6 Things Your Certification Auditor Needs to Hear You Say

When having a certification audit against a GFSI-benchmarked scheme, there are many things the auditor will ask and need to see and/or hear the client. The following are a few examples of what you can expect:

1. Senior Management Review

Your auditor will be looking for evidence that sufficient information has been provided for each agenda item to allow an informed discussion that leads to appropriate action plans. You can demonstrate this through a review of meeting input documentation, including discussion minutes and agreed action plans.

For example, to demonstrate that senior management has reviewed the management of the HACCP system, the minutes should contain a general summary of the HACCP review meeting and a record of the meeting outcomes, along with any actions requested during the senior management meeting. The senior management team needs to be able to speak easily about the food safety objectives that have been set and how they are tracking toward those objectives. The team will need to show that they are well-versed in this.

2. Food Safety Team 

It is good practice to document the team members within the HACCP plan, with a summary of their roles within the company. HACCP team membership needs to be reviewed and updated when necessary (e.g. when job responsibilities change or personnel leave or join the company). The HACCP team leader must be able to demonstrate competency and experience in the HACCP processes; this can be shown by:

  • the quality of the plan
  • documented evidence of qualification (e.g. successful completion of an industry-recognized HACCP training course)
  • demonstrable, extensive experience in implementing or training HACCP

The HACCP team members should know their HACCP plan inside and out, including the hazard analysis.

3. Internal Audit Program

The primary role of an internal audit program is to provide an ongoing assessment to ensure that the site is following written procedures and work methods defined in its quality system. The scope of internal audits needs to be established and must ensure that all aspects of the food safety and quality system, including the HACCP program, prerequisite programs, policies, documentation, hygiene, and production are audited.

Your site must have a schedule or program of internal audits to ensure that individual sections of the process, documentation, or production are scheduled for different, predefined audit dates throughout the year. An annual check against all the GFSI-benchmarked standard requirements may be of value as a gap analysis when preparing for an audit, but is insufficient to cover the full requirements of an internal audit program as it will not provide the depth of assessment or level of confidence required.

For example, the site should consider the consequences if the system, or compliance with it, is inadequate, and the potential for changes that would affect these control systems. Frequency may also be influenced by known issues within the company, best practice, or customer requirements. All activities within the site’s food safety management system must be covered at least annually.

4. Internal Audit Records and Corrective Actions

Audit results must be documented and clearly indicate what was audited. Reports must show evidence of conformity as well as non-conformity, and therefore tick lists showing that items have been assessed will not normally be acceptable as the only form of evidence. Information showing how the items audited have fulfilled the requirements, or how they are non-compliant, is required.

Notes, references, or copies must be kept as evidence of aspects that have been examined to allow an independent reviewer to reach the same conclusion as the internal auditor. For example, the date and title of records that were inspected should be noted in sufficient detail to allow them to be traced; if any records are non-compliant, precise detail of the non-compliance should be given. The listing of records reviewed can also ensure that a wide range of records are reviewed (e.g. training records of a variety of staff rather than repeated audits of the same records). Records will also confirm whether anything has changed since the last audit.

Full records of all internal audits and the results, including conformity and non-conformity and verification of corrective actions, must be kept for a defined period, typically two years.

5. Identification of Raw Materials and Finished Product

Identification may be achieved by physically labeling materials and products, by recording systems identifying the allocation of materials to production or mixing areas, or through the use of computerized barcoding systems. The level of traceability may need to be agreed upon between the company and its customers, but the system used must be capable of linking all raw material lot codes through to finished product codes. This will enable finished product to be identified should the recall of a particular batch of raw material need to be instigated.

The traceability system needs to include primary packaging (in direct contact with food), other relevant packaging materials (e.g., printed outer packaging), and processing aids (substances used within the process but not required to be declared as an ingredient, like sodium alginate for the clarification of beer).

6. Documented Training Program

The site must have a documented training program showing that job role competencies are identified, actions are undertaken to ensure that staff obtain these competencies, and a review of the effectiveness of these actions is undertaken. For example, a job training matrix could be used to list all of the site roles and details of which procedures and work instructions are required for each role.

Training must be delivered in an appropriate language for the trainee using either written or verbal translation where required.

Evidence of all training needs to be kept and must include:

  • the name of the trainee and confirmation of attendance
  • the date and duration of the training
  • the course title or contents
  • the name of the training provider

This information may all be included in the certificate of attendance provided at an external or internal course, or the course contents (e.g. personnel induction booklet) kept and cross-referenced with a record of training (with trainee name, date and name of trainer, and the name of any translator). Training records for any temporary staff, agency-supplied labor, or external consultants must also be available.

Plant personnel must be able to show that each employee has been trained on all of the various tasks/activities that he or she performs.

When having a certification audit against a GFSI-benchmarked scheme, there are many things the auditor will ask and need to see and/or hear the client. The following are a few examples of what you can expect:

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