This article follows on from my previous article about training, which you can read here if you missed it:

Internal audit training article…

In this article I’m going to go through how here at Techni-K, we think the industry needs to change how it carries out internal audits, so that they are done effectively – we’ll be specifically looking at auditing HACCP first.

The problem…

As I said in the previous article, internal auditing of our HACCP systems are typically carried out by internal auditors who have been trained through a typical internal audit course. This type of course teaches how to carry out an internal audit, but it doesn’t teach the auditor about HACCP. Ask yourself:

  • How can someone audit a HACCP system that they don’t understand?
  • How are they meant to know what to look for and whether it’s correct or not?

To audit a HACCP effectively, an internal auditor would need to be trained (in my opinion) to level 4, so they can audit the system and also the validation of the CCP’s. Internal auditors are often not trained in food safety, to the level they need to be – which would also need to be level 4, so that they understand if all of the required food safety hazards have been assessed as they should.

The result…

HACCP systems go unchallenged, which means that when they are audited by external auditors, who understand HACCP and also, food safety in detail – they pick up non-conformances. When we audit HACCP systems here at Techni-K as part of our consultancy work with food manufacturing sites,  9 times out of 10 we always pick something up on the HACCP system.  Many times, we’re told: “Nobody has ever picked that up before.”

The reason why is because the internal auditing of the HACCP system hasn’t been effective and so, it leaves non-conformances for external auditors to find. Which nobody wants.

The solution…

Wouldn’t it be great, if you had an internal audit system which defended you from getting non-conformances from external auditors?  A system that made sure that your HACCP (and your full QMS) was effective? That’s what we think everyone is aiming for and what everyone wants.

We want to change how internal auditors are trained so that they can be equipped with the knowledge they need, to be able to audit their HACCP system really, really well.  This is so that, there are no non-conformances left behind for external auditors to find.

That’s why we’ve developed an internal auditing course which teaches your internal auditors how to audit to a best practice standard, but it also teaches them the standard in detail, so they know the content of what they need to audit. Our Best Practice Internal Auditing course, teaches how to audit internal audits, corrective and preventive actions, root cause analysis, senior management commitment (including culture), training and document control.

After this training, your internal auditors can take their training further if they want to go on to audit other parts of the standard, such as HACCP. We are building more courses that can be bolted onto our Best Practice Internal Auditing course so our next course is going to be Best Practice Food Safety & Hazard Analysis.  Once your internal auditors have done this training – they can audit your HACCP system too and when they do, your systems are going to be bulletproof!

After that we’ll be developing our range further by adding other modular courses which can be bolted onto the internal auditing one, which again will teach in detail, the other parts of the standard. That way, your internal auditors can audit those sections of the standard to best practice too.

Do you agree?

When you compare this way of training, to the way it’s currently done – I hope you can see, like we do – how much more beneficial it will be.

However, it’s going to take a lot of senior management commitment to implement it.  We know it’s much easier to send someone on a quick internal audit course to ‘tick the box’, rather than investing time and money in our internal auditors, to allow them to audit effectively. So, this is going to be a difficult thing to achieve.  Here at Techni-K we know we’ve got a lot of work to do, to make senior management realise that it’s worth the investment.

I’d really love to know what you think about this.  We are going to put our heart and soul into it – but I’d love to know if you think it’s possible!

It would be such an amazing place to be, if we could get companies to understand the value in training their internal auditors – because if we get that right, everything should fall into place.  We wouldn’t have to worry about up-coming audits, because we could feel confident that our internal audits have got it all covered already. To us, senior management are the key.  Changing their view is the hard part.

I’d love to know your opinion on this – please, please, please could you add your comments to the reply box below?

Have your say…

7 thoughts on “Why auditing HACCP at sites doesn’t work

  1. Agree that it is difficult for internal auditors to audit HACCP systems – our solution is to include our internal auditor (Development Manager) in our HACCP reviews / meetings to give them a much better understanding of our HACCP to aid them in auditing it.

  2. Good idea Deborah!

    I think one of the issues is with HACCP itself; too much focus on CCPs and insufficient focus on prerequisite programmes – this tends to be where HACCP falls down in my experience. Also too many CCPs is not uncommon (confusion of CPs with CCPs – which is also an issue for internal auditors).

    The US FSMA system is an improvement. HARPC – Hazard Analysis of Risk-based Preventive Controls; the focus is on the preventive measures – if you get those right then there are fewer CCPs to worry about. HARPC based system is much easier for internal auditors to deal with as they audit the Preventive Controls rather than a HACCP Plan.

    Using the Campden decision tree instead of Codex also helps as the focus is shifted to PRPs rather than CCPs.

  3. I find that sometimes the system of internal audits (with an enthusiastic team who are all trained in HACCP) picks up so many points for action that a business is overwhelmed with so much to d o all at once!

  4. I agree with senior management to be the key as with HACCP there is a view ‘once we invested in people and they know about the subject get them on the team not to waste a thing’, then leaving no one who keeps impartial to be able to audit, not to be on the HACCP team but still have sufficient knowledge of the subject to be able to constructively critique study…

  5. Hi Kassy
    I’ve read the blog, seen the video – is there a T-shirt?
    Seriously, though. You are spot on again. As a consultant (for want of a better word) I’ve been building BRC-compliant quality systems since the publication of the first “BRC Technical Standard and Protocol for Companies Supplying Retailer Branded Products”, back in the late 1990s. I’ve worked mostly with food companies who are too small to have a ‘technical’ team in place. They hire me to either set up their quality systems or to audit them, usually a mixture of both. I’m often appointed as HACCP Team Leader as well. So, the first problem is one of auditor ‘independence’. Who else on site has the knowledge of the Codex HACCP Principles, the BRC Standard and the technical know-how to audit Section 2?
    We’ve managed to get round this on some occasions using internal auditors trained through the typical internal audit course, as you put it, but in a managed way with me acting as Lead Auditor to steer them through the process. This approach seems to have satisfied some external auditors but you can’t rely on it!
    Whilst better training is probably the right way to go, the problems for small producers are twofold – the cost of training and the loss of the resource for the duration. Let’s face it, you’re not going to cover this is anything like the depth required in less than 3-5 days.

    1. Hi,
      T-shirts… hmm, that’s an idea! 🙂
      I’m glad you agree. Like you says it’s not going to be easy, but we do like a challenge!

  6. Surely the solution lies in ensuring that Internal Audit teams have the right mix of technical and auditing skills and knowledge? It’s probably also more cost effective to train staff with relevant technical knowledge to do internal audits rather than the other way round. That’s the approach that we have adopted successfully in my team.

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