FSMS auditing

FSMS audits that find it before the auditor does

An FSMS audit tests whether a food safety management system works the way it is written, using records the site did not choose. ASC audits against FSSC 22000, ISO 22000:2018, BRCGS Food Safety, GLOBALG.A.P. IFA, HACCP and GMP, SIZA, IFS Food and SQF, as your internal auditor, as a pre certification auditor, or both. ASC is not a certification body.

Auditing is charged hourly and a full programme is quoted on scope once ASC has seen the site. ASC will tell you before the quote if the work is smaller than you think.

Three daysOn site for a BRCGS internal audit
Last dayFindings presented to management at the closing meeting
Two weeksFull written report after the closing meeting
SAATCA, Exemplar Global, IRCA registered lead auditorsFoodBev SETA Accredited Provider No. 587/00337/1900Gqeberha, Johannesburg, Cape Town and Durban
Talk to ASC, or start with the documentsWhatsApp ASCRequest a quoteFSMS toolkits
Audited to ISO 19011Findings rest on evidence rather than opinion, written so a certification body auditor could read the report cold and follow it.
Led by a working lead auditorThe person auditing your site is a lead auditor registered with SAATCA, Exemplar Global and IRCA who audits to these standards for a living, so a finding is graded at the severity its consequence justifies.
You are told the truth about the dateWhere a customer deadline is not achievable, ASC says so before the quote rather than after the audit.

An FSMS audit tests whether a food safety management system does in practice what its documents say. A document review tells you the paperwork is complete. An audit goes looking for the records that system should have produced on a Tuesday night shift three months ago, asks the operator who owns a control to explain it, and follows a finished batch back through every check it passed.

For most South African manufacturers and packhouses, certification is a trading condition: a retailer listing, an export buyer or a tender specification names the standard, and the site holds the certificate or loses the business. A major nonconformance pulls production into writing responses and can push the certificate past the date the customer was promised.

ASC does three things here, and this page is the hub for them. We run the internal audit your standard requires, as an independent party, where nobody is trained for it or the trained person would audit their own work. We run pre certification and readiness audits the way a third party auditor runs them, so you learn what the certification body will find while there is time to act. And we get you ready, closing the gap with corrective action worked to root cause and evidence in the form the auditor will ask for it.

What a real audit does that a walk round does not

Much of what is sold as auditing is a guided walk with a checklist. The site knows the date, prepares a file, walks the auditor down a clean line, and hands over the records it selected. The output is a list of observations against clause numbers, usually ungraded.

Auditing the evidence a site chose tests the filing rather than the system, because the records that were never completed are the ones that do not come out of the cupboard. Ungraded findings compound that, because a list of observations does not tell a quality manager which of them would have been majors.

ASC audits differently. Record dates come off the production plan and the despatch register, not the file prepared for the visit, so the sample belongs to the auditor. Operators are asked to explain the controls they own, because a control only the quality manager can describe is not implemented. Evidence retrieval is timed, because a record that cannot be produced while the auditor waits will be treated as one that does not exist. ISO 19011 devotes a full clause to auditor competence, and ASC audits are led by a lead auditor registered with SAATCA, Exemplar Global and IRCA who says which findings are firm and which are borderline.

Key facts at a glance

ASC Food Safety Consultants conducts internal audits, pre certification readiness audits and second party supplier audits against FSSC 22000, ISO 22000:2018, BRCGS Food Safety, GLOBALG.A.P. IFA, SIZA, HACCP and GMP, and can also audit against IFS Food and SQF.
ASC audits follow ISO 19011, the international guidelines for auditing management systems, whose audit principles include integrity, fair presentation, due professional care, confidentiality, independence, an evidence based approach and a risk based approach.
An ASC internal audit on site runs two days against ISO 22000:2018, two and a half to three days against FSSC 22000 depending on site size, three days against BRCGS and one day against GLOBALG.A.P.
A customer or second party audit conducted by ASC runs one day on site, and a GMP audit is generally one day on site with the report turned around in a week.
ASC presents audit findings to management on the last day of the audit and issues the full written report within two weeks of the closing meeting.
ASC supplier audits run on an annual cycle, with the written report issued within two weeks of the audit.
ASC Food Safety Consultants is not a certification body, and the certification decision belongs to an accredited certification body after its own third party audit.
ASC is SAATCA registered and a FoodBev SETA Accredited Provider No. 587/00337/1900, and ASC Consultants SA is a member of the Sustainability Initiative of South Africa, membership number 20240910 112270.

When a business calls ASC in

  • You are certifying for the first time and want to know what the auditor will find.
  • Your standard requires an internal audit programme and the person able to run it wrote the procedures.
  • A certification audit is booked and you doubt the records can be produced in the time an auditor allows.
  • Nonconformances you closed after the last audit have come back, which points at the corrective action system.
  • A customer or retailer requires a second party audit of your site or a supplier.
  • You are changing standards, or adding a site, a shift or a product stream the system was never written for.

How ASC does the work

1

Internal audits, run by someone with no stake in the result

Every management system standard requires the site to audit itself against the whole of the standard on a planned programme, by auditors competent and independent of the activity audited. In a small technical team that collides with reality, because the person who understands the standard wrote the procedures and signs the verification records.

ASC runs the audit as the independent party, with the duration for each standard set out in the questions below. Findings go to management at a closing meeting on the last day, and the full written report follows within two weeks. A programme that has raised nothing but observations since the last certification audit tells the next auditor more about the programme than the site. This is covered in depth on the internal food safety audits page.

2

Pre certification and readiness audits

A readiness audit is a rehearsal conducted under audit conditions. Records are sampled at random from dates ASC selects, a batch is followed from receiving to despatch, operators are asked to explain the controls they own, and evidence retrieval is timed against the patience an auditor has.

The output is a readiness picture rather than a pass mark, with findings ranked so that anything likely to become a major nonconformance is dealt with first. Where the system will not hold under audit conditions we say so, and the site can decide whether to move the booked date rather than pay to be told the same thing by the certification body.

3

Getting you ready: from finding to verified closure

A response that reads retrained the operator closes almost nothing, because it locates the cause in a person, not in the system that allowed the failure. If the same finding could happen next month with a different operator, the root cause has not been found: the real question is why the form permitted a week of signatures in one sitting, and why verification never compared it against the production plan.

ASC works each finding through four recorded steps: the correction that deals with the product or record, the root cause established by investigation, the corrective action that stops the cause recurring, and the verification weeks later that checks whether it worked. Only the last closes anything, and closure follows evidence: a promise to update a document closes nothing until it is on file, issued under document control and verified in use.

Severity is a mechanism rather than a table. A minor is a single lapse in a control that otherwise exists and is generally followed. A major is a failure of the control itself, where the procedure does not exist, or nobody follows it, or the site cannot demonstrate that a hazard was controlled, or a legal requirement or critical control point is touched, and a cluster of minors against one clause is often graded upwards. The internal audit programme, the corrective action process and management review are what certification bodies most often find lapsed, and ASC rebuilds those three first.

4

The systems ASC audits against

ASC audits against the systems South African food businesses are actually asked to hold, and each has its own page here explaining how ASC implements it: FSSC 22000, ISO 22000:2018, BRCGS, GLOBALG.A.P., HACCP and GMP and SIZA. ASC can also audit against IFS Food and SQF where a customer specifies them.

The differences change how an audit is run, not how rigorous it is. ISO 22000:2018 asks whether the organisation planned, operated, verified and improved, so the audit spends real time on objectives, verification and management review. FSSC 22000 adds the prerequisite programme specifications and its own additional requirements. BRCGS is prescriptive and weighted towards the factory environment, product control and record discipline, which an auditor who has not worked a factory floor misses. GLOBALG.A.P. IFA is audited against control points and compliance criteria on the farm and in the packhouse, with producer groups carrying internal inspections on top of the producer self assessment. SIZA rests on contracts, wage records, working hours, housing and worker interviews.

5

Scope, the audit trail, and the limits of a remote session

Scope is set first and set honestly: which standard and sections, which sites, shifts and product streams, and which processes are seasonal. Auditing one shift proves nothing about the other two, and practice drifts at night because supervision is thinner and the person doing the pre operational hygiene check wants to go home.

The audit trail is what separates a real audit from a document review. Take a finished batch chosen from the despatch records, not one offered by the site, and work backwards through the release decision, the foreign body control records, the process records at each control point, the raw material lot numbers and the supplier approval file. Then work forwards into complaints, traceability and mass balance.

Remote sessions have a place, and ASC applies the approach IAF MD 4 sets for accredited certification bodies on the use of information and communication technology in audits, treating them as a planned technique rather than a substitute for being there. A screen verifies document control, training files, calibration, management review minutes and a live traceability exercise. It cannot verify dust on an overhead beam, condensation above open product, a perished door seal or pest evidence in a void, so ASC keeps the plant and the observation of practice on site.

How ASC helps, in practice

The following are illustrative composites of the kind of work ASC does. They name no client and report no measured outcome.

An internal audit that opened a record the site had already signed off

A ready meals manufacturer had its internal audit programme run by the technical manager who wrote the system, which the standard would not accept. Metal detection challenge records were signed and verified for the whole quarter.

ASC picked three dates from the production plan rather than the file and compared those records against what the line had run. On one date the line had been down for maintenance, yet the record showed hourly test piece checks completed: the form was filled in weekly from memory.

The finding was written as a systemic failure of a control point record, not operator error. The form was redesigned to be signed per check with the batch code at the time, and verification became a comparison against the production plan.

A pre certification audit that moved the audit date

A snack manufacturer preparing for its first BRCGS certification had an audit date driven by a retailer deadline and a documented system that looked complete, so ASC ran a three day readiness audit under audit conditions.

The internal audit programme had covered the factory sections but not the management system clauses, so parts of the standard had never been audited internally. Management review minutes recorded no review of verification results or complaint trends, and corrective actions were closed without effectiveness checks.

The site moved the certification date, ran a full internal audit cycle across the standard, held a management review with the required inputs and closed the outstanding actions with verified effectiveness.

A readiness programme that closed an allergen gap

A bakery ran a milk free product on the same equipment as a milk containing one, with an allergen policy, a changeover procedure and a visual sign off, but no validation that the cleaning method removed the allergen.

ASC audited a changeover live rather than reading the procedure, and found the written sequence and the one the team worked to had diverged, with two dismantling steps skipped because a fitting had been replaced. The cleaning method was validated with analytical testing at the worst case points, and the instruction rewritten around the plant as it stands.

The site moved from an allergen control it could assert to one it could evidence: a validation report, a work instruction that matches the equipment, training records and a verification schedule. ASC re audited the changeover on night shift.

What you receive

Deliverable What it contains
Audit plan and confirmed scope The standard and sections in scope, the sites, shifts and product streams to be sampled, and the trail to be worked.
Closing meeting and findings presentation Findings presented to management on the last day, each against its clause with the evidence seen, plus corrections agreed there.
Full written audit report Issued within two weeks of the closing meeting, written to be read cold by a certification body auditor: clause, evidence, date, location, expectation against finding.
Findings register and corrective action plan Every finding with its correction, root cause, corrective action, owner, due date and the evidence that closes it.
Readiness picture for pre certification audits What would be raised if the certification body arrived today, ranked by severity, and what to close before the booked date.
Internal audit programme and auditor records An annual programme covering the full standard across shifts and seasons, with auditor independence and competence recorded.

The rest of the ASC audit programme

FSMS auditing sits alongside the other audits ASC runs, and alongside the implementation work that closes what an audit finds.

Who this work suits

ASC audits across the sectors that feed South Africa and its export markets: citrus, table grape and deciduous fruit packhouses, dairy processing, red meat and poultry abattoirs, fish and squid processing on the Eastern Cape coast, bakeries, snack and ready meal manufacturing, beverages, spice blending and wine cellars. Teams work from Gqeberha, formerly Port Elizabeth, in Nelson Mandela Bay in the Eastern Cape, and from Johannesburg and Cape Town, with on site teams in Durban and across the country. ASC audits are led by lead auditors registered with SAATCA, Exemplar Global and IRCA.

South African law sits underneath those audits. The Foodstuffs, Cosmetics and Disinfectants Act 54 of 1972 is the governing statute, the general hygiene requirements in R638 of 22 June 2018, published in Government Gazette 41730, require food premises to hold a certificate of acceptability from the local authority, and R146 of 1 March 2010 governs labelling and advertising. ASC is SAATCA registered and a FoodBev SETA Accredited Provider No. 587/00337/1900, and ASC Consultants SA is a member of the Sustainability Initiative of South Africa, membership number 20240910 112270.

Where ASC stops

ASC Food Safety Consultants is not a certification body and never certifies a management system. No audit ASC performs results in a certificate against FSSC 22000, ISO 22000:2018, BRCGS, GLOBALG.A.P., IFS Food, SQF or SIZA, because that decision belongs to an accredited certification body after its own third party audit.

ASC is not a SIZA approved audit body and not a SMETA approved audit company. Where SIZA is named on this page, the ASC role is the preparatory audit or the second party audit only, and an ASC report carries no standing with SIZA, Sedex or a retailer scheme. ASC Consultants SA is a member of the Sustainability Initiative of South Africa, membership number 20240910 112270, which is membership of the programme and nothing more.

What ASC provides is the internal audit your standard requires, an independent readiness assessment run to the discipline a certification auditor applies, and the work of closing findings before that auditor arrives. Where a finding is borderline, ASC says so rather than promising an outcome that is not ASC’s to give.

The standards ASC audits against

Each of these is audited by someone who implements it as well, so the finding comes with the route to closing it. Follow the link under any standard for how ASC builds and beds down that system.

FSSC 22000 audits

Two and a half to three days on site, by site size

ASC audits the full FSSC 22000 scheme: the ISO 22000 management system, the sector prerequisite standard that applies to your category, and the additional scheme requirements, including food defence, food fraud, allergen management, environmental monitoring and the quality culture requirement. Run as your internal audit, or as a pre certification rehearsal under audit conditions.

FSSC 22000 implementation →

BRCGS audits

Three days on site

ASC audits against BRCGS Food Safety and BRCGS Packaging Materials, including the fundamental clauses that carry a certificate on their own, the site standards and product control sections, and the traceability and mass balance exercise that BRCGS auditors time against the clock. Findings are graded the way a BRCGS auditor grades them, so nothing is a surprise on the day.

BRCGS implementation →

ISO 22000:2018 audits

Two days on site

ASC audits the clause structure the way an ISO auditor reads it: context and interested parties, the hazard analysis and its validation, operational planning and control, the PRP and OPRP logic, monitoring and verification, and management review. This is the internal audit the standard itself requires.

ISO 22000 implementation →

GLOBALG.A.P. audits

One day on site

ASC audits GLOBALG.A.P. IFA on farm and in the pack house, covering the control points and compliance criteria, record keeping through the season, plant protection product use and intervals, water and hygiene, and the worker welfare add on where your buyer asks for it.

GLOBALG.A.P. implementation →

HACCP and GMP audits

One day on site, report in a week

ASC audits the HACCP study itself, the hazard analysis, the CCP decisions, the critical limits and the validation behind them, together with the prerequisite programmes and the operating conditions that HACCP assumes are already in place. This is where most systems actually fail.

GMP audits →

SIZA and ethical readiness audits

One day on site, findings the same day

ASC runs the preparatory audit before a SIZA or a Sedex visit, against the programme criteria and against South African labour law. ASC is not a SIZA approved audit body and not a SMETA approved audit company, and the ASC report carries no standing on those platforms.

Ethical and social compliance audits →

Not sure which applies to you, or heading for certification for the first time? Start with a gap audit, or see internal food safety audits and second party audits.

Frequently asked questions

Can an outside consultant legitimately run our internal audit?

Yes. The standards require internal audits to be planned, to cover the full scope and to be done by competent auditors independent of the area audited. Nothing requires the auditor to be an employee, and many sites use an external one because independence is impossible in a small team.

Does a pre certification audit mean we will pass the certification audit?

No. A provider who promises that is selling something they cannot deliver. A readiness audit tells you what a competent auditor found on the day, ranked by likely severity. The certification decision belongs to an accredited certification body.

How long does an audit take and what does it cost?

On site, an internal audit runs two days against ISO 22000:2018, two and a half to three days against FSSC 22000 by site size, three days against BRCGS, and one day against GLOBALG.A.P. A customer or second party audit and a GMP audit are generally one day. Consulting and auditing are charged hourly, and a full programme is quoted on scope once ASC has seen the site.

Can the same firm audit us and then help us fix what it found?

An accredited certification body may not do both, which is why its auditors will not tell you how to solve anything. ASC is a consultancy, so no rule prevents it, but the audit report and the corrective action work stay apart in the record.

Which standard should we be audited against?

Usually the customer decides, so read the specification or retailer requirement first. Where there is a choice, the factors are what your buyers recognise, how prescriptive a system you can sustain, and whether the scheme must be recognised by the Global Food Safety Initiative. Confirm the applicable version and any transition dates with your certification body.

How much of an audit can be done remotely?

The documented system audits well remotely: document control, records, training files, calibration, management review, supplier approval, complaints and a live traceability exercise, with interviews. The plant does not, because hygienic condition, drainage, seals and pest evidence need someone in the building.

Find out what the certification body will find, while you can still act on it

Tell ASC which standard you are audited against, how many sites and shifts are in scope and when your next audit is booked, and you will get an audit plan that fits. A scoping conversation costs nothing.

Not ready for a quote? Use Where Do I Start, or book a virtual consultation.

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