| 04/13/2017 9:10PM |
Yuksel Eyyuboglu |
2. Prerequisites
2.1. The CB shall be accredited for ISO 22000 by ANAB or another IAF management systems MLA signatory AB, or be accredited for any GFSI-recognized certification program (e.g., BRC, SQF).
COMMENTS: ISO 22000 is a system that requires HACCP program implementation which is the sole purpose of ISO22000 system implementation. Whereas GFMS is not HACCP-dependent; it is an independent program requires a risk assessment from a site to keep the gluten out of those products which carry the claim ‘Gluten-free’. It is not understood by this writer why ISO 22000 would be inserted to this standalone GFMS.
4.2. After the documents are found acceptable, ANAB shall conduct an office assessment and required witnessed audits.
COMMENTS: The witness audits are not quite qualified, besides they would possibly make the program very heavy (for an addendum to GFSI-scheme audits), especially if the auditors have already been witnessed regularly in the GFSI schemes they are auditing. The expertise required for Gluten-free program was completely covered by auditors’ GFSI-scheme expertise.
4.2.2. ANAB shall witness the CB conducting a two-stage audit process (stages 1 and 2).
COMMENTS: We find this also unnecessary for 1: GFMS scheme is not a two-stage audit process and 2: the GFMS audits are usually attached to a GFSI-recognised scheme audit.
4.2.2.2. Because of the level of expertise needed, ANAB may use technical experts for GFMS witnessed audits. ANAB will invoice the CB for the fees and expenses of the technical expert.
COMMENTS: As per our COMMENTS above, this is not relevant. Also for that the audits are usually combined with GFSI-recognized scheme audits because of the synergy in contents. The expertise for Gluten-free program was completely covered by auditors’ GFSI-scheme expertise.
5.1. ANAB shall conduct an annual office assessment and annually witness a CB team conducting a GFMS audit.
COMMENTS: There should be no need for annual witness, simply for the reason that the witness programs for BRC/SQF/FSSC/22000 are already in place and sufficiently rigorous. The GFMS is an addendum to them. This would be duplication and wasteful if the office assessments for all other schemes are already covered by another Accreditation Body. The GFMS is about the ‘management of keeping Gluten out of a site’ which syncs with the above GFSI scheme requirements; we do not see any further benefit of these requirements to the GFMS accreditation and program delivery.
5.1.1. When possible, the office assessment shall be conducted concurrently with assessments for other ANAB accreditation programs for which the CB is accredited.
COMMENTS: This would be duplication and very wasteful and would increase the cost of the Gluten-free program delivery if the office assessments for all other schemes are already covered by another Accreditation Body.
5.1.3. Because of the level of expertise needed, ANAB may use technical experts for GFMS witnessed audits. ANAB will invoice the CB for the fees and expenses of the technical expert.
COMMENTS: This item also completely disagrees with the reasons listed in the 5.1 above. Besides, the GFMS is about ‘management of keeping Gluten out of a site’; we do not see any relevance of these requirements to the program objectives.
6.1. ANAB shall conduct a document review and an on-site full system office assessment at approximately six months prior to the expiration of accreditation. COMMENTS: This also is not necessary for GFMS; as mentioned previously, GFMS is usually an addendum to other GFSI-scheme audits. Its contents are almost in full synergy with these scheme requirements; this practice too would be rather wasteful and duplicate. Our view is that the Accreditation Body audits this program as well at usual frequency. |
Comments from SAIG - April 13 2017.docx |