Don't Forget About Those Corrective Actions!


After passing a third party food safety audit there is a tendency to celebrate. And you should! What a terrific achievement, especially if you've gained certification to a GFSI benchmarked scheme (SQF, BRC, etc.). But your work isn't done just yet. Now it's time for those corrective actions.

Depending on the severity of the non-conformance corrective actions must be closed out within a specific amount of time. For SQF, Major Non-Conformances must be closed out within 14 days and Minor Non-Conformances must be closed out within 30 days. BRC allows 28 days to close out non-conformances, but if the audit score was C/C+ close out is done by means of another site visit within 28 days.

Keep in mind, the audit process is not complete and no certificate can be issued until all corrective actions are closed out. Also, notice that corrective actions must be closed out within the required time frame, not simply submitted. Often times facilities will submit their corrective actions for review on the last day. This does not leave enough time for the auditor to review and close out the non-conformance, especially if the corrective action is inadequate and needs to be redone or expanded upon. 

Not having the corrective actions approved and non-conformances closed out within the required time frame can have terrible consequences. The SQF and BRC standards are very clear that certification cannot be granted in the event that non-conformances are not closed out by the deadline. 

If this were to happen on an initial certification there is a risk of needing another full audit. While some certification bodies may be slightly more lenient than others when handing down this judgement, it is best to never put your facility in this position. Imagine putting all that time, effort, and money into gaining certification only to need to repeat the entire process! 

If deadlines were exceeded on a re-certification audit, the facility's certificate is suspended immediately until non-conformances are closed out. Another full audit may needed (as is mentioned in the BRC Standard Issue 6) or another site visit may be required by the auditor to verify the implementation of the corrective actions. 

In response to this procrastination on the part of certified facilities, NSF is now requiring all corrective actions for BRC audits to be submitted within 21 days. This will give their auditors enough time to review, provide feedback, and close out non-conformances within the 28 day requirement. Don't be surprised if other Certification Bodies follow suit or if this practice expands to include other audit standards. 

Don't forget those corrective actions! Create a detailed corrective action plan with root cause analysis, submit them with enough time to be closed out, and your new certificate should be on its way in no time. Then it's time to celebrate.