Hi Ignacio
I represent an Australian based Independent Certification Body (ECAAS) that
certifies organisations against numerous requirements, including: HACCP, ISO
22000, ISO 14001, ISO 9001, AS4801, MSC Sustainable Fishing and Chain of
Custody. A lot of our clients operate as part of the seafood industry
(wildcatch, ranching, aquaculture and processing) and are exporters of tuna
to the Japanese sashimi market and other fish and fish products to the EU.
While I can talk with authority about how we do (and are required to)
operate, I guess my comments must be taken with a grain of salt in relation
to your Inspector and the relevant authority for which he works.
Whether you are being reviewed by and auditor or inspector, the same
underlying principle applies, they can not make and adverse finding nor
require you to change your practices without being able to provide reference
to the criteria that they claim you fail to adequately satisfy. This
protocol is in place to avoid the situation whereby an auditor/inspector's
personal opinion is becomes an unofficially enforced requirement because
they think it is necessary as opposed to it actually being "recognised
criteria" that you must satisfy. (This happens a lot where the authority
fails to spend sufficient time on auditor/inspector review, debrief and
continuity.) In some cases, a few of our clients do have mandatory health
surveillance requirements (annual medical certificates), but they are
clearly outlined in the requirements to which they subscribe (industry,
association, state, federal, etc). Having said that, these requirements
relate to the nature of their operations and operational environment and
have nothing to do with HACCP, ISO22000 or export requirements. So what does
all that mean...If your inspector can not provide a reference and refuses to
do so, then you are within your rights to challenge the request. The
relevant authority should have an independent dispute process and make
information available to you as to how you exercise your rights through this
process. If they can't identify the criteria (provide the appropriate
reference) then they must overturn the finding to preserve the objectivity
and impartiality of process that should exist.
I'd be interested to know a bit more about the authority and how you get on.
Best of luck
Regards
Wayne Cullinan AIMM CPMgr MQSA
Director
(Senior Auditor/Assessor - 007291)
ECAAS Pty Ltd [t:] +61 8 8237 0557 [f:] +61 8 8237
0555 <http://www.ecaas.com/> www.ecaas.com
This email message is intended only for the addressee(s). It contains
information, which may be confidential and subject to legal privilege. If
you are not the intended recipient please do not read, save, forward,
disclose, or copy the contents of this email. If this email has been sent to
you in error, please contact us at <mailto:info@ecaas.com> info@ecaas.com
for instruction on deleting this email and any copies or links to this email
from your system. In accordance with the National Privacy Principles (NPP)
Act 1988, all information disclosed to and by ECAAS, is subject to NPP and
is strictly Private and Confidential. The recipient is bound to collect,
store, access and destroy personal and sensitive information in accordance
with NPP. This information remains the property of ECAAS. The content of
this information is not to be communicated to any other person than the
designated recipient without the express prior permission of ECAAS and in
accordance with NPP permission from the person/s this material refers to.
This information is not to de duplicated or copied in any form including
electronic without direct authorisation by ECAAS.
This archive was generated by hypermail 2b29 : Tue May 02 2006 - 18:09:02 PDT