10 replies to this topic

[Marshenko]

During our recent BRC recertification audit, we got the following NC.  Our auditor swore up-and-down that BRC had released a position statement which they had definitely seen (but couldn't find during our audit) which stated that internal system audits must be undertaken quarterly, so we need to audit quarterly.  I challenged them on it and showed them a listing of all the position statements that BRC has published, none of which include that requirement.  The NC reads:

 

Audits are and conducted throughout the year it appears quarterly, however, the second quarter of 2024 has no internal audits scheduled.

 

All of 2023s system audits were completed before I came to the company at the end-end of 2023.  I based our 2024 audit schedule on the fact that we have an unannounced audit window open from April-August in one location, and an announced audit in May at another.  So, my audit schedule goes from August to December, with audits scheduled every month based off of risk assessment and using an updated Master Auditing Document as a guide.

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I want to challenge this finding, but we have an unannounced audit still pending, and the auditor may very well be our auditor at the other facility, and it's unclear how they might handle being "challenged"...

Or... do I just include a very-snarky root cause analysis as part of my corrective action to satisfy my urge to be right? 

[SQFconsultant]

You may know that SQF has had a saying since inception an that is - SAY WHAT YOU DO, DO WHAT YOU SAY, PROVE IT!

 

Prove it - your Auditor failed to prove it, if there was an update he/could have simply called up the cb and asked for a scanned copy or fax.

 

All in all - I like the snarky route.

[Ishau]

The expectation is that internal audits are completed on a quarterly basis - i.e. 4 dates spread throughout the year.

Doing them each month from August to December is not acceptable and would result in a non-conformance. This is not spread throughout the year.

There is not a position statement which uses the word quarterly, because the expectation is within the Standard itself. The reason they don't use the word quarterly is because for some sites (e.g. seasonal) it isn't possible because of a shorter year, but the expectation will be to be to spread them out within their typical production year.

If you don't agree with a finding then you should challenge it, however I think in this case it is a fair find, perhaps explained badly, and you should ensure your internal audits are spread throughout the year (i.e. quarterly) going forward.

[Scampi]

The expectation is that internal audits are completed on a quarterly basis - i.e. 4 dates spread throughout the year.

 

That needs to be written in the standard or position statement----------you cannot audit "expectations"

[Marshenko]

Yeah, what Scampi said.

 

If the expectation is that they are done quarterly, the standard, or a subsequent position statement should say quarterly.  Quarterly is explicit and doesn't require interpretation. 

"4 dates spread throughout the year" is not quarterly.  Saying "4 dates spread throughout the year, with a frequency of at least quarterly" is quarterly and explicit.

 

The origin of multiple dates "spread throughout the year" was due to companies in the past doing their entire internal audit like a certification audit - all-at-once as a 1/2-day exercise.  Heck, I did that in 2013 with a new-ish SQF system.

 

The expectation is that internal audits are completed on a quarterly basis - i.e. 4 dates spread throughout the year.

Doing them each month from August to December is not acceptable and would result in a non-conformance. This is not spread throughout the year.

There is not a position statement which uses the word quarterly, because the expectation is within the Standard itself. The reason they don't use the word quarterly is because for some sites (e.g. seasonal) it isn't possible because of a shorter year, but the expectation will be to be to spread them out within their typical production year.

If you don't agree with a finding then you should challenge it, however I think in this case it is a fair find, perhaps explained badly, and you should ensure your internal audits are spread throughout the year (i.e. quarterly) going forward.

[ChristinaK]

If you have the internal audit schedule that states the minimum 4 different dates, proof that the internal audits occurred on a minimum of 4 different dates, and the scope is defined and covers your entire food safety & quality management system...you should definitely be in conformance with the BRC clause. Unless your internal audit policy says different about the schedule but I assume it doesn't based on your post.

 

If the auditor had trouble believing that you thoroughly audited your entire FSQM system--which it seems to me like that's the case for them--they should have asked about specific areas/sections/programs, the risk analysis or previous audit results you based the schedule on, or what your internal audit procedure is like instead of focusing on the 4 dates thing. It just seems like they thought they had a "gotcha" moment and weren't going to back down. Or maybe you were doing "too well" and they needed to ding you on something. ¯\_(ツ)_/¯

 

As for worrying about that same auditor going to your second facility and retaliating because you challenged them on this non-conformance for your first facility...just request the CB send a different auditor and state that as the reason. I think it's an entirely reasonable request to make. 

[KTD]

If challenging the n/c and winning will not change your grade, I would agree with SQFConsultant and just provide a snarky answer.

 

The interpretation guide does mention quarterly several times and states that 'most' locations would benefit from quarterly audits, but quarterly is not reflected in the Standard clause. As Marshenko & Scampi state/infer, auditing to an expectation is not acceptable.

 

Your risk analysis should state the frequency/timeframe you plan to follow (and that conditions outside the location's control which may affect the timeframe and what you'll do when that happens), and then reflect that in your program and internal auditing schedule.

 

I backload my minimum 4 internal audits to the back half of the year after my BRC audits because it may take some time for any drift away from 'audit prepared' (which never happens  ) to appear. I have not been challenged...yet.

 

KTD

[Tony-C]

Hi Marshenko,

 

I think you can challenge the NC especially given that BRCGS Global Standard Food Safety Interpretation Guideline for Clause 3.4.1 Internal audit programme states:

 

The majority of sites are likely to benefit from a programme of audit dates spread diversely throughout the year, as this maximises the opportunity to identify any non-conforming processes in a timely manner, allowing correction and minimising the potential for standards to fall between audits. The Standard promotes this concept by requiring a minimum of four audit dates spread throughout the year. However, it does not require all audits to be completed quarterly, as there may be genuine situations where risk assessment shows an alternative frequency. Seasonality is an example; if a site is open only for part of the year, then there is little value in completing internal audits while the site is shut.

 

BTW I’m sure that not auditing for the first 7 months of 202 will go down well as they are clearly not being ‘spread throughout the year’.

 

Kind regards,

 

Tony

[jfrey123]

I can't speak to the finding as I'm not BRC familiar, but everyone's presenting some sound logic to base a challenge to the NC.

 

I have been part to two challenges to an SQF auditor's finding.  The most recent was marked as a critical at one of our plants which we disagreed with and petitioned for it to be a major.  My boss man told the auditor he understood her position for marking critical, but we would be challenging, and we went out of our way to make sure she knew it was simply business and nothing personal.  We won the challenge, and despite her being scheduled for another of our plants the following month, that facility made it out with a 98.  We too were concerned she might retaliate in some way, but she was utterly professional in all dealings afterward.

[Marshenko]

Here's what I'm putting for root cause on my CAR:
 

The BRCGS Global Standard

FOOD SAFETY

ISSUE 9, Section 3.4.1 States: “There shall be a scheduled programme of internal audits.

At a minimum, the programme shall include at least four different audit dates spread

throughout the year.” but does not state quarterly as a minimum.  There were no position statements released by BRCGS related to a quarterly requirement.

 

The BRCGS Global Standard Food Safety Interpretation Guideline states: “The majority of sites are likely to benefit from a programme of audit dates spread diversely throughout the year, as this maximises the opportunity to identify any non-conforming processes in a timely manner, allowing correction and minimising the potential for standards to fall between audits. The Standard promotes this concept by requiring a minimum of four audit dates spread throughout the year. However, it does not require all audits to be completed quarterly, as there may be genuine situations where risk assessment shows an alternative frequency.”

Based upon this, 3^rd party and internal audit results from 2023, risk assessment in 2023 and 2024, and the new QA/QC Manager joining the company in December 2023, an audit schedule including five dates after an announced AND unannounced audits in 2024 seemed, erroneously perhaps, reasonable.   

Edited by Marshenko, 07 June 2024 - 05:54 PM.

[Ishau]

Now that it is 28 days post audit and whatever you did would have likely have been resolved, I just wondered how this ended up in the end?

Did the CB accept the rationale or did you end up doing something differently?