Providing further tips on audit preparation, a quality assurance manager who successfully achieved SQF certification offered several pieces of advice:
“First, the QAM must take the necessary time to thoroughly understand every requirement in the standard and effectively apply the requirements to their unique operation. If you’re undergoing a first-time GFSI audit, don’t rush the implementation. Take the necessary time to get thoroughly prepared. You must understand the standard as a whole, and the clause by clause application to your operation.”
Second, understand that the audit expectation GAP and pre-assessment audits are based on the clause requirements in the standard. An auditor can do either. If a site elects to make sure that they are as thoroughly prepared as they can be, having a consultant do a GAP first is the way to go. A GAP audit is intended to uncover problem areas. If a consultant does the GAP, he or she can make recommendations on how to fix the problems. An auditor doing a pre-assessment can only report what is wrong, not make recommendations.
Third, if your facility is undergoing renewal, make sure that your documentation is accurate and up to date.”
Successful certification clients demonstrate the following:
- Senior management fully committed to implementing requirements of the standard;
- A well-documented food safety plan and HACCP;
- Well-documented sanitation and GMP procedures;
- An internal audit system that identifies non-conformances and provides corrective procedures and preventive action for resolution of non-conformances;
- Clear and well-documented procedures for monitoring the performance of suppliers;
- Traceability through documentation of every ingredient, final product, and service;
- Well-documented evidence of layout, process flow, and segregation;
- An incident management system;
- Well-documented handling requirements for specific materials, i.e., materials containing allergens and identity-preserved materials; and
- Well-documented training procedures, with records, for employees.
The BRC recently released a list of common non-conformances cited during U.S. audits: improper equipment maintenance; lack of a chemical control procedure for non-food chemicals; lack of sealed exterior doors to prevent pest ingress; lack of proper handling of glass and similar materials; ceilings and walls that do not meet requirements; correct version of controlled document that is not properly controlled; failure to control and manage potential risk from chemical, physical, or taint contamination; lack of a process flow diagram—Codex Alimentarius Step 4; lack of suitable and sufficient hand washing facilities.
Requirements, Accountability, and Reporting
A key feature of the GFSI approach is that an effective and comprehensive system of requirements, accountability, and reporting has been implemented. All participants, including standard owners, certifying bodies, auditors, consultants, trainers, and accreditation bodies such as the American National Standards Institute, operate under GFSI guidelines. Not only must food manufacturers meet GFSI requirements, but the certification body (CB) must also meet guidelines set by GFSI.
Recently added to GFSI benchmarking is the monitoring of the CB’s ability to operate according to GFSI requirements. The BRC evaluates all licensed CBs through key performance indicators. A star rating from one to five is granted according to overall performance in these five key areas:
- Compliance to protocols (how audits are undertaken and reported);
- Auditor registration and compliance relating to training, experience, and competence requirements;
- Quality of written audit reports based on a sample of audit reports;
- Speed of audit data upload to the BRC directory by the CBs; and
- CB communication with the BRC.
Companies entering the BRC certification process can find a complete directory of licensed certification bodies with their KPI rating noted on the BRC’s website, www.brcdirectory.com. The BRC promotes competency, professionalism, and consistency among its CBs with this rating scheme. The SQF Institute also provides a listing of licensed and accredited CBs on its website, www.sqfi.com. CBs listed here meet all SQF license requirements, including the requirement to employ SQF-registered auditors and/or contract auditors to conduct the audits.
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