01 – The audit philosophy
The core of the audit system is based on the following GFSI Standards:
- BRCGS Food Safety
- BRCGS Packaging
- BRCGS Storage & Distribution
- BRCGS Agents & Brokers
We’ve taken these Standards and combined them, into one huge standard. Which we’ve called The Combined Standard.
There are a number of reasons for this:
To be ahead of the game
Every year at least one Standard is updated and this means we’re forever in an endless cycle of updating the documentation we audit to.
Because at Techni-K we audit all the Standards, this means updating each set of audit templates individually. And then repeating this process the following year for the next set of audit templates with the same things, as the updates are the same – or similar.
But updating all of the audit templates when any one Standards is updated, means we’re ahead of the game.
And, we find that typically the changes to the Food Safety standards drive the updates in the other standards anyway – so it’s a really safe bet that they’ll get updated too. This means, we can pass on these changes to you, giving you more time to prepare and implement the changes – ready for your audit.
To keep it simple
Sometimes one Standard will get updated and the update will be forgotten in another (whistleblowing in the BRCGS Packaging Standard is a great example of this). Or when the Standard is updated, sometimes there are aspects that don’t make sense, or there are mistakes in it. By us assessing the changes and implementing just what’s needed, it means that you don’t have to work through this confusion, as we’ve done it for you.
So it makes sense
When you compare the Standards – there are things in one Standard, that really should be in them all, but they’re not. Artwork control is a great example; BRCGS Packaging has this, but it’s not mentioned in food – where it would be of great use. Control of glass containers (like jars) is another good example, which is included in the BRCGS Food, but not in packaging. This means, in theory, you don’t have to control glass container breakages, if you’re making glass jars. But you do – if you’re filling into them.
By combining the Standards, we’re taking the learnings from one and applying good practice to the others where it’s relevant. This also means, that were an external auditor, audits more than one standard – they can apply the principles of one standard to another.
Even though the clause may not explicitly state that you need to do what the auditor is asking for, the standard is broad enough to allow the auditor to do this – meaning you could be at risk of getting a non-conformance. Using the learnings from all the standards, reduces the risk of this happening.
To translate and standardise
We like to think we can write things, in a simple to understand way. So, by taking all the Standards and combining them, we can then translate them into a Combined Standard which makes sense and is easy to understand. It also allows us to use a consistent language (the Standards don’t tend to be consistent and they’re definitely not consistent across the different standards). This then means we can provide a glossary for the terms we use.
Because all standards are laid out slightly differently (even standards by the same accreditation body) to allow us to combine the standards, we had to come up with a way of categorising the topics, so that it can be aligned.
The result of this is the following 18 topics, which are:
- Senior management commitment
- Document management
- Continuous improvement
- Contingency planning
- Hazard analysis
- Contamination control
- Product development
- Supplier management
- Product defence
- Site Standards
- Risk-based facilities
- Process control
- Intake, storage & distribution
Each clause, from each Standard, has then be assigned to each topic. And, the Standards have all been aligned. Which creates one huge table of information…. This table provides a matrix of how the sections of each of the Standards are aligned.
Unfortunately, the way the Standards are written isn’t always logical. Sometimes one clause can talk about different subjects. And some sections can refer to a range of subjects. BRCGS also include requirements in the interpretation of their clauses, which also complicates things. This means that sometimes we’ve had to split a clause, or the interpretation of a clause across different subjects. So, you may find that the same clause is referenced in more than one of the 18 topics. For this reason, the information provided in this table should only be used as a guide.
When all the clauses and the interpretation of the clauses are aligned we take all that information and put it together, remove the repetition and then translate it into something that’s easy to understand. The result of this, is one combined clause – which complies with all of the core standards and is understandable. We then take that combined clause and translate it into audit questions and instructions for the auditor for the system audits.
Next, we produce cross-cutting theme questions. These are questions which check compliance to document control and also training – because these subjects are so fundamental to everything we do. Which means, they need to be checked when you audit each topic. This means, you’ll end up with 18 system audits.
And then finally, we create GMP inspection questions – where something practical needs to be checked. If you’ve chosen an audIT.app bundle which has GMP inspections included, then we’ll show you how these are built in more detail later. When the questions are put into the system, we filter the relevant standard – so for the BRCGS Food Safety core standard, we filter all those clauses and enter them. This means, when you audit a question, you can see which clause it came from.
Things to note!
One of the benefits of putting the clauses together, is that some standards have key things in them, that are missing from others. This means that the combined clause is more comprehensive. But what it also means, is that sometimes the clauses that are listed don’t contain all the information referred to in the combined clause.
If you find a question refers to something that isn’t mentioned in the clause in your standard, this will be why. Something else you’ll notice is that sometimes there isn’t a clause referenced in the audit question. But instead – it states ‘Techni-K’
The reason for this is that the core Standard doesn’t explicitly state in any of its clauses that this is a requirement.
However, we would recommend that you comply with the requirement as it’s either implied, or it’s needed in order to comply with something else.
We’ve only talked so far about the core GFSI standards. However, if you work with the retailers or other customers you may have customers standards or codes of practice that you need to work to.
But don’t worry – we’ve got that covered too. You can choose the additional standards you want to audit to, on top of your core standard.
Over time, we’ll be adding additional standards that you can use. When we add an additional standard, we’ll add it to the combined standard. Then, if you want to audit to one or more additional standards we’ll just add these specific requirements into your existing audits for you.
And you’ll be able to tell which questions include your customer requirements as they’ll be referenced back to the individual specific standards.
Each time a standard is updated or a position statement is published, we will update the combined standard and then update the questions where needed.
This means, that you only have to worry about updating your management system, as we’ll sort the audit system for you.
We’ll also let the system manager know, when updates are implemented, so you’re aware of them.
OK now you know how the system is built and maintained, let’s move on to setting up your users for the system audits.