In my previous post, I sent you information on the new audit guidelines for Vulnerable Persons (VP) in NSW.
At the session, John Fallon from the New South Wales Food Authority (NSWFA) explained that there are only 22 approved external third party auditors in NSW.
He provided an enforcement update on all VP audits that have been conducted (by NSWFA employed auditors and external third party auditors).
He indicated that the top TWO problems encountered during audits were:
- Ineffective monitoring records
- Not complying with there food safety program
#1 Non Conformance: “Ineffective” Monitoring records
- Not having records in place
- Missing records or records not available
- Completed records not identifying issues (i.e. Temperatures recorded outside critical limits)
- No recorded corrective action when problems were identified
- Supervisor signing off on incomplete or incorrect records
It is stated in the VP Guidelines that IT IS a requirement for someone to check all completed records. Even though it is not a requirement for records to be signed, we certainly recommend this practice to our clients.
We have a client who purchased from a newsagent, an “APPROVED” stamp and the person doing the checking stamps the monitoring record and signs above where it was stamped. I think this is a simple and effective means of verifying your records. You still need to make sure that the person who does the “approving” actually checks that the record has been completed correctly.
#2 Non Conformance: “Not complying with their food safety program”
Remember a couple of days ago I told you that your program should:
“Say as you do” and you should “Do as you say”.
Consistent areas where Corrective Action Requests (CARs) were raised included:
- Labeling techniques used
- Content of an internal audit – The internal audit process did not include a review of their food safety program. (Note: The findings of the internal audit should reflect what is found at an external audit)
- Good manufacturing practices
- Allergen management
The NSWFA will continue to monitor ALL Vulnerable Persons facilities (including businesses with Third Party Auditor (TPA) approval) and the Proprietor of the facility is responsible for ensuring that an audit is organised.
All VP audits conducted in NSW are reported electronically to the NSWFA. Every month, the NSWFA runs a report on facilities that are overdue for an audit. The following process is applied:
- If overdue by 3 months they will be sent a “reminder letter”
- If overdue by 6 months they will be sent a “warning letter”
- Failure to comply will result in a $1320 penalty for corporations
and $660 for individuals.
All scheduled audits must be conducted within the allocated 6 or 12 month period.
Your license cannot be renewed if there are any outstanding audits that have not been conducted.