An essential part of a healthy food safety program is a robust auditing process, built into the organisation as culture. Every day and every audit presents an opportunity for education and evolution, to ensure a business can operate at its very best, which includes addressing non-conformances.
Despite their reputation, non-conformances offer great insights into how things have been operating, and how they could be improved to make things even better. There is rarely finger pointing and a good auditor will turn out to be the greatest support and ally to a facility.
In this blog, we will uncover:
- How to reframe non-conformances for the greater good
- Non-conformance for beginners
- Types of non-conformances
- The most common areas for non-conformances to occur
Review these supportive resources:
- Download our free guide to learn how to create a strong food safety culture.
- Read more on preparing for your food safety audit
- View our wide range of training courses to help learning, planning, implementation, assessment, and improvement of food safety management systems.
Reframing non-conformance for the greater good
The purpose of an audit is to find compliance, and identify opportunities where improvements can/need to be made, in line with the requirements stated by the standard or scheme.
The most common response of those who’ve received a non-conformance is dismay, or an abiding sense of failure, yet this reaction couldn’t be more misplaced.
At Intertek SAI Global, an auditor’s entire reason for being is to make every business better, safer, and more successful. The only way to do this is through reviews, feedback, and ongoing support and encouragement. This is achieved by focusing on supporting businesses through continual improvement of their operations with independent audits and obtaining objective evidence to validate that their processes, procedures, and records are aligned with standard requirements and best practices.
To ensure future audits are met with excitement rather than trepidation, it’s useful to be across the outcomes of the last audit, to be able to report on how previous non-conformances were handled, and even offer reflections on how they’ve benefited the business. Understanding the differences between minor, major, and critical non-conformances is also useful, empowering a facility to react and respond quickly with solutions, rather than catastrophise and create a situation of frustration and negativity.
At Intertek SAI Global, an auditor’s entire reason for being is to make every business better, safer, and more successful. The only way to do this is through reviews, feedback, and ongoing support and encouragement.
Non-conformance for beginners
An audit is a detailed review of how a facility has aligned itself to the relevant food safety standards (including policies, procedures, and practices). At all stages of a business’s life cycle, this alignment or interpretation will shift. While food safety standards exist to ensure everyone is striving towards best practice, not every business can successfully achieve every element of those standards first time round. In the event they have not, this is noted and listed in the audit report as a ‘non-conformance’.
The Intertek SAI Global auditor’s job is to not find fault, but to review operations with a professional, technical, and experienced eye, and help to identify opportunities for improvement, in line with best practice and regulatory requirements. Non-conformances are guide points in most cases, in the form of expert advice aligned with industry standards, that will drive the continuous improvement and evolution of a facility.
Types of non-conformances
There are three types of non-conformances – minor, major, and critical. Each comes with their own parameters, and each has their own time frame for resolution and outcomes if resolution is not achieved.
- Minor – is evidence of a random or infrequent failure to maintain compliance with a requirement but does not indicate a breakdown in the food safety management system or that food safety is compromised. It is evidence of an incomplete or inappropriate implementation of the standard requirements, which could lead to system element breakdown if not corrected.
If identified, a formal NCR (non-conformance report) will be issued, requiring a facility to respond and submit what the proposed corrective action plans will be and how these will be/have been implemented. Assuming Intertek SAI Global approves those corrections, certification will not be impacted, and those corrections will be formally verified at the next audit – providing a great opportunity for the facility to showcase how they have improved their business.
- Major – is a failure of a system element, a systemic breakdown in the food safety management system, a serious deviation from the requirements, and/or absence of evidence demonstrating compliance to an applicable system element of Good Manufacturing Practices (GMP). It is evidence of a food safety risk to products included in the scope of certification.
A major NCR would be issued where there’s objective evidence the facility has failed to implement the requirements of the relevant standard. The issue in question would be significant enough that doubts would be raised around the capability of the food safety management system to achieve the required goals. In the instance of a major non-conformity, Intertek SAI Global would issue a formal NCR and require that the proposed corrective action plans have been implemented and evidence of that supplied, usually within 90 days of the NCR being issued. If a major NCR is not addressed, certification may be impacted.
- Critical – is a breakdown of control(s) at a critical control point, a prerequisite program, or other process steps and judged likely to cause a significant public health risk and/or product contamination. In other words, a critical NCR usually means there is the potential for a food safety issue, or there is a concern immediately in place. It may also be in reference to a legal issue. In the case of a critical NCR, operations will usually be paused until a resolution has been implemented. If not resolved, certification will be suspended.
In the event of a non-conformance being issued, your first response should be to reach out to your auditor. This gives you the opportunity to ask questions and get advice from them on next steps. Their support will ensure you resolve issues efficiently and effectively, minimising the impact on your operations.
The most common areas for non-conformances
Our auditors are some of the most experienced professionals in the industry. Many have had tenures of more than a decade, so they know best practice inside out and can advise on how to resolve issues and improve operations quickly and effectively, to ensure a facility constantly evolves as it grows and changes.
Through their experience, we have been able to identify the areas where non-conformances appear time and time again. By understanding what those areas are, a facility can be sure to pay extra attention and minimise the possibility of an NCR being issued at their next audit.
1. Cleaning, hygiene, and sanitisation programs
The foundations of food safety of course lie in effective and thorough cleaning and sanitisation of all aspects of the facility and its operations. Additionally, maintenance and structural integrity is also crucial. This includes the integrity of the building, the floor and walls and their junctions, doors, and the ceiling. This kind of integrity facilitates cleaning and sanitation, prevents foreign objects from entering and contaminating products, and prevents pests from entering the facility. A business should understand the risk factors specific to their operations and whether they have adequate or appropriate equipment and resources for their requirements.
2. Business continuity planning
Food Safety Management Systems must be continuously monitored, measured, evaluated, and improved. The strength of a brand’s FSMS, practice and culture will only take it so far, however. Proactively integrating robust action plans around risk and potential crises is of fundamental importance.
3. Food safety culture
For food safety to be truly embedded into an organisation, a mindset that thinks beyond compliance is required. A shared food safety culture is developed through a subtle but meaningful shift away from the gold standard practices of clipboards and ticking boxes. It becomes evident when all the logistics are in place and food safety exists as everyday behaviour.
4. Internal audit programs
Consistent internal audit programs implemented and reviewed by prepared, trained, and skilled internal auditors are the key to a fully compliant operation. They also ensures a dynamic approach is taken, with internal teams knowing the intricacies of the facility and therefore able to customise each audit to the current state of operations.
5. Supply chain management
Effective supply chain management depends on a solid understanding of the present-day risks and challenges as well as those on the horizon and ever evolving. This then ensures the business is adequately prepared to improve supply chain risk management practices before and as they arise.
Why Intertek SAI Global?
We’re here to help you build a world-class, globally competitive, and sustainable Australian foodservice industry today.
With over 25 years of experience and a global reputation built on first-class delivery and technical support. SAI Global Intertek has partnered with the foodservice Industry for decades, engaging with hundreds of foodservice suppliers and contractors throughout their assessment and certification process – while making the process as seamless and simple as possible.
Adding value is at the core of our business and our processes. Let us show you how assessment and certification can add value to your business. Australia-wide, delivering over 60,000 audits each year, your local Intertek SAI Global team is equipped to support your unique requirements.