of mandatory food safety programs - lga.sa.gov.au guidelines... · national library of australia...
TRANSCRIPT
National Library of Australia Cataloguing-in-Publication entry
Title: Guidelines for auditors of mandatory food safety programs.
ISBN: 9780730897446 (pbk.)
Subjects: Auditing--Standards--South Australia.
Food--Safety regulations--South Australia.
Food industry and trade--Standards--South Australia.
Other Authors/Contributors:
South Australia. Dept. of Health.
Dewey Number: 363.19262099423
Guidelines for Auditors of Mandatory Food Safety Programs
1 Introduction 2
1.1 Aim 2
1.2 Regulatory requirements 2
2 Roles and responsibilities/
duties within the audit system 2
2.1 Department of Health 2
2.2 Local government 2
2.3 The food business 3
2.4 Duties of food safety auditors 3
3 Appointment of food
safety auditors 3
3.1 Auditor application 3
3.2 National food safety auditor certification 3
3.3 Approval of food safety auditors 3
3.4 Certificates of authority of food
safety auditors 4
3.5 List of food safety auditors 4
3.6 Term of approval 4
3.7 Conflict of interest 4
3.8 Suspension or cancellation of approval 5
3.9 Review of approval decision 5
4 The audit 5
4.1 Audits or inspections 5
4.2 Audit fees 6
4.3 Priority classification 6
4.4 Complaints 6
4.5 Verification activities 6
5 Audit reports 6
5.1 Auditor reporting requirements 6
6 Non-conformances 7
6.1 Non-conformances and inadequacies 7
6.2 Critical non-conformance notification 7
6.3 Major non-conformances 8
6.4 Minor non-conformances 9
7 Audit frequency 10
7.1 Initial frequency of auditing 10
7.2 Redetermination of frequency of auditing 10
8 Attachments 12
1. Auditor application form
2. RABQSA NFSA Certification Scheme
3. Approved Auditors Code of Conduct
4. Priority classification system
5. FSP audit checklist
6. FSP audit report
7. Audit system process flow diagram
9 Acknowledgments 12
10 References 12
Contents
Guidelines for Auditors of Mandatory Food Safety Programs page 1
1 Introduction
1.1 Aim
The aim of this publication is to outline the requirements for auditing food businesses in South Australia
that are required to have mandatory food safety programs.
The guidelines explain the responsibilities, duties and roles of auditors approved by the South Australian
Department of Health under the SA Food Act 2001 (the Act).
Primary Industries & Resources SA (PIRSA) and the Dairy Authority of South Australia (DASA) are responsible
for auditors authorised under the Primary Produce (Food Safety Schemes) Act 2004. Department of Health,
PIRSA & DASA are working closely to ensure South Australian jurisdictions comply with the National Food
Safety Audit Policy and apply consistent approval criteria.
The guidelines will assist auditors and prospective auditors to understand South Australia’s regulatory system
in relation to the food safety audit system and the requirements for auditing food safety programs, to ensure
provision of safe and suitable food by high-risk businesses required to have a mandatory food safety program.
1.2 Regulatory requirements
Part 7 of the Act outlines:
the requirements for approving food safety auditors in Division 1 >
auditing and reporting requirements in Division 2. >
The approval and audit process will comply where practicable with the National Food Safety Audit Policy
agreed to by the Australia and New Zealand Food Regulation Ministerial Council in October 2006 to promote
national consistency in food safety auditor and audit management.
2 Roles and responsibilities / duties within the audit system
2.1 Department of Health
As defined in the Food Regulations 2002, the Department of Health acts as the relevant authority
for administration of the Act.
The Food Safety and Audit Section in Food Policy and Programs Branch, Public Health SA, will manage
the system for the new food safety requirements for higher risk food businesses in South Australia.
The Food Safety and Audit Section is responsible for the priority classification system, the auditor
approval process, the facilitation of training and support for local government auditors, and the completion
of verification audits.
2.2 Local government
Local government is the appropriate enforcement agency for food businesses requiring food safety programs,
except for the unincorporated areas where it is the Department of Health.
The appropriate enforcement agency will inform food businesses in writing of their requirement to have
a mandatory audited food safety program and of the initial audit frequency.
If a food business is required to have a mandatory audited food safety program, the Department of Health
would not expect the council to continue routine inspection of the business. Unannounced inspections may,
however, still be conducted at the discretion of the council.
Guidelines for Auditors of Mandatory Food Safety Programspage 2
The majority of audits, particularly those that are scheduled, will be announced audits. The benefits
of announced audits include the following:
They encourage a compliance relationship with the food business, where the business and auditor work >
together to ensure that the food safety program is compliant.
They ensure that relevant personnel are available on the day of the audit and that the timing of the audit >
minimises disruption to the food business.
They ensure that the food business is actually operational on the day of the audit. >
The appropriate enforcement agency (local government or Department of Health) will be responsible for
following up any contraventions that are reported as critical (reported in 24 hours) by approved auditors.
2.3 The food business
The proprietor of a food business is responsible for the preparation, implementation and maintenance
of a mandatory food safety program. The proprietor is also responsible for ensuring that the food business
is audited at least as frequently as determined by the priority classification.
2.4 Duties of food safety auditors
Section 80 of the Act sets out the duties of food safety auditors:
To carry out audits of mandatory food safety programs and determine their compliance with >
the requirements of Food Safety Standards 3.2.1, 3.2.2 and 3.2.3.
If necessary, to carry out any follow-up action, including follow up audits, to ensure that corrective actions >
to fix non-conformances have been completed.
To report in accordance with the requirements of the Act. >
Approval as an auditor in no way diminishes from the applicant’s duties as an authorised officer.
3 Appointment of food safety auditors
3.1 Auditor application
Applications for approval (see attachment 1) as a food safety auditor under the Act need to be forwarded
to the Department of Health, Food Safety & Audit Section; and must be accompanied by the appropriate
certificate from the auditor certification body, Registrar Accreditation Board Quality Society of Australasia
(RABQSA), a criminal history clearance letter and the approval fee as specified on the application form.
3.2 National food safety auditor certification
RABQSA is the certification body recognised by the Department of Health to certify food safety auditors
under the National Food Safety Auditor (NFSA) scheme.
Attachment 2 provides a summary of the NFSA scheme and its process. Requirements and information
can be viewed on the RABQSA web site www.rabqsa.com.
3.3 Approval of food safety auditors
Under Part 7, s73 of the Act, auditors for mandatory food safety programs must be approved
by the Department of Health.
Approval Criteria
As part of the approval process prospective auditors will be required to:
demonstrate technical and audit competence >
demonstrate knowledge of relevant Food Safety Standards including 3.1.1, 3.2.1, 3.2.2 and 3.2.3 >
demonstrate relevant and ongoing work experience in administering food legislation, in particular, >
the skills and experience collecting evidence and taking action where breaches of the Act are identified.
Guidelines for Auditors of Mandatory Food Safety Programs page 3
hold current certification as National Food Safety Auditor Level 4 (High risk) >
demonstrate ongoing professional development or currency of skills >
demonstrate knowledge of the South Australian food regulatory system >
obtain a criminal history clearance letter. >
As a general guide, the Department of Health considers that, in order to meet the competency requirements
for approval, an applicant should have had at least 2 years’ relevant work experience, that is, experience with
administering food safety legislation.
Employees of councils (or of bodies established by a council or councils) approved as food safety auditors will
be conducting food safety audits in the course of their employment.
Once approved, auditors are required to comply with the relevant provisions of the Act and conditions
of certification that have been determined by the Department of Health. As part of the application process,
the auditor will be required to agree to the Approved Auditors Code of Conduct (see attachment 3).
Auditors must notify the Department of Health immediately of any changes to their personal details
and qualifications that may affect their suitability to undertake the role of a Department of Health
approved auditor.
If an application is granted, the applicant must be issued with written approval that sets out any conditions
to which the approval is subject. If the application for approval is refused, the reasons must be set out in
writing to the applicant.
3.4 Certificates of authority of food safety auditors
The Department of Health will provide a certificate of authority in the form of an ID card for each approved
auditor. This will cite their authority under Part 7 of the Act and carry the auditor’s name, signature, photo
and expiry date.
The card is to be carried when conducting audits as evidence of approval to do so.
3.5 List of food safety auditors
A list of approved auditors will be available on the Department of Health web site.
3.6 Term of approval
Approval is granted for a 4-year period unless cancelled or suspended within that timeframe. Auditors must
re-apply to the Department of Health every 4 years to be re-approved.
Re-approval may be conditional upon attendance at annual auditor forums/workshops and other appropriate
professional development as determined by the Department of Health, to ensure skills maintenance and
development of the auditor workforce.
3.7 Conflict of interest
Auditors must, in all circumstances, avoid possible conflicts of interest. Auditors must not audit a food safety
program that they have written or provided direct assistance in preparing. Auditors must not audit premises
where they have a personal and financial interest in a business.
Payment for carrying out the function of an auditor does not constitute a direct or indirect interest in a
business. Inspection of a food business or general food safety advice to a food business does not constitute
a direct or indirect interest.
In situations where the auditor is the authorised officer and is the only educational resource for food
businesses, a conflict of interest can be managed by providing advice to the food business through examples
of how hazards may be controlled rather than giving specific direction to the food business on how specific
hazards will be controlled by that business.
Guidelines for Auditors of Mandatory Food Safety Programspage 4
There is no conflict of interest where an auditor is a state or local government regulator. Currently,
environmental health officers conduct inspection where they are both the ‘inspector’ and the enforcement
agency. The Department of Health considers this to be a similar situation but including the audit process rather
than the inspection process.
3.8 Suspension or cancellation of approval
Under s76 of the Act, the Department of Health may vary the conditions of, suspend or cancel an auditor’s
approval under certain circumstances.
The Department of Health must be satisfied that the person:
has failed to comply with the requirements of the Food Act; or >
is found not to be sufficiently competent; or >
has been guilty of any fraudulent conduct in carrying out an audit; or >
was granted certification on the basis of fraud, misrepresentation or concealment of facts; or >
is no longer an authorised officer under the Act. >
The Department of Health may only vary conditions, cancel or suspend an approval after providing the person
with the reason(s) in writing, and having considered the person’s response should they make one.
3.9 Review of approval decision
If unhappy with a decision by the Department of Health relating to auditor approval, a person may apply
to the Administrative and Disciplinary Division of the District Court for a review of this decision in writing
within 28 days.
Reasons for requesting a review as defined under s77 of the Act are:
the grant or refusal of an application for an approval >
the imposition of conditions on an approval >
the variation of conditions of an approval >
the suspension or cancellation of an approval. >
4 The audit
4.1 Audits or inspections
An inspection is used to assess compliance where the standard is fairly prescriptive and where no
documentation or records are required to be kept by the business. The recognised international definition
for inspection is: ‘Evaluation for conformity by measuring, observing, testing or gauging the relevant
characteristics.’
An audit, on the other hand, is used to assess systems. Where a standard requires a business to have a
management system to control either processes or the quality of product, an audit is used to assess whether
the system has been implemented and is effective in meeting that standard. ‘Audit’ is used where there is a
documented system and records to review. The recognised international definition for audit is: ‘A systematic
and independent examination to determine whether quality/safety activities and related results comply with
planned arrangements and whether these arrangements are implemented effectively and are suitable to
achieve objectives.’
4.2 Audit fees
The Department of Health will only set audit fees for public hospitals and other businesses audited directly
by the Department of Health. Other audit fees may be determined by auditors or councils and will be
regulated by market forces.
Guidelines for Auditors of Mandatory Food Safety Programs page 5
4.3 Priority classification
The Food Act 2001:
s79(1) requires that the appropriate enforcement agency must determine the priority classification >
of individual food businesses for the purposes of food safety programs; and the frequency of auditing
of any food safety programs.
s79(2) requires that the determination must be made having regard to a priority classification system >
for types of food businesses approved by the relevant authority.
s79(3) requires the appropriate enforcement agency to provide written notification to the food business >
of its priority classification and audit frequency.
The priority classification system approved by the Department of Health is based on the Food Regulation
Standing Committee National Risk Profiling Framework (April 2007) (see attachment 4).
Enforcement agencies (local government or Department of Health) will be responsible for providing written
notification to the food business of its priority classification and audit frequency.
4.4 Complaints
If the council or a business is dissatisfied with a response from an auditor, has complaints of incompetence,
or has evidence of non-compliance with the requirements of the Act against an auditor, they must refer these
matters in writing to the Department of Health for resolution.
4.5 Verification activities
Auditing is a critical component in the mandatory food safety program system. The audit system must provide
sufficient competent auditors who perform at an appropriate level.
To ensure that auditor performance is appropriate, the Department of Health will monitor the performance
of approved auditors to confirm that appropriate audit outcomes are identified. This is also a requirement
of the National Food Safety Audit Policy.
To ensure the audit system is operating effectively and to identify improvement opportunities, the Department
of Health will review the system after 2 years in operation (2010).
5 Audit reports
5.1 Auditor reporting requirements
In relation to reporting, s81 of the Act requires that the food safety auditor must prepare a written report on
the prescribed forms (Audit Checklist & Food Safety Audit Report; attachments 5 and 6) of the results of any
regulatory audit carried out.
A food safety auditor must report to the enforcement agency any contravention that is an imminent and
serious risk to the safety of food intended for sale, or that will cause significant unsuitability of food intended
for sale, as soon as possible but in any event within 24 hours.
A copy of the Audit Checklist and Food Safety Audit Report must be given to:
the proprietor of the food business concerned >
the appropriate enforcement agency, usually the council >
the Department of Health >
within 21 days after completion of the audit.
The report must take account of any action taken before submission of the report to remedy any deficiency
identified by the food safety auditor.
The food safety auditor must ensure in the audit report that any non-compliances are documented,
with details provided of the nature of the non-conformance including objective evidence.
Guidelines for Auditors of Mandatory Food Safety Programspage 6
Where non-conformances have been identified and subsequently remedied by the food business proprietor,
the audit report must describe each failure or inadequacy that has been remedied.
A food safety auditor must report in writing to the appropriate enforcement agency when the frequency
of inspection is changed.
A food safety auditor must report in writing to the appropriate enforcement agency, and provide reasons,
if the auditor considers that the priority classification of a food business that has been audited should be
changed and no longer requires a food safety program. Examples of reasons why a business providing food
service to vulnerable populations may require a change of priority classification include ceasing to prepare
potentially hazardous food or clientele permanently dropping below six vulnerable persons.
Where non-conformances have been identified, the auditor must follow the procedures detailed in Section
6 ‘Non-conformances’.
6 Non-conformances
6.1 Non-conformances and inadequacies
A non-conformance is a food handling practice that is found not to comply with specified requirements
documented in the food safety program or the requirements of the Act or Food Safety Standards.
6.2 Critical non-conformance notification
A critical non-conformance is defined as a contravention of the requirements of the Act or Food Safety
Standards where a serious or imminent risk to public health is identified, or that will cause significant
unsuitability of food intended for sale. That is, if the food, practice or situation has compromised the health
of consumers or, if allowed to continue, will compromise consumers’ health.
Where a food safety auditor has conducted a food safety audit for the purposes of the Act, they must notify
the appropriate enforcement agency immediately by telephone and follow up by written confirmation as
soon as practical but no later than 24 hours.
The authorised officer of the appropriate enforcement agency should attend the premises and ensure action
is taken within 24 hours of the telephone notification to ensure the risk to health is removed. The appropriate
enforcement agency will advise the auditor when it is satisfied the risk to health has been removed and the
auditor will re-audit the premises to close out the critical non-conformance.
Where the auditor is auditing a food business within their own agency’s jurisdiction, that is they are the
appropriate enforcement agency, the auditor may choose to stop the audit and take action as the authorised
officer. It is recommended that the auditor advise the food business at the commencement of the audit that
they may exercise this option and, if they do, that they are clear in their communication.
Guidelines for Auditors of Mandatory Food Safety Programs page 7
Where a critical non-conformance has been detected, the written advice to the appropriate enforcement
agency should contain:
the name and address of the food business >
the date the non-conformance was issued >
the Standard or other requirement being breached by the non-conformance >
details of the non-conformance, including copies of records, if required >
signatures of the auditor and the person in the business with whom the non-conformance was discussed >
corrective action as proposed by the food business >
details of verification of corrective action. >
6.3 Major non-conformances
A major non-conformance is a potential high-risk situation, where the potential impact is likely to compromise
food safety if no remedial action is taken. All major non-conformances will be submitted with the standard
audit report to the appropriate enforcement agency within 21 days, as the issue does not present an imminent
risk to health. The appropriate enforcement agency will decide if they need to act.
The auditor may conduct a follow-up audit to check that corrective action has been taken to remedy
any major non-conformances. This could be in addition to the regular frequency of audits.
Example of a critical non-conformance
During an audit of a nursing home, the auditor observes that kitchen staff are using the same
cutting board for cutting up raw chicken and for the preparation of fresh salad. The proprietor
explains that it is a waste of money buying extra cutting boards, though he will eventually do it.
The auditor also queries that the food handler didn’t wash their hands after handling the raw
chicken and then the salad.
Scenario 1 - The auditor immediately advises the nursing home manager that this is a critical
non-conformance; and that all ready-to-eat food cut on the cutting board in question should
not be served, and other food may be contaminated by poor personal hygiene of food handlers.
The auditor contacts the council environmental health officer by telephone as soon as possible,
advises of the critical non-conformance and follows up later that day with a facsimile to the council
of what was observed. A week later, the council environmental health officer advises the auditor
that the non-conformance has been rectified and that they can now re-audit the business.
Scenario 2 - The auditor immediately advises the nursing home manager that this is a critical
non-conformance and represents an imminent risk to public health, and that the audit will stop
at this point and the auditor will then be addressing the non-conformance as the council’s
authorised officer.
Guidelines for Auditors of Mandatory Food Safety Programspage 8
6.4 Minor non-conformances
A minor non-conformance is a low-risk situation where there is a non-compliance with the requirements
of the Act or Food Safety Standards but the potential impact of the non-conformance is not likely to
be a serious or imminent risk to public health. This includes a non-conformance with the business’s food
safety program.
The auditor must negotiate with the business to determine an appropriate timeframe for rectification,
and then follow up to ensure the minor non-conformance has been rectified. This can generally be checked
at the next scheduled audit.
If an auditor identifies a number of minor non-conformances which, taken collectively, are likely to
compromise food safety, the non-conformances may be classified as a major or critical non-conformance
immediately, and appropriate action be taken.
Minor non-conformances must be reported to the appropriate enforcement agency by the auditor by means
of the ‘audit report and checklist’ within 21 days.
Example of a major non-conformance
During an audit of a hospital kitchen, the auditor observes that there are no disposable towels at the
wash hand basin. The proprietor explains that staff constantly wash their hands but use tea towels,
which aren’t sighted by the auditor, to dry their hands.
The auditor is satisfied that staff do wash their hands but issues a major non-conformance for the
lack of appropriate hand-drying facilities, and re-audits the business within 14 days.
Example of a minor non-conformance
During an audit of an aged care facility, the auditor observes that there are broken floor tiles in
the kitchen area, a build-up of grease in the filters of the exhaust canopy above the stoves, and
packaged food being stored on the floor of the cool room. The auditor also observes that stock
rotation, though not a safety issue at the time of the audit, could be improved.
The auditor negotiates with the proprietor of the business that the filters are to be cleaned within
24 hours, and that within 21 days the broken floor tiles will be replaced and that there will be
additional shelving for the cool room so that no packaged food has to be stored on the floor.
The auditor also gets an undertaking that ‘first-in-first-out’ stock rotation will be implemented.
Prior to closing out the non-conformance, the auditor verifies that it has been rectified––this may
be by a re-audit or by having the business send photographs of the clean filters, new floor tiles
and cool room shelving.
The auditor could leave the first-in-first-out stock rotation issue until the next audit.
Guidelines for Auditors of Mandatory Food Safety Programs page 9
7 Audit frequency
7.1 Initial frequency of auditing
The priority classification system approved by the Department of Health presently recommends an initial
audit frequency for high-risk businesses requiring food safety programs to be 6-monthly. The outcomes
of two audits will be required to establish a compliance history that can allow for the adjustment of
audit frequency.
All businesses required to have a mandatory food safety program will require an audit at least annually.
The audit frequency for high-risk businesses is based on the Food Standards Australia and New Zealand
(FSANZ) Food Safety Priority Classification System for Food Businesses (2001).
7.2 Redetermination of frequency of auditing
The food safety auditor, as per s82 of the Act, may advise the appropriate enforcement agency and the
Department of Health that the food business’s audit frequency will change to require either more frequent
audits in the case of poor performance or less frequent audits in the case of good performance. A food safety
auditor must have regard to the compliance history of the food business in making such a determination.
Guidelines for Auditors of Mandatory Food Safety Programspage 10
Guidance on movement of food businesses within audit frequency ranges
Level of Audit
frequency notes
Level of frequency
Audit confidence
Notes
Critical (notifiable)
non-conformance
To be determined
by authorised officer
relative to the breach.
Audit frequency
increases to the
maximum level
(3-monthly).
The food business’s food safety program is not effective
in producing safe food. The auditor raises a critical
non-conformance and the enforcement agency is notified.
It is then the responsibility of the enforcement agency
to take action to address the identified problems.
Assessment of the food business, on identification of a
critical non-conformance, may include inspection as well
as audit, that is whatever is determined to be appropriate
by the enforcement agency.
Major non-conformance
(marginal food
safety program)
Audit frequency can
remain the same or
increase a level (i.e. if
the food business is on
6-monthly audits, the
frequency would move
to 3-monthly).
The maximum
adjustment is one level.
The food safety program has been implemented but does
not always follow the documented process, e.g. there
may be a non-conformance identified that has not placed
public health at risk, and therefore does not constitute a
critical non-conformance.
A non-conformance against specific controls within the
food safety program would most likely make the
program marginal, whereas it may take a number of
non-conformances against prerequisite or support
programs to make the program marginal.
Minor non-conformance
(satisfactory food
safety program)
Frequency remains
the same or can be
decreased if the auditor
has confidence in the
food safety program.
The maximum
adjustment is one level.
There is confidence that the system has been
implemented and is effective. There may still be a small
number of non-conformances raised against prerequisite
or support programs.
Confidence in the
food safety program
Frequency reduces
to the minimum level
(i.e. if the food business
is on 6-monthly
frequency, this moves
out to 12-monthly).
The maximum
adjustment is one level.
There is a high level of confidence in the food safety
program and the food business. Confidence can be
measured in one of two ways: the food business has
a continuing compliance with the food safety program,
or it has an effective internal food safety audit and
management review process.
Food businesses cannot be moved to this audit
frequency unless there is a compliance history available
to the auditor, and the food business has had no critical
non-conformances identified in two previous audits.
Guidelines for Auditors of Mandatory Food Safety Programs page 11
8 AttachmentsThese attachments are correct at the time of publishing but may be updated periodically.
1. Auditor application form
2. RABQSA NFSA Certification Scheme
3. Approved Auditors Code of Conduct
4. Priority classification system
5. FSP audit checklist
6. FSP audit report
7. Audit system process flow diagram
9 AcknowledgmentsThis guideline was developed with the assistance of a working party comprising representatives from the
following organisations:
Environmental Health Australia (SA Division) >
Department of Health, Food Policy and Programs Branch >
Local Government Association of South Australia >
Adelaide City Council >
Berri Barmera Council >
City of Holdfast >
City of Mitcham >
City of Port Adelaide Enfield >
City of Tea Tree Gully >
City of Unley >
City of West Torrens >
Eastern Health Authority >
The Department of Health would like to convey their sincere appreciation to the supporting organisations for
making a representative available and to the members of the working party for their valued contribution.
10 ReferencesParliament of South Australia 2001, Food Act 2001, Parliament of South Australia, Adelaide, viewed
1 September 2008, <http://www.legislation.sa.gov.au/LZ/C/A/FOOD%20ACT%202001.aspx>
Australia New Zealand Food Authority 2001, Food safety: an audit system, Food Standards Australia New
Zealand, Canberra, viewed 1 September 2008,
<http://www.foodstandards.gov.au/_srcfiles/FS_Audit_Report_final%20edit0702.pdf>
Australia New Zealand Food Authority 2001, Food safety: guidance for food safety auditors, Food Standards
Australia New Zealand, Canberra, viewed 1 September 2008,
<http://www.foodstandards.gov.au/_srcfiles/Auditor%20Handbook%20final%20Oct%202001.pdf>
Australia New Zealand Food Authority 2001, Food safety: the priority classification system for food businesses,
Food Standards Australia New Zealand, Canberra, viewed 1 September 2008,
<http://www.foodstandards.gov.au/_srcfiles/ANZFA_1578_Info_Paper__final.pdf>
Australian and New Zealand Food Regulation Ministerial Council 2006, National food safety audit policy,
Department of Health and Ageing, Canberra, viewed 1 September 2008, <http://www.health.gov.au/internet/
main/Publishing.nsf/Content/2087CDEAEE7C703CCA256F190003AF4B/$File/nat-food-safety-aud-pol.pdf>
Guidelines for Auditors of Mandatory Food Safety Programspage 12
For more information
Food Policy and Programs Branch SA Health PO Box 6, Rundle Mall SA 5000 Telephone: (08) 8226 7100 Fax: (08) 8226 7102 Email: [email protected]
www.sahealth.sa.gov.au
Non-English speaking: for information in languages other than
English, call the interpreting and Translating Centre and ask them
to call The Department of Health. This service is available at no cost
to you, contact (08) 8226 1990.
http://www.gilf.gov.au/
© Department of Health, Government of South Australia. All rights reserved. ISBN: 9780730897446 (pbk.) FIS: 10189.1 Updated October 2010.
Under the Food Act 2001 June 2014
Approved Food Safety Auditor Application New approval � Renewal of approval � Auditor No....................
Applicant details
Name: ....................................................................................................................................................................................
Address: ...................................................................................................................................................................................
Website contact details (only include details you want added to the SA Health website)
Telephone: .......................................... Mobile: ................................................. Work: ............................................
Email Address: ...........................................................................................................................................................
Qualification details
Authorised Officer of Council / Authority:..................................................................................................................
RABQSA Registration Number:................................................................................................................................
� attached copy of my NFSA Level 4 certification.
� attached copy of my Criminal History Screening Unit letter of clearance.
� emailed a current photograph (email digital photo to [email protected])
� invoice council or � I have attached cheque or money order for $147.40 ($134.00 + GST).
Audit area (please indicate � this will be included on the SA Health website)
�Own council/authority �Other council/authority Specify ........................................................
�All councils
Declaration by applicant
I, (print full name) ......................................................................................................................................................
Being the applicant, apply for approval as a food safety auditor under the provisions of the South Australian Food Act 2001, and confirm that:
> I have read and agree to comply with the Approved Auditors Code of Conduct and the South Australian Guidelines for Auditors of Mandatory Food Safety Programs.
> I will be able to demonstrate skills, knowledge and competencies required to be an approved auditor if requested.
> I understand that I must notify the Department for Health and Ageing immediately of any changes to my personal details and qualifications that may affect my suitability to undertake the role of a SA Health approved auditor.
> I note that attendance at the annual auditor forum will be required. > I declare that all information supplied in preparing this application is true.
Signature of Applicant: .......................................................
Date: ...................................................................................
OFFICE USE ONLY
Application/Auditor number
Date Received
RABQSA National Food Safety Auditor Certification Scheme (NFSA)
As part of the development of the National Food Safety Audit Policy the National Food Safety Auditor Certification Scheme (NFSA) was developed by the Australian Government Department of Agriculture, Fisheries and Forestry (DAFF) and RABQSA International Inc. (Personal certification body PCB) in partnership with industry and food safety regulators. It was launched on 28 Feb 2006 and highlighted the food industry’s need for the Scheme which establishes a national benchmark for certifying food safety auditors.
The Department of Agriculture, Fisheries and Forestry headed the initiative to develop a single national certification scheme that encompasses first, second and third party auditors, and provides confidence to industry in the abilities of food safety auditors. Improved confidence and national consistency in food safety auditor competency should contribute to reducing audit duplication and compliance costs.
The scheme represents a world’s first in terms of government and industry engagement on an issue of national importance involving food safety.
The scheme is the catalyst for the coming together of producer, supplier, regulator and retailer in the aim of unifying food safety standards, audit consistency and conformity assessment rationalization.
The NFSA scheme reflects an innovative approach by combining:
> Knowledge competency;
> Education requirements associated with each high risk scope, to determine auditor competence.
> Personal attributes; and
> Required auditor performance (Skill) competency.
The committee reviewed the diversity and scope of the food industry in Australia and aligned food safety auditor certification levels according to food safety risk rather than industry sector scopes. This risk-based approach provides clear advice to system owners selecting auditors and also enables NFSA certified Auditors to audit across a broad range of industries.
The scope is determined by risk
> Level 1 Compliance
> Level 2 Low Risk
> Level 3 Medium Risk
> Level 4 High Risk
Attachment 2
September 2008
Level 4 Auditor Certification requirments
NFSA-4 auditors are recognised as competent to audit high, medium or low risk businesses/processes.
1. Knowledge Requirements
All Applicants for Level 4 (NFSA-4) certification must provide evidence of the knowledge competency defined by RABQSA in the following competency units.
RABQSA-NFS2: Communicate and negotiate to conduct food safety audits
> Develop a communication plan to support audit processes
> Select and use appropriate communication methods to conduct an audit
> Negotiate to achieve agreement on audit outcomes
RABQSA-NFS3: Conduct food safety audits
> Plan the audit
> Conduct the audit
> Manage the audit process
> Consolidate audit outcomes
> Confirm and close out corrective actions
RABQSA-NFS4: Identify, evaluate and control food safety hazards
> Identify food safety hazards in a food business
> Control food safety hazards in a food business
2. Education
Applicants for NFSA-4 certification must provide evidence of a relevant nationally or internationally recognised tertiary qualification at Australian AQTF Certificate IV (or equivalent) or higher, such as a Degree, Diploma or Advanced Certificate in Food Technology or related field.
3. Examination of Personal Attributes
All Applicants for Level 4 (NFSA-4) certification must provide evidence they possess appropriate personal attributes, as shown. The attributes examined by
RABQSA are related to those defined in ISO 19011:2002 Guidelines for quality and/or environmental management systems auditing.
Applicants are required to demonstrate these personal attributes through completion of the e-based PAAS Master® Examination. Details to enable the completion of the PAAS Master® Examination will be provided to each Applicant when RABQSA receives their Application.
PAAS Master® Examination Fees are submitted with the Application Fees for Certification.
> Ethical – fair, truthful, sincere, honest and discreet;
> Proactive and Organised – takes the initiative with issues, and is personally
> organised;
> Systematic – shows a balanced affiliation for both tasks and people;
> Logical – makes decisions based on facts and reasoned logic;
> Decisive – expedites decisions methodically;
> Observant – shows the ability to identify both patterns and exceptions in complex situations;
> Diplomatic – relates to others and shows tact in appropriate situations;
> Flexible – shows a balanced global and detail focus;
> Process focused – demonstrates the ability to follow a pre-determined method;
> People Sensitive – is sensitive to and can identify a person’s emotional state;
> Adaptable and Resourceful – adapts to, and works with, different types of people
> in a range of situations and copes with change; and
> Confident – demonstrates certainty and competency, and reacts well to a variety of challenges, i.e. demonstrates calm and poise in challenging situations.
September 2008
4. Examination of Skill
All Applicants for Level 4 (NFSA-4) certification must provide evidence of the skill competency defined by RABQSA. Competency is to be demonstrated under auditing (onsite) conditions during an audit of a high risk business/process. The Skill Examination will be conducted by an RABQSA Certified NFSA Skill Examiner (Skill Examiner) who holds NFSA Level 4 certification. It is the responsibility of each Applicant to arrange for a Skill Examination.
The Skill Examiner examines and reports on the competency defined in the RABQSA Skill Examinations Level 2 and Level 3. Applicants must provide a copy of the completed Skill Examination Report, signed by both the Skill Examiner and the Applicant, as evidence of demonstration of the required Skill competency.
RABQSA Skill Examination Level 2
> Implement the audit plan
> Maintain communication during the audit
> Collect and verify information
> Assess food safety and implementation of food safety programs
> Conduct interviews
> Generate audit findings
> Prepare audit conclusions
> Conduct closing meeting
> Prevent and resolve conflicts
RABQSA Skill Examination Level 3
> All competency in Skill Examination Level 2 and
> Identify food safety hazards
> Identify methods to control food safety hazards
5. Surveillance
To maintain certification, all certified NFSA Auditors are required to demonstrate continuing compliance with the current certification criteria for the level of NFSA certification awarded.
RABQSA will provide reminders with the invoice for Annual Certification Fee to all certified auditors when the date for surveillance is due and the information required to be provided to RABQSA.
Every two years from the date of initial certification or each re-certification, NFSA Auditors must demonstrate continuing compliance with the current certification criteria by providing:
> evidence of current knowledge competency through successful completion of the relevant RABQSA e-based examination for the type and level of certification; and
> confirmation that the RABQSA Code of Conduct has been adhered to and any complaints against performance have been resolved.
The Annual Certification Fee includes the cost for Surveillance.
September 2008
6. Re - certification
RABQSA will provide reminders with the invoice for Re-certification Fee when the date for re-certification is due and the information required.
Every four years from the date of initial certification and each subsequent re-certification, certified Auditors must demonstrate continuing compliance with the current certification criteria by providing:
> evidence of examination of skill competency by an RABQSA certified NFSA Skill
> Examiner appropriate for the NFSA level of certification;
> evidence of evaluation of personal attributes by successful completion of the RABQSA PAAS Master® Examination within the previous four years;
> confirmation that the RABQSA Code of Conduct has been adhered to and any complaints against performance have been resolved.
September 2008
Guidelines for Auditors
Purpose of the codeAudit services must be delivered with honesty,
integrity, professionalism and accountability.
The Code of Conduct outlines how such an
outcome is to be achieved.
Application of the code
Auditors should:
familiarise themselves with the Code of Conduct >
ensure that its provisions are observed. >
An auditor who fails to comply with the provisions
of the Code of Conduct may be subject to
suspension or cancellation of their approved
auditor status.
Code of Conduct An auditor shall act professionally, with >
honesty, in good faith and in the best interests
of the consumers of food as a whole.
Auditors are expected to maintain open, honest >
and thorough communication with all parties
involved in the audit process.
An auditor has an obligation at all times >
to comply with all legislative requirements,
the ‘Guidelines for Auditors of Mandatory
Food Safety Programs’ and the principles
of this Code of Conduct.
Auditors shall show respect for other >
people, avoiding patronage and favouritism
and not allow personal beliefs to influence
their judgments or decisions on food safety
audit-related issues.
Auditors shall treat audit participants fairly, >
equitably and consistently, and follow clearly
defined and recognised criteria, processes
and delegations when making decisions.
An auditor shall not use abusive, obscene >
or threatening language or behaviour towards
others. Physical and/or verbal violence against
any person in the audit process is considered
a breach of the Code of Conduct.
An auditor shall observe the principles >
of procedural fairness when making decisions
by allowing the person concerned the
opportunity to put their side of the case
and have it considered before any decision is
made, and provide reasons for their decisions.
An auditor has a duty to use due care >
and diligence, including consideration
of equal opportunity, occupational health
and safety, discrimination, harassment
and victimisation legislation.
Audits are to be carried out in accordance with >
Department of Health policies. And auditors
are expected to conduct themselves in a
positive manner with a demonstrated positive
attitude to the Department of Health policies
and directions.
Auditors should conform to a standard of >
dress that is suitable for the type of work
performed and meet all bio-security and
occupational health and safety requirements
of the businesses being audited. It should be
respectable, clean, and not compromising to
the professional image of food safety auditors.
Auditors shall not smoke in non-smoking >
areas at workplaces or at any time allow
the consumption of alcohol, or restricted
or dangerous drugs, to adversely affect their
work performance or conduct.
An auditor shall not undertake auditing >
activities where there is a conflict of interest.
At any time, an auditor who is unsure whether
a conflict of interest exists should consult
the auditor guidelines or, where appropriate,
seek direction from the Department of Health.
Code of Conduct for Approved Food Safety Auditors
In short, the fundamental policy of the >
Department of Health is that no auditor
may solicit or accept gifts from any member
of the public concerned with any matter
connected with the duties of the auditor.
These policies do not apply to the acceptance
of meals during the course of an audit.
An auditor shall never ask for, encourage >
or initiate a bribe of any sort, whether it is
for himself, herself, or anyone else. Auditors
shall immediately report any situation to the
Department of Health where it is considered
that a benefit is being offered in return for
preferential treatment or to cause a conflict
of interest.
Confidential information received by an >
auditor in the course of the exercise of their
duties remains the property of the auditee.
It is improper to disclose that information
or allow it to be disclosed, unless that
disclosure has been authorised by the persons
from whom the information is provided, is
required by law or generated by, or supplied
for the purpose of communicating it to other
people or organisations, and has been released
for circulation (e.g. drafts of legislation,
guidelines, policies, Green Papers).
An auditor shall not improperly use information >
acquired in the course of their duties. Official
and commercial information shall not be
used by auditors to improperly gain any kind
of advantage for themselves, or for another
person or organisation.
The falsifying of any audit related >
documentation constitutes a breach of the
Code of Conduct and may result in suspension
or cancellation of the auditor’s approval.
Code of Conduct for Approved Food Safety Auditors
Department of Health Food Business Priority Classification System Part 7 Division 2 of the Food Act 2001 has provisions for auditing and reporting requirements relative to food safety programs.
The relevant enforcement agency must determine the priority classification and frequency of auditing of food safety programs for each food business having regard to a priority classification system for types of businesses approved by the relevant authority, in this case the South Australian Department of Health (DH).
The priority classification system establishes the initial auditing frequency and the range of allowable auditing frequencies for food businesses requiring a food safety program.
At this time, the priority classification system identifies only those food businesses that are required to have mandatory food safety programs compliant with Food Safety Standard 3.3.1 that is food businesses serving vulnerable populations. No other businesses are classified.
Food Businesses Type
Priority Classification
Compliance Arrangements
Food businesses required by the Food Act 2001 to comply with Food Safety Standard 3.2.1 Food Safety Programs.
Currently food businesses as set out in Standard 3.3.1 Food Safety Programs for Food Service to Vulnerable Person (generally hospitals, aged care facilities, childcare centres and delivered meals organisations but not including supported residential facilities and retirement villages).
Priority 1 (P1) Audit by Department of Health Approved Food Safety Auditor
Frequency of audit
Initially audit frequency - 6 months.
Audit frequency range
- maximum 3 months to minimum12 months.
An approved food safety auditor may change the audit frequency in accordance with section 82 after two complete audits.
Other food businesses Not classified at this time.
September 2008
Attachment 4
Page 1 of 10 October 2010
Audit Checklist
Legend
N/A Not applicable to this business
� Complies with the requirement
� Does not comply with the requirement
� / � The business generally complies but there is some area of non-compliance.
Name of facility:
Address:
Telephone: Fax:
Email Address:
Date of visit: Date of previous visit:
Reason for visit:
Business representatives:
Auditor representatives:
Page 2 of 10 October 2010
REQUIREMENT – FOOD SAFETY PROGRAM (Std 3.2.1)
���� or ���� COMMENTS
1. Is there evidence that all food handling operations have been identified? (eg by use of process flow chart).
2. Is there evidence that these activities have been assessed for potential hazards? (Physical, Microbiological, Chemical)
3. Are control steps identified and documented for each identified food safety hazard?
4. Tick nominated Controls: List Critical Limits for controls
Receipt
Storage
Thawing
Preparation
Cooking
Cooling
Reheating
Service
Delivery (on site)
Transport
Are the controls appropriate for the products / processes?
5. In monitoring is it clear who, where, when and how procedures are implemented?
6. Is there an appropriate corrective action for each control? Are there records of validation?
7. Are records maintained for all corrective actions taken when control measures are not complied with?
8. Are all records easily accessible and identified?
9. Does the internal audit check that all records are present and review any deviations?
Page 3 of 10 October 2010
REQUIREMENT – FOOD SAFETY PROGRAM (Std 3.2.1)
���� or ���� COMMENTS
10. Does the internal audit provide verification that hazards are kept under control?
11. Does the business conduct a review at least annually to ensure the adequacy of the program?
12. Does the review highlight any deviations and indicate corrective actions?
REQUIREMENT – CONTROL (Std 3.2.1 and Std 3.2.2)
���� or ���� COMMENTS
RECEIVAL
13. Are staff conducting visual examination of foods on receipt?
14. Are staff monitoring and recording temperatures / condition of incoming Potentially Hazardous Food?
DRY STORAGE AND PACKAGING
15. Are foods protected from contamination and clearly identified?
16. Is the packaging material fit for intended use, protected from and not likely to cause contamination?
17. Are single use items protected from contamination?
COLD AND FROZEN STORAGE
18. Are foods protected from contamination and clearly identified? Examples - Are raw foods stored separate from RTE food? Is food adequately covered?
19. Are the temperatures of all cool room facilities including fridges and freezers, checked, recorded and under control?
Page 4 of 10 October 2010
REQUIREMENT – CONTROL (Std 3.2.1 and Std 3.2.2)
���� or ���� COMMENTS
THAWING
20. Does the business have a documented thawing procedure?
21. Depending on the procedure, is the control step documented and monitored?
PREPARATION
22. Raw / unprocessed foods separated from cooked / processed / RTE foods.
23. No potential for physical or chemical product contamination.
24. Are food contact surfaces, utensils, equipment and chopping boards properly cleaned and sanitised before use?
25. Is the time that PHF foods are out of temperature control monitored and / or controlled?
COOKING
26. Are foods thoroughly cooked? Example - by ensuring the core temperature reaches 75°C or greater.
27. Is the cooking procedure documented and recorded?
COOLING
28. Is the procedure used for cooling adequate?
29. Is the cooling procedure documented and recorded?
Page 5 of 10 October 2010
REQUIREMENT – CONTROL (Std 3.2.1 and Std 3.2.2)
���� or ���� COMMENTS
REHEATING
30. Are food handlers ensuring the internal temperature of food is 60°C or greater?
31. Is the reheating procedure documented and recorded?
SERVING
32. Is food kept covered and protected from contamination?
33. Is food for hot holding held at 60°C or greater ?
34. Is the serving procedure documented and recorded?
35. Is food served to the client within a defined and monitored time?
36. Are staff observing appropriate health and hygiene practices when serving and plating food?
DELIVERY
37. Is food protected from contamination?
38. Is food being transported under appropriate temperature control or delivered within a defined and monitored time?
Page 6 of 10 October 2010
REQUIREMENT – SUPPORT PROGRAMS (Std 3.2.2)
���� or ���� COMMENTS
SKILLS AND KNOWLEDGE
39. Do staff have adequate Skills & Knowledge?
40. Are records of staff skills & knowledge kept? (Food handler skills & knowledge register)
FOOD HANDLER HEALTH AND HYGIENE
41. Does the business have a policy for food handler hygiene? It must give adequate consideration to reduce the risk of food contamination. Example – hair covering, protective clothing, allowable jewellery.
42. Does visual observation confirm compliance with hygiene policy?
43. Is there a policy for managing food borne illness in staff?
44. Hand washing stations adjacent to work areas?
45. Are all hand washing stations supplied with soap and suitable drying tools?
46. Is there evidence of frequent hand washing?
SUPPLIERS
47. Is there a policy on purchasing and donations?
48. Is there a specific policy on high risk Listeria foods?
49. Is a list kept of suppliers? Does it detail approval criteria?
Page 7 of 10 October 2010
REQUIREMENT – SUPPORT PROGRAMS (Std 3.2.2)
���� or ���� COMMENTS
RECALL
50. Is there a documented food recall plan if required?
51. Is there a procedure in place to deal with recalls from suppliers?
52. Does the business have a documented procedure to ensure that food for disposal is labelled and kept separate?
CLEANING & SANITATION
53. Are premises & fittings clean?
54. Are food contact surfaces clean and sanitary?
55. Are all equipment and utensils used in a clean and sanitary condition prior to use and stored to prevent contamination?
56. Are there documented cleaning & sanitising procedures / schedules / records.
57. Are cleaning chemicals stored well separated from food?
58. If used, what is the final rinse temperature of dishwashers? Is this checked and recorded?
TEMPERATURE & CALIBRATION
59. Does the business have a temperature measuring device that is readily accessible and can accurately measure the temperature of PHF to +/- 1°C?
60. Are there recorded checks on calibration and accuracy of all monitoring devices e.g. • Thermometers / Probes • Cool rooms • Dishwashers?
Page 8 of 10 October 2010
REQUIREMENT – SUPPORT PROGRAMS (Std 3.2.2)
���� or ���� COMMENTS
PEST CONTROL
61. Is there an effective and recorded pest control program?
62. No visual evidence of pests?
63. Are all practicable measures being taken to prevent pests entering the premises?
WASTE DISPOSAL
64. Internal rubbish placed in plastic lined bins and emptied frequently? If unlined, are bins part of cleaning schedule?
65. Is there a separate waste disposal area and is it kept clean?
MAINTENANCE
66. Does the business have a system to maintain the food premises, fixtures, fittings and equipment in a good state of repair and working order?
REQUIREMENT – PREMISES (Std 3.2.3 ref) ���� or ���� COMMENTS
67. Floors – are they sealed, non-absorbent surfaces, able to be easily and effectively cleaned and in good repair?
68. Walls – are they sealed, non-absorbent surfaces, able to be easily and effectively cleaned and in good repair?
69. Ceilings – are they appropriate for the area, sealed, non-absorbent surfaces, able to be easily and effectively cleaned and in good repair?
70. Fixtures, Fittings and Equipment? Are they in good repair, able to be easily and effectively cleaned and not likely to contaminate food?
71. Is there sufficient lighting for the activities conducted?
72. Is there sufficient ventilation?
Page 9 of 10 October 2010
REQUIREMENT – PREMISES (Std 3.2.3 ref) ���� or ���� COMMENTS
73. Are there windows in production areas? If so, do they open and do they have screens?
74. Does the business have an adequate supply of potable water?
75. Does the business have an effective sewage and waste water disposal system?
76. Are external openings adequately sealed to prevent entry of pests? (Air curtains / screens / insectocutors)?
77. Is there adequate drainage of floors?
78. Are adequate storage facilities available for chemicals, clothing and personal effects?
79. Are adequate toilet facilities available for food handlers?
80. Is the space and layout of food preparation and storage areas adequate?
REQUIREMENT - ADDITIONAL ���� or ���� COMMENTS
Page 1 of 2 October 2010
Food Safety Audit Report Food Act 2001.
Entry & Exit meeting attendance (business representative & auditor to sign) Date:
Name (print) Position Entry initial Exit initial
AUDIT SCOPE
REQUIREMENTS ���� or ���� Comments
Food safety program Hazard identification Documented controls Monitoring & records
Controls Receival Dry storage & packaging Cold and frozen storage Thawing Preparation Cooking Cooling Reheating Serving Delivery
Support programs Skills & Knowledge Food handler health & hygiene Suppliers Recall Cleaning & sanitation Temperature & calibration Pest control Waste disposal Maintenance
Premise s Building Equipment
Additional
Start time: End time:
Non-conformances Critical – Major – Minor –
Frequency & date for next audit 3 months – 6 months – 12 months –
Business contact’s signature: Date:
Auditors signature: Date:
Business Name:
Manager / Key Contact Person:
Premises address:
Council Area:
Business phone:
Type of audit (first / scheduled / follow up):
Page 2 of 2 October 2010
Food Safety Audit Report Food Act 2001.
Areas of non-conformance and corrective action
Business name:
Reference: (standard, audit checklist or food safety program)
Food process: (e.g. Receival, Storage, Preparation, Cooking, Support Programs, Training, Food Recall and Records)
Type of non- compliance: (critical, major or minor)
Areas of non-conformance: (non-compliance or inadequacy) Stating reasons
Agreed date for corrective action:
Company’s proposed corrective action:
Evidence of closure: (Auditor to date & sign when evidence of corrective action has been supplied or sighted)
Business contact’s signature: Date:
Auditors signature: Date:
Attachment 7: Guidelines for Auditors
Auditor Approval Process
Food Business Audit Process
Food Safety Audit Process
Applicant applies for
NFSA level 4 certification
from RABQSA through
Department of Health.
Food safety program is
developed and implemented
by food business.
Council notifies business of
requirement for mandatory
food safety program based
on Department of Health
Priority Classification.
Department of Health
facilitates Skill Examination.
Food business contacts
approved auditor and audit
is conducted according
to the set audit frequency.
Critical
Non-conformance
Identified
No Critical
Non-conformances
Identified
Once certified the applicant
applies to the Minister
of Health for approval
as a Food Safety Auditor
under Food Act 2001.
Applicant assessed against
set approval criteria. If
approved auditor is issued
with ID card as certificate
of approval.
Approved auditor may
audit food businesses
defined as requiring
regulatory food safety
programs (Standard 3.2.1).
Audit report provided to
the food business and copies
sent to enforcement agency
(council) and the Department
of Health within 21 days.
Auditor notifies
council within
24 hours
Auditor acts
as Authorised
Officer.
Council environmental health
officer should attend the
premises and ensure action
is taken within 24 hours
of notification to ensure
the risk to health is removed.
The auditor will re-audit
premises on council
notification that the risk
to health has been removed.
Enforcement agency reviews
and assesses audit outcomes.
Department of Health
conducts verification activities
to monitor competency
& conduct of auditors.
Audit System Management Department of health
Environmental health
officers may conduct follow
up inspections as result
of complaints or major
non conformances.
Department of Health acts on
misconduct or incompetence
by auditors, disputes,
complaints and appeals
within the audit system. Review and continual
improvement of the
audit system.
No problem
identified
September 2008