General Corrective Actions
|
Options B, C and D |
Options E and F |
Options A1, A2 | |
|---|---|---|---|
| 1. What is the passing score? | 100% | 95% | 85% |
| 2. What happens if an operation does not achieve the passing score? | The operation needs to complete corrective actions or a corrective actions plan to achieve certification. | The operation needs to complete corrective actions or a corrective actions plan to achieve certification. | The operation needs to complete corrective actions to achieve certification. |
|
3. Can an operation use a corrective actions plan? When can an operation use a corrective actions plan? |
Yes Depending on the nature of the corrective actions, it may not be possible for an operation to address them until the subsequent year/season. In such cases, to achieve the audit score of 100% needed to be certified in the current year, the operation may submit a corrective action plan for approval by the Certification Body. NOTE: Autofails cannot be corrected through a corrective actions plan |
Yes
Depending on the nature of the corrective actions, it may not be possible for an operation to address them until the subsequent year/season. In such cases, to achieve the audit passing score of 95% needed to be certified in the current year, the operation may submit a corrective action plan for approval by the Certification Body. NOTE: Autofails cannot be corrected through a corrective actions plan |
No, corrective actions must be taken. |
|
4. How does an operation choose which items to correct from their audit? |
All items on the audit checklist that receive less than full points must be addressed. | Autofail items need to be addressed first. All autofail items must be corrected. Otherwise, (or as needed in addition to correcting autofails), operations should refer to their audit report for auditor comments (i.e., Executive Summary page and sections where they lost marks). | Autofail items need to be addressed first. All autofail items must be corrected. Otherwise, (or as needed in addition to correcting autofails), operations should refer to their audit report for auditor comments (i.e., Executive Summary page and sections where they lost marks). |
| 5. What happens if an operation cannot take corrective actions until next season? | To be certified in the current season, the operation would need to submit a corrective actions plan for approval by the Certification Body. | If necessary to obtain a passing score and be certified in the current season, the operation would need to submit a corrective actions plan for approval by the Certification Body. | It might not always be possible to take corrective action after the audit. It might be too late or it might be necessary to wait until the following season (for example, if the season is already over). In this case, the operation would need to wait until the next season to achieve certification. |
|
6. What tool should an operation use to record corrective actions taken or the corrective actions plan? How does an operation complete the Corrective Actions Report? |
The Corrective Actions Report (CAR)
Carefully read the instructions on the CAR |
The Corrective Actions Report (CAR)
Carefully read the instructions on the CAR |
The Corrective Actions Report (CAR)
Carefully read the instructions on the CAR |
| 7. Who decides whether the corrective action(s) or plan(s) are acceptable? | The Certification Body | The Certification Body | The Certification Body |
The score to pass the audit will depend on your certification option. Generally, if you fail the audit, you will still have an opportunity to achieve certification through the corrective action process.
- For Options B, C, and D: You must comply 100% with the CanadaGAP audit checklist to pass the audit. Items that receive less than full points must be addressed through corrective actions, or if corrective actions are not possible in the current year, you must submit a corrective actions plan for approval by the Certification Body.
- For Options E and F: A score of 95% with no autofail items is required to pass the audit. You must always correct all autofail items first. Those scoring below 95% must implement corrective actions to obtain a passing score of 95%. If corrective actions are not possible in the current year, you must submit a corrective actions plan for approval by the Certification Body.
- For Options A1 and A2: A score of 85% with no autofail items is required to pass the audit. You must always correct all autofail items first. Those scoring below 85% must implement corrective actions to obtain a passing score of 85%.
Though there are some cases where it is acceptable to make minor corrections and improvements to the operation’s food safety system during the audit, generally it is not the case. If the situation involves any of the automatic failure items, the auditee is NOT allowed to address the corrective action immediately. These situations usually have a high food safety risk and need to be treated accordingly to mitigate the risk. An audit is a ‘snapshot in time’ of what a particular auditor saw on a particular day, and the score needs to reflect that. Operations can and should be continuously improving their food safety programs. Food safety issues should always be addressed when they are noted, regardless of whether that is during an audit or not. However, most issues require more follow-up (i.e., verification of the preventive or corrective measures, including effective re-training, etc.) to ensure the issue has truly been addressed.
Example #1: During the audit, both the auditor and the person responsible notice mouse droppings on a table that will shortly be used for packing product. The person responsible removes the droppings, covers the table with a clean rubber mat, trains the employee to inspect the table and clean it before use, and records all information on Forms R and K. This would be an autofail. The person responsible did what is necessary to mitigate the risk at that time; however, this is a significant issue, and more investigation is required to ensure the root cause of the hazard is properly and consistently addressed.
Example #2: During the audit, both the auditor and the person responsible notice one stall in a multi-stall washroom has no toilet paper. The person responsible replaces the roll using a nearby stock of replacement toilet paper. This may be corrected at the time of audit with no points lost, provided that the auditor determines during their risk assessment (e.g., supplies are in nearby closet, other stalls have toilet paper, employees say washrooms are usually stocked, etc.) why this situation occurred. If there are no controls in place, then the auditor would note the issue on the audit checklist and remove points even though the person responsible replaced the roll of toilet paper.
Example #3: During the audit, employees are observed using an option #3 handwashing station in the incorrect order – hand sanitizer followed by hand wipes. The person responsible stops activities, gathers all employees, re-trains on the correct order of use (hand wipes followed by hand sanitizer) and records this training on Form K. This would be an autofail. The audit is not the best time to be re-training employees. Perhaps not all employees are on-site that day, there could be language barriers, as well as employees made nervous by the presence of the auditor and not able to focus on the information. The person responsible also needs time to observe, verify and reinforce the training.
Here are some examples of issues that would require the operation to wait until the next season to be certified:
- If agricultural chemicals not registered for use in Canada were sprayed on crops during the course of the season and therefore caused product contamination.
- If untreated sewage water or biosolids were used on crops throughout the season.
- If personal hygiene facilities were not provided for employees and the harvest season was completed.
In all cases, corrective actions implemented by the operation are subject to review by the Certification Body. The Certification Body will decide which are acceptable, based on evidence and clarification from the operation which shows they have sufficiently completed the corrective action.
The operation is responsible for implementing corrective actions to the best of their ability, within the timeframe required by the program or indicated by their customer if the customer has a shorter timeframe [e.g., immediately (one week), one month, etc.]. Under program rules, participants are given a maximum of 60 days from receipt of the audit report or the end of the season (whichever is sooner) to complete corrective actions. Those who have not implemented corrective actions by the deadline will either not be certified, or will have certification withdrawn, and will need another audit.
It depends on the situation and the issue being corrected. The Certification Body may accept:
- Documentary evidence (e.g., missing records)
- Photographic evidence
Important Note: there may be situations where demonstrations of the corrective action can only be confirmed by a further site visit. The decision about a return visit is at the discretion of the Certification Body and depends on the audit results and the corrective actions required. If in doubt, operations should consult their Certification Body or auditor about the type of evidence that will be acceptable for their situation.
If the Certification Body decides that the demonstration of the corrective action/corrective action plan can only be confirmed by a future site visit, they will coordinate that with the operation. When this is required, the operation is responsible for costs (i.e., auditor time and travel). Please note that operations will not become certified until the corrective actions/corrective action plans can be completed. If the Certification Body has to come back for a site visit and the season is over, they will have to schedule for the next season, and certification will not be possible until that time. Operations should take this into consideration when they are scheduling their audit, particularly when they are starting out on the program and are uncertain whether their operation meets the standard.
Regardless of whether an on-site visit is required, the operation is responsible to pay the Certification Body fees for follow-up on corrective actions/corrective action plans. Charges also apply to desk review of evidence (documents, photographs, etc.) even when a return visit to the site is unnecessary. Operations should check the rates in their contract with the Certification Body.
Corrective Action Requests (CARs) must be closed out within 60 days of receiving the audit report. This 60-day closeout period includes the time the Certification Body/Auditor needs to review the corrective actions and/or the corrective actions plan.
If an operation is unsuccessful in implementing corrective actions within the allotted timeframe:
For Options A1 and A2:
If operations are unsuccessful in implementing corrective actions to pass the audit:
- If there is time left in the season, the operation can undertake another audit to achieve certification.
- In exceptional cases, they can discuss with their certification body whether an extension to the CAR closeout timeframe is possible (e.g., if major capital improvements are needed). Any such extensions are at the discretion of the certification body.
- They can maintain their enrolment and have their annual program fee applied to next season, when they will re-attempt certification. The CanadaGAP office must be informed in writing of their plans to ensure that the annual program fee is properly applied.
- They can withdraw officially from the program, and if desired, enrol again the next year and re-attempt certification. CanadaGAP must be informed in writing so that the annual program fee for the current year can be refunded, minus an administrative charge of $100, or applied as a credit against a future year. The audit fees (auditor’s time and travel) for the failed audit are not refundable.
For Options C, D, E and F:
As an alternative to one of the actions listed above, if operations are unable to implement corrective actions to pass the audit before the end of their season/year:
- They may be able to develop a corrective actions plan and submit it to the certification body within the 60-day timeframe to close out the CARs. The certification body must approve the corrective actions plan. At the next audit the auditor will confirm that the plan was implemented and the approved corrective actions were taken.
Self-assessment Corrective Actions
For Option A1 and A2 program participants, the certification body’s review of their completed self-assessment could trigger further activities: either requests for corrective actions, or a triggered audit. In both cases, the fees charged by the certification body for the follow-up on corrective actions and the triggered audit are borne by the operation. If an operation is responding to requests for corrective actions from their certification body, they should use the Corrective Actions Report and include information on the action taken to correct the issue, any supporting evidence (if needed) and date of implementation.
Yes. The operation should use the Corrective Actions Report. They can record corrective action(s) taken to increase their audit score. In this case, corrective actions are subject to review by Certification Body in the same way as corrective actions taken after a failed audit. After receiving their audit report, they have 60 days or until the end of the season (whichever is sooner) to seek adjustments to the audit score through the corrective actions process.