The Tender Deadline and the Allergen Records
During the closing meeting of a two-day ISO 22000 audit at a ready-meal factory, you have recorded four major nonconformities. The most serious: cleaning verification records for allergen changeovers are missing for 6 of the 12 changeovers sampled in the last quarter, and two of those changeovers produced product already shipped to three retail customers. The general manager takes you aside and says the classification is 'commercially driven', that a major finding will jeopardise a supermarket tender closing in ten days, and asks you to record it as an observation instead. He adds that the company is reviewing certification bodies and that a three-year contract with your CB, plus more audit days, is 'on the table'. Your CB pays you a day rate and you are currently booked for only nine days next quarter. You are the audit team leader; the report is due in 48 hours.
1. How should you respond to the request to reclassify, and why is the classification not a matter for negotiation?
Read the worked answer
Decline explicitly, so there is no later ambiguity about what was agreed. Classification follows from evidence and criteria, not from consequences. Allergen changeover verification is a control the food safety management system depends on; six of twelve sampled changeovers have no evidence it happened, and product from two of them has shipped. That is a systemic failure of a control affecting product already in the market - the usual basis for a major nonconformity.
The tender date, the contract value and the CB's commercial interest are irrelevant to the classification. If they enter the decision, the audit stops being evidence-based and the certificate stops meaning anything.
What you should do:
- Restate the criteria and the evidence in the closing meeting, with management present.
- Record the nonconformity as written, with lot numbers, dates and record references.
- Note factually in the audit record that a reclassification was requested and declined.
- Offer only what is legitimately available: a clear corrective-action path and an early follow-up if your CB's procedures allow it.
What you must not do is trade the finding for future work.
2. The offer of extra audit days and the remark about reviewing certification bodies are aimed at you personally. What should you do with them?
Read the worked answer
This is a self-interest threat directed at the auditor, and also an attempt to influence the outcome. Handle it in three steps:
- Do not engage. Say once that you cannot discuss commercial arrangements during an audit and that the finding will not change. Then move the conversation back into the closing meeting, with witnesses.
- Declare it in writing to the CB the same day. The CB carries the impartiality risk, not just you, and it needs the facts to manage it.
- Record the statement in the audit file.
The day-rate model is the structural weakness: an auditor whose next quarter depends on client satisfaction has a financial interest in soft findings. That does not excuse anything, but the CB should know so it can manage the risk - for example, not booking you with this client again and reviewing how fees create pressure.
If the pressure continues, or if anyone inside the CB suggests softening the finding, escalation is the only defensible route: internally first, then to the accreditation body if the CB's integrity is compromised. Withdrawing from the audit is better than signing a report you do not believe.
3. What belongs in the nonconformity report, and what should be kept out of it?
Read the worked answer
In the finding: the requirement (the clause or the client's own procedure on allergen changeover verification), the objective evidence (which changeovers, which dates, which records are missing, which lots shipped and to how many customers), the classification, and how the sample was selected. Write it so a third party could re-check it independently.
Out of the finding: speculation about why records are missing, individual names where the process is the issue, the general manager's commercial pressure, and any language that reads as advocacy such as 'clearly negligent'.
The pressure belongs in the audit record or impartiality file, not in the nonconformity, because it is a fact about the audit rather than about the client's food safety system. Mixing the two weakens the finding: the auditee can then argue the nonconformity is about the argument rather than the allergen control. Keep the factual spine clean, and put the conduct issue where the CB can act on it.