Private Certification Policy (Food Safety)
Annex 1 - Accredited Certification Framework
In recent years third party food safety audits have come under critical scrutiny from the mainstream media. Accredited certification does not deliver a guarantee of food safety nor prevent food safety incidents; it provides a proven framework of checks and balances that significantly improves the rigour of the audit process and reduces the risk of food safety failures.
Food businesses should not rely solely on third party audits to provide evidence of their food safety compliance. However, accredited third-party certification audits, if used correctly, are worthwhile tools for any food business seeking to implement and maintain behaviours and practices within their facilities.
Cutting through the Jargon
Accredited certification is not new and is not unique to the food industry. The accredited certification system offers credibility, rigour and consistency.
The Accredited Certification framework is a tried and tested process that applies credibility and robustness to third party food certification audits. It is a process by which Accreditation Bodies (ABs), who are themselves subject to peer review, test the competence of Certification Body (CB) involved in food safety certification, which in turn hire and provide oversight of auditors who audit and certify food businesses.
To begin with, a food business applies to a scheme for certification and then selects a CB to audit and certify the selected standard.
CBs, based on conformity assessments (or audits), provide written assurance that an audited food business has identified all potential food safety hazards, implemented effective controls, continues to validate and verify these controls, and has a management system in place that conforms to the requirements of the scheme's standard.
The CB must also have systems in place to ensure the capability of all management, technical, and administrative personnel, and in particular the competence of auditors involved in the certification process. Auditors must be competent in food safety management as applied to the industry sector(s) they are auditing, and the requirements of the specific scheme.
ABs, in turn, assess the CBs against one of two ISO standards: ISO/IEC Guide 65 or ISO/IEC 17021, supplemented by ISO/TS 22003. ISO Standards Accreditation is "a process by which an authoritative body gives formal recognition of the competence of a certification body to provide certification services against an international standard." Accreditation activities are conducted by ABs, which are not-for-profit organisations, either government owned or under agreement with government, charged with ensuring that participating CB in the country are subject to oversight by an authoritative body. The Standards Council of Canada is a Canadian AB that leads and facilitates the development and use of accreditation services. ABs may not be high profile in each country, but play a key role in the accredited certification process and ensuring international consistency in conformity assessment.
The International Accreditation Forum
Even ABs are not immune from further scrutiny. Sitting over the top of the accredited certification framework is the International Accreditation Forum (IAF). The IAF is the world association of conformity assessment ABs. Its primary function is to develop a single worldwide program of conformity assessment which reduces risk for business and its customers by assuring them that accredited certificates may be relied upon. The mechanism by which IAF implements its objective is the IAF Multilateral Recognition Arrangement (MLA).
To put it simply, the IAF helps to ensure that all ABs are following the rules of accreditation and applying the standards to affirm consistent delivery of the certification schemes. This is achieved by peer evaluation to ISO/IEC 17011: 2004–General Requirements for Accreditation Bodies Accrediting Conformity Assessment Bodies.
The Food Certification Process
The food business generally does not need to have any contact with IAF or the Accreditation Bodies, but does need to know that there is a robust accredited certification framework behind the scheme, that helps to protect the interests of the food business and the scheme owner.
For the most part, the only points of contact for the food business are the scheme owner and the CB. The points to consider are:
- Select the Right Scheme:
The first step in the certification process is selecting the scheme with a standard that best fits with the products and processes of the business, and helps meet customer requirements. This may be requested by a retailer, food service business, or manufacturing customer, or maybe to confirm the business's internal food safety protocols and controls.
- Select a CB:
Each of the scheme owners maintains a list of accredited CBs that are licensed to certify to their standard. The ABs also maintain a list of accredited CBs. When selecting a certification body, it is important for food businesses to consider a number of aspects including availability of qualified auditors, regional presence, seasonality, scheduling, audit duration, and overall costs.
- Apply for Certification:
The certification process is essentially the same, irrespective of the scheme or CB selected The process officially starts with completion of CBs application documents which allow the certification body to fully understand the scope of a facility's operations and the products to be covered by certification. It also becomes the basis of the contract between the CB and supplier, and is critical for calculating audit duration and proper assignment of an auditor with expertise in the appropriate food sector category(s).
The CB contacts the facility to schedule a mutually acceptable date for the certification audit. Most GFSI benchmarked schemes specify time limits within which certification and re-certification audits must occur to maintain certification. However, within these limits, the audit must be scheduled on a date that suits both the facility and the auditor, and within a peak production period.
- Certification Audits:
All food safety standards require an on-site third-party certification audit. Some schemes also require a document review prior to the certification audit. The role of the audit is to determine how well a facility identifies and implements food safety controls and complies with the requirements of the applicable standard. Certification audits are always non-consultative, which means that the auditor is not permitted to instruct or advise the facility on how to meet requirements of the schemes. The auditor reviews HACCP plans, procedures, policies, physical conditions, and records and observes the implementation of food safety plans within the facility Any non-conformances observed during the audit are documented in the audit report. At the conclusion of the audit, the facility is informed of all observed non-conformances.
- Closure of Non-Conformances:
To achieve certification the food business is required to take actions necessary to sufficiently correct any non-conformances noted during the audit, and to prevent their recurrence. Each certification schemes has unique time-line requirements for non-conformance closure. The CB reviews the evidence submitted and accepts the corrective actions if they are sufficient to resolve the noted non-conformance. If the submitted corrective actions do not sufficiently resolve the non-conformance, the CB rejects them, and the food business is required to re-submit within a specific timeframe.
In some cases or as prescribed by the scheme, the CB can undertake a further site visit to verify closure of non-conformances. A certificate can only be issued when non-conformances have been appropriately addressed.
- Certification Decision and Issuance:
The auditor does not make the decision on certification. An individual within the CB, independent of the original site audit, makes the final determination on certifications based on a review of the audit report and evidence of close-out of non-conformances. Only after a successful certification decision can a certificate be issued.
- Annual Recertification:
Each year a certified food business is required to undertake a recertification audit to maintain certification. The rules around the timing of this may vary based on a scheme's rules and procedures, but typically the recertification audit will take place very close to the anniversary date of their initial certification audit. Just as in initial certification audits, the facility must address non-conformances prior to being issued a certificate.
A third party audit is a process of obtaining objective evidence of conformance or non-conformance to a specified standard. The auditor obtains objective evidence by observation, interview, and review of documented procedures and records. However there are occasions where food businesses do not accept the outcomes of the audit, feel the auditor was not objective, was superficial, or did not adequately understand the process or technology.
Most CBs have a complaints and appeals process in place to deal with such occasions. Where a food business justifiably feels that the CB or its representative (i.e. the auditor) have not fulfilled their side of the agreement, the food business must first report it to the CB and work through their complaints and appeals process.
If it cannot be satisfactorily resolved at that level, it is then escalated to the scheme owner's complaints and appeals process. There are "checks and balances" procedures defined in the accreditation and certification framework Global Food Safety Initiative that addresses situations where there is misconduct on behalf of an auditor or CB.
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