What is a ‘split audit’? Can operations choose to split their CanadaGAP audit?

A split audit occurs when the audit takes place over two or more on-site visits that are separated in time (e.g., a 0.5-hour visit to see harvesting on September 12 followed by a 3.5-hour on-site document review on November 14). On-site CanadaGAP audits must not be split into two or more separate visits separated in time except under highly unusual circumstances, and only when the Certification Body has received written authorization from CanadaGAP to split the audit. Permission must be sought in writing by the Certification Body, along with a clear description of the circumstances, and approval must be obtained from CanadaGAP in advance of the audit. Split audits are not permitted under the CanadaGAP program.

An example of a split audit is:

• an auditor observes harvesting of potatoes in October and returns in January to complete the document review.

In contrast, these examples would NOT be a split audit:

• an operation needs two audits their first year in order to have two crops on their certificate— one in May for asparagus and one in October for apples.
• an auditor is unable to see a new packing line on the day of an audit due to mechanical failure. The remainder of the audit is completed that day, but then the auditor returns to the operation two days later to complete the observation of the packing line.
• an auditor arrives at the audit and it’s raining; therefore, the harvesting of strawberries cannot be observed. The remainder of the audit is completed that day, but the auditor returns to the operation the week after to complete the observation of harvesting.
• the Certification Body has approved, in advance, a partially remote audit at a small, potato-only operation enrolled in certification option A1, where the producer/person responsible for the operation must operate the harvester on the day of the audit. The auditor completes part of the audit on-site, and the remaining portion of the audit remotely and in accordance with the requirements specified in CanadaGAP Technical Procedure TP-09-RM.

Except in very special circumstances, audits must occur when activities relevant to the operation’s certification are underway – during harvest, product handling, packing/repacking season, shipping, etc. This is important for the auditor to properly assess the implementation of the food safety program based on a snapshot of what is occurring at the operation on the day of the audit. When the operation wants to split an audit so that the auditor can rush through observing activities such as harvesting and then come back at much later date to review documents when the operation is less busy, that does not achieve the intent of an audit.

Some further reasons that audits cannot be split into two parts include:

• The tour portion of the audit may take the most amount of time for the auditor to complete; therefore, splitting the audit does not save the operation much time.
• The auditor cannot assess the implementation of the food safety program properly without cross-checking details to determine their accuracy, currency and validity. Having the audit take place on two separate dates, makes cross-referencing of information next to impossible.
• A two-part audit would entail substantial overlap for each visit. This means that the auditor would spend more time overall, thus increasing the total audit duration.
• If audits were to be split, it would create confusion for the auditors about which questions to score and at which audit, especially for non-conformities. This confusion would lead to inconsistency among audits and increased potential for disputes around audit findings and results.
• If there are non-conformances found at either of the visits, the CB and the operation may have difficulties with CAR completion, and in most cases corrective action cannot be taken after the season is over. Examples of possible situations include:
  • At the 1^st visit the auditor observes the agricultural chemical storage and records a few of the chemicals seen. During the 2^nd visit the auditor reviews Form H1 and notices that one of the agricultural chemicals observed at the 1^st visit was used on a crop that it is not registered for. An autofail would be issued, however harvested product would have already been shipped several weeks before.
  • At the 1^st visit handwashing facilities were observed to be fully stocked. During the 2^nd visit it is determined that Form J was not completed. Since there was no record for the handwashing facility to ensure it was fully stocked throughout the season, it is unclear if the handwashing facility was being properly maintained.
• Splitting audits introduces a further complication for certification bodies in managing the audit and certification process for all clients.

For more information, see Section 3.3.5.4 of the CanadaGAP Program Management Manual.