As many of you have heard, a much-anticipated announcement from GFSI was published on June 11th, 2020, approving the amended benchmarking requirements that will allow for the use of Information Communication Technology (ICT) as part of the GFSI benchmarked certification audits. The decision by the GFSI Board was made after careful consideration and feedback from the various stakeholders involved in the process. One of the key reasons for the seemingly slow approval was that the Board wanted to ensure that the requirements were sustainable and could be used after the current pandemic had passed. In the past week, each of the main Certification Program Owners (CPOs) have released their information about how the remote activities can be incorporated into their certification audit programs. This information will now allow the Certification Bodies, like Mérieux NutriSciences Certification, to implement the required procedures and begin to use remote activities as part of the GFSI benchmarked certification process.
Key Takeaways from the Benchmarking Document
There are several key components that have been identified within the GFSI Benchmarking Requirements that will help to drive consistency and alignment among the different stakeholders. Some of these components include:
- The use of remote activities is not mandatory and must be mutually agreed upon between the audited organization and the certification body. Part of the decision to use remote activities must also include an assessment to ensure that the auditor and site have access and the capability to effectively use ICT.
- The full audit objectives must be met and all parts of the audit process completed effectively and as a combined process.
- Each CPO must define what parts of the audit may be carried out remotely, but the onsite portion must include, at a minimum, the inspection/physical verification of the GMPs and verification that the food safety management system addresses all parts of the operations.
- The full audit (i.e. both the remote and onsite activities) must be completed within a 30 day window. In extreme situations where this requirement cannot be met, the CPO is allowed to have a program that would allow the timeframe to be extended to 90 days. Each CPO may implement different criteria, but in all cases a risk assessment must be completed to ensure efficiency and integrity of the audit will not be affected and additional audit time may be required.
How would a typical certification audit with remote activities look?
To start the process, MNCert would work with the audit site to determine if the site had the capabilities to do some activities remotely and what parts of the audit could be conducted remotely. An audit plan will be established that identifies the ICT technology that will be used (i.e. WebEx, Google Hangouts, etc), parts of the audit that will be conducted remotely, the dates for the audit (both remote activities and onsite audit), and the expected outcomes. In most cases, the remote activities will include the review of the food safety policies and procedures, the review of some records, and interviews with higher level management staff. Any non-conformances identified during the remote activities would be shared at that time, and also included within the final audit report.
The onsite audit would be conducted within 30 days and include the physical inspections and verification that the pre-requisite programs have been implemented/effective, verification that the food safety plan covers all parts of the process, interviews with production staff in their work areas, review of records in the work area, and follow up on any programs or procedures that were not fully reviewed during the remote activities. A single, full audit report will be generated that identifies all non-conformances. After that, the corrective action process would be followed along with the technical reviews and subsequent certification decisions.
How does the future look?
The GFSI Board was purposeful in assessing the use of remote activities to ensure they would not result is a less effective audit and to ensure that this could be something usable in all parts of the world moving forward. The use of remote activities is not only applicable during the pandemic, but could be used more frequently for audits in the future. This also has the potential to provide cost savings by minimizing the travel costs and can improve the quality of life for auditors by reducing the number of days that they must be traveling. If you are interested to learn more about the use of remote activities, please contact your Mérieux NutriSciences Certification representative.
Originally published on 14th July, 2020 at http://foodsafety.merieuxnutrisciences.com/
The blog was written and contributed by:
Director of Auditing Operations