Certification Bodies (CBs) are required to train and regularly refresh auditors on the limits of the role of a consultant during CanadaGAP audits. Auditors are to be reminded that a consultant cannot serve the role of ‘person responsible’ for activities within the operation, since the consultant is not on site at the operation on a daily basis. As such, while a consultant may attend the audit as an observer, the consultant is not to be considered the ‘auditee’ and cannot be delegated by the operation to answer the auditor’s questions on behalf of the auditee or to explain the food safety management system in place. Rather, employees who are responsible on a day-to-day basis to carry out the functions associated with food production within the operation and for implementing the food safety procedures are to be considered the auditee(s).
The consultant may also help the auditee(s) implement the program, set up the Forms and ensure the requirements have been completed. The auditee(s) are then responsible to maintain their program on a daily basis and continue to fulfill the requirements and prove their understanding, involvement and responsibility during the audit.
Depending on the activity involved, the ‘person responsible’, as defined in the Glossary of the CanadaGAP Food Safety Manuals, is ‘The one(s) who carries out an activity (e.g., harvesting, packing, storage, cooling, icing, labelling/coding, transporting, etc.) and ensures that the activity within his or her control is complete’. By default, the owner is considered the ‘person responsible’ for the operation. However, in many operations, there will be someone else responsible for the management of the food safety program and this person would then be considered the ‘person responsible’. Obviously, there will be many activities/tasks that this person will delegate further, since they can’t do everything themselves. However, they are still the person responsible and therefore are still expected to oversee everything and ensure food safety is being managed. A consultant who is present at an operation only one day a week would not be able to fulfill this obligation. The consultant could sit in during an audit and provide support when needed, but since they do not oversee the daily food safety procedures should not be answering the questions. Each operation needs to have someone overseeing the food safety requirements, and that person should be answering the auditor’s questions.