S. Dix, Tesco Stores plc, Welwyn Garden City
3.2 Routine auditing: new suppliers
The auditing of a potential supplier should include a thorough examination of their hazard analysis critical control point (HACCP) and quality management systems both on paper and in practice. There must be a thorough inspection of the factory to assess whether or not the standards of maintenance and cleanliness comply with the retailer’s code of practice. Many companies would like to supply major retailers so it is common practice to send out a pre-audit questionnaire. The format of this may vary depending upon the type of product manufactured. Risk assessment is often used to define the conditions required, the frequency of re-audit and the number and frequency of product checks that should be carried out by both the supplier and retailer. The pre-audit questionnaire will therefore be highly detailed for suppliers of products such as chilled ready meals which must be manufactured in a high care environment and less detailed for low risk producers such as produce packers. The replies to these questionnaires may eliminate some potential suppliers. However, if there is a real customer need then retailers may send the company a copy of their own quality management systems manual and help them to work through and comply with the contents. This is most likely to occur with a new business unused to dealing with major retailers.
3.2.1 Auditing a supplier’s safety and quality systems
One indicator of the suitability of a supplier would be the existence of a fully documented safety and quality management system. This should be detailed in a manual which contains a description of all the control measures taken within the factory and stipulates the frequency with which all checks are carried out, together with the name of the most senior manager accountable for these measures. Systems change continuously within a factory as a response to the introduction of new equipment, ingredients and processes. A retail auditor would therefore expect to see evidence that the management system was under continuous review. This is easily checked by looking at an index showing revision numbers and dates.
Retailers and their agents will usually send a checklist to potential suppliers in advance detailing both the written policies that they wish to see and a list of
daily/weekly/monthly check sheets that will prove that measurements are carried out as described in the manual (see Fig. 3.1). There is an additional opportunity to check this documentation during the factory inspection on the day when systems can be viewed in action as well as in retrospect. The existence of an ISO certified system would not necessarily ensure approval as the quality management systems required are often specific to that retailer and matters of supreme importance to them might not be covered by the certification process.
For example, retailer requirements on the welfare of animals before and during slaughter may not be covered in the ISO certification process but might form a major part of a retailer’s policy. Adherence to the retailer’s policy would therefore be equally as important as ISO certification.
Retailers are primarily concerned with the safety of their customers. The existence of a fully documented HACCP plan is a legal requirement and therefore a detailed examination of this is essential before approval. A retail auditor may ask to see the HACCP plan for a particular product in advance of the visit as the quality of this would be a good indicator of the management’s understanding of HACCP. However, the existence of a plan is not enough.
During the factory inspection the auditor should specifically ask departmental managers, line leaders and operatives where the critical points in the area are and how often they are monitored. The ability to answer additional questions on why these points are critical would give a measure of the effectiveness of hygiene training. The design of quality control sheets can assist in reinforcing this knowledge by indicating where the critical control points are in the process and what action should be taken if there is a deviation from permitted values.
The approval audit must include a check on the frequency of staff training together with the adequacy of training records.
A further key requirement would be the traceability of all ingredients from the coding on incoming raw materials through processing into the finished pack.
The systems for doing this would be documented in the manual but can be checked during the factory inspection and/or by asking in advance for all of the records for one product made on a particular day to be available. These would then be examined during the audit. Full traceability is essential to ensure that withdrawals from sale for both safety and quality purposes catch all affected products. Sound systems are particularly necessary if the specification allows reworked material to be included in a finished product no matter how small the quantity. The practical application of the system can also be verified by checking the labelling on bins and racks during the factory inspection.
A key indicator of management commitment to quality and safety would be regular internal audits of the systems of work. These must be well documented and show that action has been taken to correct any non-compliances with the written quality management system.
The factory approval visit must be fully comprehensive as it is much harder to obtain improvement once supply has begun. Withholding approval until the required standards are reached usually results in speedier compliance. Retailers may use scoring systems before approval but extreme caution is needed with
Dear
LEGAL COMPLIANCE AUDIT
I am writing to advise you that I intend to carry out a factory audit at your premises on . . .
I intend to examine the following aspects of your Legal Compliance and Quality Management Systems and will require production of the documentation identified below:
1. Legal Compliance Management 2. Legal Compliance Systems 2.1 ú HACCP Charts and Records.
2.2 ú Product Specification.
2.3 ú Pest Control Records.
2.4 ú Metal Detector/Checkweighing Records.
2.5 ú Traceability Records.
2.6 ú Internal Audit Records.
2.7 ú Complaints Records.
2.8 ú Other.
3. Premises and Equipment 3.1 ú Cleaning Schedules.
3.2 ú Maintenance Records.
3.3 ú Other.
4. Raw Materials
4.1 ú Records relating to audits of raw materials.
4.2 ú Records relating to audits of raw material suppliers.
4.3 ú Other.
5. Process Controls
5.1 ú Production Records.
5.2 ú Other.
6. Inspection/Test/Analysis 6.1 ú QC Records.
6.2 ú Other.
7. Packaging/Storage/Distribution 7.1 ú Lot Marking.
7.2 ú Other.
8. Staff and Training 8.1 ú Training Records.
8.2 ú Health Screening Procedures and Records.
8.3 ú Other.
Please ensure that all the relevant personnel are available to discuss the above.
Should it be necessary to cancel/postpone my visit, you will be notified by telephone at the earliest opportunity.
Fig. 3.1 Legal compliance audit checklist.
these. It may be possible to obtain a high score while failing to control a critical point in the process, thereby putting customers at risk. Any scoring system must therefore employ a weighting procedure which takes account of the risk assessment of the product type. There is no substitute for the experience of a knowledgeable and well trained auditor.
3.2.2 Auditing a supplier’s quality of service
Auditing of a new supplier should not concentrate only on legal and safety issues.
The retailer will have various requirements as to capacity, shelf-life and delivery deadlines. Conversations between buyers, technical managers and potential suppliers as to volume requirements in advance of the visit are essential. Approval of a factory to supply 500 stores with a chilled short-life product, if the factory only has refrigeration and packing equipment to supply 200 stores daily, will usually end in short deliveries or poor quality. Allowance should be made for additional volume requirements for promotions and supply to other customers of the factory must be considered. The auditor should therefore check aspects such as cooking capacity, line speeds, cooling capacity, etc. at the time of the visit to ensure that the predetermined requirements can be met.
Short shelf-life products such as poultry meat may also present other diffi-culties. Supply will depend upon a schedule which allows for slaughter, chilling, packing, transport to depot and onward distribution giving sufficient days in store for sale. When planning to import from abroad this can cause difficulties. The auditor must consider measures that could be taken to extend shelf-life. Modified atmosphere packaging is particularly useful in these circumstances and the auditor may decide that provision of this is a condition of supply.
The quality of raw materials in use must be appropriate for the product and a knowledge of suitable ingredients suppliers is invaluable to an auditor. For example, if the factory produces fish ready meals, they should be serviced by companies with vessels that fish in areas that provide the best quality. Questions about the catchment area of supply should be included in the pre-audit question-naire in order to eliminate visits to unsuitable potential suppliers. However, during the audit, raw material supply records should be checked to ensure that the fish is coming from the quoted suppliers. Some retailers may even specify the sources of ingredients to be used in order to ensure that their own codes of practice are adhered to at all stages of manufacture and this should also be checked during the audit. The authenticity of ingredients which are claimed to be free from genetic modification or suitable for vegetarians can be checked at this stage.
The type of packaging used by suppliers can also be critical. If supply is required in plastic bottles then a visit to a plant that can only fill into glass would be a waste of both parties’ time. Sources of packaging supply, the nature of materials, e.g. recyclable, ability to withstand conventional cooking, grilling or microwaving are important, as are conditions under which packaging materials are stored and sterilisation before use, if appropriate. A certain amount of pre-visit questioning will ensure the best use of limited time.