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5 Additional Ways to Prepare for an Audit
by Scott E. Zimmerman, M.Sc, CP-FS
In the previous article “5 Ways to Prepare for an Audit," the benefits to taking a proactive stance, surveying orderliness, working as a team, instilling a positive attitude amongst coworkers, and involving senior management were discussed. Here are five additional techniques producers should consider to ready themselves before and during a certification audit.
1. Don’t cover up your mistakes. No operation is perfect, and it is statistically rare to encounter an operation that scores 100 percent on an audit. If you’re asked a question and you don’t know the answer, write down the compliance point and tell the auditor you will follow up with your staff. Try not to guess, or even worse, lie. In most cases, if you are unable to produce quantifiable evidence to support your claim, the auditor cannot verify compliance. Never ask an auditor what should be done to correct the non-conformance as it shows inexperience and it is a conflict of interest for an auditor to consult. Furthermore, it is the applicant’s duty to comply with 100 percent (depending on the standard) to attain certification. If you are concerned that your corrective action report is inappropriate, consider having the document reviewed by a third-party before submitting to the certification body.
2. Accommodating the auditor for success. Auditors like information, but they do not like to be bombarded with lots of the wrong information. Do not provide an auditor with more information than is necessary to comply with the standard criteria. Make them ask for specific documentation or to visit certain areas of your facility. Auditors can sometimes have a slightly different perspective regarding compliance with the standard, so be sure to have your own hard copy of the standard available during the desk audit. Make sure your auditor reads out the number of the compliance point so you and your staff can follow the audit and make personal notes referencing each section of the standard.
3. Review monitoring activities. Employees should know the significance of what an “•” or an “x” actually means. More importantly, they should know what is done to ensure that the proper corrective action is taken. Review your records and look for trends. All recordkeeping activities should have similar identifiers. For example, “ok” should not be written instead of “•” as it shows a lack of staff training and communication. An auditor can interview employees at any time during an audit. This especially goes for subcontracted parties. Auditors are trained to look for falsified records. If you identify this, have a meeting with all employees and document your progress.
4. Keep records up to date. If you have critical programs, such as Hazard Analysis and Critical Control Points (HACCP), make sure that new employees are collecting the correct documentation at each CCP, that records are verified at the required frequency, and that the dates and responsible parties are current. Your HACCP team should include current members of your staff, and the majority of the team should be present during the audit. Traceability and material balances need to be conducted at least two weeks prior to the certification audit. These exercises shouldn’t take longer than four hours, and in most cases, operators should be able to conduct these exercises in about one to two hours, depending on the variety of documentation requested.
5. Make a strong first impression. In order for audits to be cost effective, they have to move as quickly as possible. There are a lot of bases to cover, so forcing an auditor to wait for staff to arrive for opening/closing meetings is disrespectful to the auditor and sets the wrong tone for the rest of the audit. Make sure security is on board with all of the procedures that must take place before anyone enters the facility. Search your standard for terms like “subcontractor” and “visitor.” Most standards require visitors to sign in, sign waivers, and wear protective clothing.
Finally, processors can use many techniques to prepare for an audit, but the most important asset to a strong program is commitment from senior management. A competent auditor can sense the degree of senior management buy in long before requesting documentation.
Many of the points raised in this series may seem minor, but collectively, deviations can add up and potentially determine the difference between a passing and failing grade. Before scheduling an audit, the processor should schedule a meeting with essential staff and have a candid discussion regarding their ability to meet requirements. Those operators who consistently pass their audits often seem effortless in their ability to comply with the standard. Those producers have spent the time and received the support needed to seamlessly embrace a new operational culture.
Zimmerman is founder/CEO of Safe Quality Seafood Associates, LLC. His primary focus is GFSI benchmarked certification standards and regulatory requirements for wild and aquacultured seafood. Reach him at firstname.lastname@example.org