I feel for your situation. We were very fortunate with the consultant we used years ago to help us with SQF. He spent time at our plant, learned our process and helped me understand the code better. He was a huge help. However one of our sister plants switched from BRC to SQF a few years ago and their consultant came in for a couple of days and then made recommendations that did not fit and did not catch that support for some of the items was not in place. Needless to say, they did not do well on the audit after the consultation, just like your situation. It was a shame. - It sounds like you have taken great strides in getting things back in alignment so hopefully next year will not be so dramatic for you. - I don't know if it will help you with your argument but below is what we do to meet the requirements and we have not had any non-compliances on our audits for these sections.
2.5.5.3 - We have monthly GMP Audits where we break our GMP's out into sections and complete an audit on one of the sections each month. We also have Facility Audits monthly where we audit the exterior and non-production areas one month, raw end one month and the RTE end once a month verifying the facility, equipment and pest control preventions are all in good condition and helps us address items that need some attention. If one of your PM's requires these types of checks then that is what you want to show the auditor but that will not help with the GMP's as I doubt there is a PM for Maintenance for them to verify GMP's are being followed. Do you have something in place for verifying GMP's?
2.5.1.1 - i. and iv. For the Validation section of the code we lined out how we would validate each section of the code. Most often we used lack of Customer Complaints or Deviations and for some Microbiological Sampling Results to show we did not have trends of issues for that section. Although some sections are specialized such as calibration that we reviewed the calibration records to show there was not a trend of equipment being out of calibration.
ii. HACCP Validation should be covered under your HACCP / Food Safety Plan. For the annual validation we do an annual review and state that no changes have been made to the plan that would affect the CCP limits or process so the original validations are still effective and the auditors we have had seem to be good with that. We also reassess our SSOP's annually.
iii. Anytime there is a change to the process or procedures you document them and determine if controls are still effective or if any changes are needed. For example we put in new metal detectors so we had to reassess our test standards to ensure they were still applicable for the new equipment and we were actually able to move to a smaller standard test size, which was great.