When we conduct audits, we look for gaps in adherence to food safety programs and standards, which are known as ‘non-conformance’ areas.
Pleasingly, we’ve noted a distinct reduction in non-conformance rates per audit in 2019 compared with the same period in 2018:
- Minor non-conformances identified per audit in 2019 are 1.94/audit compared to 4.38/audit in 2018.
- Major non-conformances have dropped from 1.08/audit in 2018 to 0.15/audit in 2019.
- And it’s pleasing to see no critical non-conformances have been identified over the 2018-2019 period.
All major non-conformances raised in 2018 and 2019 audits have either been corrected or are in-hand.
But what are non-conformances, how are they identified and what are the trends in non-conformance?
Non-conformances can be rated as critical, major or minor. In addition, in some instances, your auditor may bring to your attention an ‘observation’, which is an opportunity for improvement in how you’re producing product or managing your food safety program. In this situation, the non-conformance isn’t presenting a risk to food safety.
Non-conformances are defined and have mandatory completion timeframes, which are:
- Minor Non-conformance: Low risk situation. ‘A non-conformance with the approved food safety arrangement where the potential impact of the non-conformance is not likely to compromise food safety.’ A minor non-conformance must be corrected prior to the next scheduled audit.
- Major Non-conformance: Medium risk situation. ‘A non-conformance with the approved food safety arrangement where the potential impact of the non-conformance is likely to compromise food safety and suitability if no remedial action is taken to correct the non-conformance within a specified period.’ A major non-conformance must be corrected within 30 days and is subject to follow-up audit.
- Critical Non-conformance: High risk situation. ‘A high risk non-conformance with the approved food safety arrangement where the potential impact of the non-conformance is of substantial and/or immediate significance to food safety and suitability warranting immediate corrective action.’
The need for Dairysafe to initiate compliance action may arise from reports of non-compliance with standards, the production of unsafe or unsuitable food, and foodborne illness investigations.
As with all Australian food safety regulators, Dairysafe applies a graduated response to drive compliance. Dairysafe uses a range of compliance options to encourage compliance with food safety standards without placing undue cost on industry.
Dairysafe will follow up the correction of major Corrective Action Requests (CARs) at or after the standard 30-day timeframe provided to correct the non-compliance. As has previously been the case, an additional charge of $100 per hour will apply for follow-up visits.
The types of issues identified and trending as non-conformances over the past 12 months have been:
- Milk cooling rate
- Milking equipment maintenance
- Vendor declarations
- Chemical management
- Milk temperature monitoring
- Product testing and results
- Internal audits
- Listeria monitoring
- Potable water test
- Recall arrangements
- Receival temperature/records
- CIP procedures
We congratulate the South Australian diary industry on your work to reduce non-conformance items, and we encourage you to talk to us about ways to improve your businesses further.