

We had a 5 month gap in audits due to the previous QA person leaving.  We conducted an internal audit of the program, acknowledged the gap (i.e. missing audits) and then performed a root cause analysis on how to keep that from happening again.  What we came up with was that we needed more people trained and have meetings set with the responsible person(s) for the entire year.  Because we found the gap before the auditor and have corrective actions and can show we are doing those actions, our auditor just put a comment and did not deduct anything. 

Good afternoon, Patrick.

Been there. What we tried was to correct as much as we could in the remaining time before the audit, and as nwilson said, make use of the internal audit and corrective audits programs to cover every point of the standard that wasn't met. 

It's important to review the risks that are involved though, some of the missing information could be a potential risk for having a hole in legality, quality or food safety and that could be a potential mayor NC. 

Also, it's important to communicate with the directive if you need their support for more resources and to make them know the risk of not prioritizing Quality positions and having empty time-frames of a good QMS. Because, as you said if you're noticing this now, that means they're not really  giving attention to the dptm. 

Thank you everyone, I'll try and write a corrective action.  The company has been in business for well over 30 years, but as many of you know how small companies work, they worry most about the day to day operation.

Thank you everyone, I'll try and write a corrective action.  The company has been in business for well over 30 years, but as many of you know how small companies work, they worry most about the day to day operation.

Hi Patrick,

It may be different in USA but I encountered some similarly potent albeit different quandaries when i elsewhere started with BRC.

I suggest you might consider (assuming you know who yr Company are going to pay to do yr next audit) simply asking their opinion on the situation. After all, they are going to encounter yr "reaction" in a short time anyway.

I previously used this approach and (to my considerable surprise)  found that the auditor(s) were not quite so determined to merely "get you" as I had anticipated and were in fact quite willing to offer useful advice. In retrospect one should appreciate that you/yr Company are an Opportunity, ie represent a diverse (eg training courses etc) cash cow of potentially infinite duration.  It's worth remembering.

One of the corrective actions should be identifying back-up people in case someone is not available.  Per SQF Edition 7: 

"2.1.2.8 Job descriptions for those responsible for food safety and quality shall be documented and include provision to cover for the absence of key personnel."

Management should have had a person taking care of your SQF system during the interim.  This may indicate that your management may need additional training.

Your management would not stop doing accounting functions just because the comptroller quit.  They would find someone to take over the duties until a new one was hired.

Dear QA Patrick,

Recently I raised a major Non-conformity in a similar situation.

The new QA who was in charge for 5 months had been very busy with a lot of things.

He noticed that in the months before he was in charge, no internal audits had been done, but he himself had also not done the internal audits. He found it more important to adapt procedures. He did not make a plan, because he wanted to change all the procedures before starting auditing them. At the day of the audit  no internal audits had been conducted in the last 12 months and no action plan to correct this.

I could do no other thing that raise a major.

If he had only made an action plan and conduct the most important audits as correction before the audit ......

I think the way you are handling/ planning to handle are good. Try to catch up by temporary increase the frequency of auditing. Write that corrective action plan and make sure you have management commitment.

I am sure you will be fine by this.