(Approved Auditors)
Dear Approved Auditors,
The department has circulated advice to industry advising of its current position on staffing, regulatory and operational obligations in relation to the audits of export establishments and the risks posed by the COVID-19 outbreak.
At this time, all audits will be conducted as scheduled, including those due to be conducted by approved auditors.
In some circumstances (compliance history, importing country, food safety risks) on-site audits will be mandatory. If a site audit is mandatory – you will be advised if this is applicable to an establishment in your allocation. Please also note:
- These measures are temporary and have been implemented to ensure the continuation of the department’s role in maintaining the assurances that underpin our export certification system.
- Auditors will adhere to safe working practices when attending third party premises in accordance with any government guidelines, such as maintaining physical distancing and increased handwashing.
- On-site audits can be undertaken fully on-site, where safe working practices can be maintained, where staff are available, and can be undertaken in two parts so site interaction is limited (e.g. walkthrough and viewing of processing is undertaken on site) and record-verification is undertaken remotely.
- ER reports and copies of RFPs are available for preparing for upcoming audits by e-mailing Dairyeggsfish@awe.gov.au
- Any issues identified (for example; no response from establishment, auditee, critical non-compliance identified at audit) are to be communicated to the Dairyeggsfish@awe.gov.au mailbox.
- Audits conducted remotely will be monitored for effectiveness by the DEF and Meat Programs
In the event that you are required to conduct a remote audit, it is to be completed with consideration of the following:
Re-scheduling / Deferring audits
- Audits are to be conducted as scheduled unless the establishment has formally advised the department of a cessation of all operations in writing to Dairyeggsfish@awe.gov.au
- Rescheduling of site audits is acceptable, but if not able to be completed within 2 months of the scheduled audit date – remote audit is required
Remote Audits
- Remote audits will be focused on a review of requested documentation. Additional information and further supporting documentation or information in other formats – i.e. photographs, phone interviews etc. may be requested
- That the audit is being conducted remotely and the type of information utilised to conduct the audit is to be noted in the audit report.
- All relevant e-mails and associated documents reviewed at audit are to be held on file by the auditor and may be subject to verification by the department.
- An audit report is to be completed, provided to the occupier and sent to Dairyeggsfish@awe.gov.au as
- The remote audit is to be conducted with consideration of the following:
1. Advising the Occupier of audit scope
The scope of the remote audit will include:
- Confirming establishment details.
- Where applicable, verification of closure of any outstanding corrective actions resulting from previous audits.
- Conducting a document trace-back of product prepared by your establishment and exported.
- For storage facilities and freight forwarders – provision of product receival, storage and dispatch records for a specified period will be requested.
- A review of any amendments made to your approved arrangement required to address changes of suppliers, new product lines, new equipment or procedures required to address issues resulting from the impacts of COVID-19.
- Any other documentation required to verify compliance
2. Audit preparation
- ER reports and copies of RFPs are available for preparing for upcoming audits by e-mailing Dairyeggsfish@awe.gov.au
- DEF Program support staff will provide between 3 and 5 of the establishments most recent RFPs for trace back where applicable
- Please do not provide copies of RFPs to the establishment unless the exporter is also the manufacturer. If the manufacturer is not also the exporter – request details of product on the basis of product type and production dates indicated in RFPs to have been manufactured for final export by the establishment. RFP certificate numbers may be included only if the exporter is also the manufacturer of the product.
- If product is subject to specific importing country requirements (i.e. product standards rather than the establishment only requiring country listing) – you may request additional supporting information – for example product test results.
- Requests for documentation and product information are to be applicable to and appropriate to the output and operations of the establishment. For example: For a storage only establishment: records of goods inwards and outwards, and temperature storage records will be applicable, whereas a manufacturing establishment must be able to provide records applicable to products exported (or transferred) by the establishment.
3. Requesting documentation
Request for documentation for remote audit is to include:
- Conformation of the details in the attached ER report (accurate and current, including persons in management and control, all nominated phone and e-mail contacts and approved operations).
- If changes are required – request this be indicate on the ER report, including the signature of someone in management and control. This report to be forwarded with your Audit Report to Dairyeggsfish@awe.gov.au for action. Please note – this includes removal of persons in management and control. Additions of persons must be completed by submission of an EX26 form that can be obtained from: https://www.agriculture.gov.au/export/from-australia/ex26 and returned to your auditor
- If CARs are due for action, outstanding or have not yet been fully addressed); request copies along with any supporting information detailing the actions taken to address the non-conformance(s) including the root cause and the evidence that the actions taken have been effective in preventing re-occurrence.
- Request details of products prepared or stored by the establishment by specifying:
- products and production dates from RFPs
- If no RFPs – product prepared post previous audit
- For storage establishments – for a range of dates post previous audit
- Request all documents relating to the preparation or storage of a range of product lines including records of:
- receipt of product (and ingredients as applicable)
- Cleaning records, pre-operational check records applicable to the dates of production / storage
- Production records detailing inputs / outputs (including storage temperature record if applicable)
- All associated CCP monitoring records for the lot or lots indicated (if not already included in the Production Record) and calibration records for devices used to monitor CCPs
- Microbiological test results if applicable to the lot exported (i.e. if test and release)
- Trade description applied to the product
- Dispatch records
4. Conduct Audit
This is primarily a thorough examination of the documentation required to be maintained by the establishment to support the certification of the product/s detailed in the selected RFPs, or for product stored handled and loaded since the previous site audit.
Additional information may be requested to further inform this examination or if non-compliances are identified.
It is not a requirement for establishments to initially provide records of general GMP monitoring unless associated with the dates specified for processing or storage and handling.
When conducting the remote audit:
- Review response from establishment and request additional details if required to verify compliance.
- If phone calls/ discussions are made to clarify or seek further information – discussion to be noted as part of the audit in the audit checklist / audit report as applicable.
Confirm product specific documentation provided is compliant – i.e. must demonstrate that:
- Any applicable importing country requirements (including current MAAs have been met)
- Changes to the approved arrangement have been recorded as applicable.
- Schedule 2 – food safety is managed (CCP monitoring)
- Schedule 5 – product has have been sourced as per legislative requirements
- Schedule 7 – trade description applied to the product meets legislative requirements
- Schedule 8 – requirements for identification, tracing systems, integrity and transfer have been maintained
- Copies of export documents have been maintained (only if the manufacturer is also the exporter and AEPI)
5. Audit findings and closing meeting
At the conclusion of the audit, the auditee is to be contacted to conduct the closing meeting.
- Provide summary of findings
- Where applicable, explain what CARs may be raised and discuss requirements for CAR close-out – with an encouragement to send in evidence to remotely close out prior to agreed close-out date.
- Audit findings that indicate a site audit may be required to confirm compliance or verify effective corrective action are to be reported to Dairyeggsfish@awe.gov.au for action.
6. Report Audit
Copies of Audit Checklists, Audit Reports, CARs and evidence of CAR closures are to be sent to Dairyeggsfish@awe.gov.au as per current procedures.
Further information
Contact the dairy, eggs and fish exports section by email.