Report & Finalise Audit Outcomes - Content Guide

Report and finalise audit outcomes – content guide

Table of contents

Overview of closing meeting

Preparing for the closing meeting

Delivering findings

Delivering CARs at the closing meeting

Agreement and proposed time frames for closing out CARs

The final report

Further references

Feedback to review questions

Overview of closing meeting

Now that the physical aspects of the food safety audit are complete it’s time to finalise and report on the outcomes of the audit in the closing meeting with the business’s management team.

Preparing for the closing meeting

As the food safety auditor you should have thoroughly reviewed your notes, checklist and observations and drawn rational conclusions as to the overall compliance of the business with respect to the food safety criteria in your audit standard. You should be well prepared to deliver any CARs that are required. You are now ready to conduct the closing meeting and exit the audit.

The closing meeting should be held on the audit day or, in special circumstances only, soon after the on-site audit. At this meeting, the auditor details the results of the audit, delivers the CARs and allows the business to discuss the findings and provide further information as appropriate.

The site audit checklist is reviewed in detail with the representative of the company (the auditee).At Luscious Bites this will be the food safety supervisor.

Recommendations for improvements, although useful, are not generally required during an audit. Care must be taken if the auditor provides advice or recommendations for improvements, as the auditor may be liable if the advice is subsequently found to be questionable.

Ideally, the auditee will agree that the information contained in the auditor’s site audit checklist portrays the audit accurately. The auditor and auditee then both sign this and the site audit can be concluded. The auditor again outlines the final reporting timeframe.

A sample of a closing meeting and audit findings report for a bakery is shown in the Resources for this section.

Communicating and negotiating on audit issues

A successful audit is not necessarily one where no non-conformances were found. One of the most successful outcomes is an audit that results in a food business becoming aware of gaps or shortcomings in its approach to food safety as a basis for identifying ways of improving the way things are done. Achieving this outcome requires auditors to clearly and effectively communicate information. It will also require that auditors are able to effectively facilitate the auditee to review their approach. Effective negotiation is a useful skill for auditors.

Some useful tips when negotiating differences between participants or between you and participants are:

• Clarify the issues and seek to establish the interests or perspective of the participants.
• Identify whether participants have sufficient information to resolve the issue. If not, identify the additional information required and agree on how to obtain it.
• Remain objective rather than personalising issues or comments. For example, ‘You haven’t sent through the food safety documents yet’, not ‘You never give me anything on time’.
• Don’t get defensive. It is easy when under attack to take it personally. Remember that people are liable to get flustered or nervous when they are being audited. Make an effort not to take criticisms or attacks personally.

The process of negotiating issues is as important as the outcomes. It is often impossible to resolve issues in ways that meet the demands of all participants but if people see that the process of discussing and working towards resolution is open and fair, they are more likely to accept the findings.

Delivering findings

CARs may be delivered verbally or in writing at the closing, depending on the requirements of the audit standard or any agreements around permitted preferences with the auditee. In all cases, CARs are later formalised in the final written audit report. The auditor’s primary role is to be impartial in collecting evidence and then to mitigate the risk by raising CARs when non-conformances are observed. At the closing meeting it is vital to gain agreement to fix non-conformances within negotiated timeframes. The final report is usually completed when the auditor returns to the office with the formal report being forwarded to the auditee as soon as possible.

After analysing and recording audit findings, the auditor carries out a debriefing or closing session, with the management team. This closing meeting has several purposes:

• to communicate to the auditee how the audit went in general
• to indicate significant non-conformances that require urgent attention
• to foreshadow the findings of the written report; and
• to highlight the strengths and weaknesses of the organisation.

Delivering CARs at the closing meeting

A verbal report of how the audit went and the flagging of any serious non-conformances are done at the closing meeting. Typically the formal written report is not usually completed until some time after the audit. It is a good idea to start the closing meeting by highlighting what the company does well before talking about any system failures or weaknesses that may have been observed during the audit.

The closing meeting gives management representatives an opportunity to produce contrary evidence or additional information that may affect the audit findings, so there is likely to be lively discussion. The closing meeting provides the opportunity to get the auditee to agree that the information contained in the auditor’s site audit checklist portrays the audit accurately.

The purpose of the closing meeting is to discuss non-conformances with the business and to get the management team’s agreement on areas of the business that require corrective action.

It is important to note that it is not the role of the auditor to provide solutions to any noted issues that will be included in the final audit report, nor to provide official recommendations on how non-conformances should be managed. An auditor may however, provide input into discussions with management around possible solutions to observed problems. It is the responsibility of the business to decide upon the appropriate course of corrective action to audit findings. As an auditor, you may be open to legal liability if you recommend or direct the business to choose a specific option with respect to corrective action and it is later found that this advice is questionable.

The closing meeting provides a forum for all non-conformances observed during the audit to be discussed so that the management team fullyunderstands the issues that relate to the proposed CARs the auditor wishes to raise.

Discussion topics in a closing meeting include:

• discussions around the root cause, source, or trigger of identified issues
• system or process failures and their ramifications with respect to food safety risks or regulatory breaches
• dates and time issues that first appeared through retrospective audits of paperwork, records and test results, as well as problems observed on the day
• the types of products or processes that are affected by the system failure(s)
• review of the HACCP system/written program including records and reports
• identification of any training requirements of staff.

Delivering CARs at the time of the closing meeting, either verbally or in written form is up to the auditor and the type of certification system the auditor is there to check upon. Usually, CARs that the auditor wishes to raise will already have been discussed withthe company’s QA manager who usually accompanies the auditor on the day. Non-compliance issues and the reasons for converting them to a CAR are discussed so that this company representative is briefed prior to commencement of the closing meeting. Ideally, in this way, the auditor has a company representative on side when delivering the audit findings.

CARs are agreed upon in the closing meeting and formalised later in the written report that usually follows in the next few days. Deciding on the timelines for completing corrective actions (short term and/or long term) is discussed and negotiated with the management team at the closing meeting and largely depends upon the nature and severity of the non-conformance. For example, where large capital expenditure is required, or business changes are already in the pipeline the auditor will consider these when proposing a completion date in the CAR(s) that will be raised. Often an audit standard requires the auditor to obtain written sign off on CARs at the closing meeting. In these cases, the CARs are raised in writing, signed by a representative of management and included as attachments in the final report.

The closing meeting discussions should result in both the auditor and the management team walking away with essential, clear information about the corrective actions required and the timelines for the implementation of the corrective action.

These include:

• the nature of the non-conformance
• proposed date for completing the corrective action
• the name of person responsible for ensuring the completion of corrective action
• a description of the corrective action, including evaluation procedures to verify effectiveness of corrective action
• if necessary, a follow up audit date to confirm corrective actions have been effective in preventing a recurrence of the noted non-conformance.

Review question 1

At the closing meeting what is the first subject the auditor should talk about prior to issuing CARs?

Agreement and proposed time frames for closing out CARs

The auditor and the management team need to agree to timeframes that are realistic for any corrective actions that need to be implemented in order to verify the food safety plan’s compliance to the audit standard(s) being checked. It is crucial for the auditor to clearly articulate that ownership of the Corrective action request (CAR) is management’s responsibility. A competent auditor often needs to draw on their negotiation skills to achieve this outcome in the closing meeting. The auditor needs to articulate why a particular system failure or non-conformance is a food safety risk and how this in turn translates to a direct risk to the business. A good understanding of how food poisoning outbreaks occur and how they affect a company’s reputation (and expose the company to legal liability) all help the auditor to frame food safety issues in the appropriate context.

Failure to comply within the agreed time frame may have negative consequences for the business. These can include, but are not limited to:

• the business being put on notice with respect to its registration
• withdrawal of the businesses certification with respect to food safety certification
• failure to renew a businesses certification
• loss of customers who require the business, as a supplier, to be food safety certified
• withdrawal of the businesses export license.

During the closing meeting, be prepared to listen to management’s feedback once problems have been outlined. In some cases, management may be able to provide extra information or explanations with respect to audit trails meaning the grading of certain CARs can be altered.

Understand that agreed corrective actions must be achievable.

The auditor and the management team need to seek a reasonable balance between the risk level an audit finding poses to the business and the financial implications for the company.

Approach to closing out CARs

Normally, audits are booked into a schedule. This may be annual or biannual,depending upon the type of standard being audited against, and/orthe risk classification for the business and its products.

Closing out minor, major and critical CARs

Providing the business is performing well against a given standard (ie only minor non-conformances or zero non-conformances are observed) the business will generally rectify these issues in the timeframe between these scheduled audits.

Minor food safety program non-conformances

Examples of minor issues that fall into this category are:

• records indicate that training of new staff has not yet been carried out or training records are not up to date
• some staff are observed not to be following correct hygiene procedures, with or hair nets/gloves not being worn in appropriate areas
• the air curtain is not working on the receipt dock, or the doors are left open allowing the entry of pests.

Exceptions to revisiting premises

An auditor may request a company to send through documented evidence in order to confirm that appropriate corrective action has taken place, thereby negating the need (in some cases) for a follow up visit. This request may also be relevant where missing information is known to exist but cannot be found on the day of the audit.

Critical and major food safety program non-conformances

In a case where a critical or major non-conformance has been raised against the food safety plan, the criteria of the audit standard will usually dictate the time frame in which the auditor has an obligation to follow up on the audit finding. Typically, for serious system failures, this is usually within 10–14 days, during which time the company is required to put systems in place, modify or replace certain equipment. The company will usually be required to alter procedures to such an extent that the immediate food safety risk is mitigated.

In most cases, however, where a critical or major non-conformance has been observed, the auditor will need to revisit the site to determine whether the required corrective action taken by the company has been implemented and is effective.

Examples of major non-conformances that could require a non-scheduled follow-up audit are:

• a complete breakdown of the cleaning and sanitation schedule, resulting in many instances of filth and debris posing a substantial threat to food safety
• critical limits in the HACCP plan are not being monitored, with direct evidence during the audit that critical limits are out of control
• items of equipment and machinery that are designed to mitigate a food safety hazard (eg continuous cooker, pasteuriser, metal detector, etc) are not working efficiently and pose a direct risk to product safety.

The food safety auditor may deem it acceptable for a company to send through evidence of compliance. If the audit is being undertaken on behalf of a regulatory agency as part of legislated audit requirements (ie a third party audit), the food safety auditor typically needs to report outcomes to the enforcement agency within 21 days of audit completion. In some cases, depending on the nature of the findings, the relevant enforcement agency may require the business to put in additional corrective actions, or may visit the site as a part of their statutory right or obligation.

Continuing non-compliance

The following are some examples of circumstances where an extension on the agreed timeframe for completion of a corrective action request could be granted:

• food safety is not compromised
• the ‘date for completion for corrective action’ is not met for reasons out of the company's control and this can be backed up with records (eg a letter from parts suppliers that a part is on back order), and
• the new ‘date for completion of corrective action’ must be agreed to by the auditor and this date is entered and initialed on the CAR form.

Often when a company addresses audit findings relating to non-conformance issues, the company’s food safety plan documentation, additional training requirements and reporting functions will subsequently need to be addressed or updated.

On conducting a follow up audit the auditor may decide that since the immediate risk to product safety has been addressed these administrative issues can be confirmed as part of the next audit. Commitment is again sought from the company with respect to this follow up work and the original CAR may be downgraded from critical to minor. In other words, it is now flagged in the system for follow up at the next scheduled routine compliance audit.

Closing out of CARs

The food safety auditor closes a CAR after determining that the action taken by the company to correct the non-conformance has been completed successfully. The food safety auditor uses their skills and knowledge of food safety, together with objective gathering of evidence relating to the area, process or system that was previously deemed non-compliant, to assess whether the corrective action that has been taken has been effective. Corrective actions should provide timely, long term and robust solutions to identified food safety issues and, where possible, should address the root cause of the problem. This may require several separate corrective actions to be put in place in order to fix a given problem.

In some cases, when the timeframe for corrective action on a given CAR has transpired and not all actions are sufficiently completed, it may be necessary to close out the CAR and re-raise a separate CAR. In this instance, the second CAR will be written to cover the remaining actions that are still to be completed.