Learn the key steps your remote audit process must include from FSMA Friday- GFSI's virtual & remote auditing processes. Presented by Rich Simmons, Senior Advisor of Food Safety at The Acheson Group.

1. FSMA Fridays Webinar Series
GFSI Remote & Virtual Auditing Update
with Rich Simmons, The Acheson Group
January 29, 2021

2. ✔ FSMA Related News
✔ Regulation Changes & Updates
✔ Industry Trends
✔ Q&A with TAG
What is FSMA Fridays?
FSMA FRIDAYS

3. ✔
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safetychain.com > Resources >
Before We Get Started
FSMA FRIDAYS

4. Featured Panelists & Host
FSMA FRIDAYS
Aaron Bolshaw
VP Marketing
Rich Simmons
Senior Advisor, Food Safety, TAG
● 36 years of experience in the food industry specializing
in GFSI food safety management system standards
having completed over 200 SQF audits and 100 BRC
audits in his career.
● Mr. Simmons has held positions of Certification
Manager and Technical Operations Manager at NSF
International
● Responsible for the certification body management of
FSSC, IFS, BRC and SQF standards and Technical
Review processes of all GFSI standards

5. FSMA FRIDAYS
The Latest FSMA Updates
1. FSMA’s 10th Anniversary: Ten years ago, on Jan. 4, 2011, the FDA Food Safety
Modernization Act (FSMA) was signed into law and Congress’ mandate was clear: “It’s not
enough to respond to outbreaks of foodborne illness. We must prevent them from
happening in the first place.”
2. VQIP Application Portal Now Open for FY 2022. On January 1, 2021, the U.S. Food and
Drug Administration (FDA) will open the Voluntary Qualified Importer Program (VQIP)
application portal for fiscal year (FY) 2022.
3. FDA Adds Clarifying Descriptions to the Food Traceability List; Publishes FAQ on Food
Traceability Proposed Rule. The U.S. Food and Drug Administration has made two updates
to its materials for stakeholders regarding the proposed rule, “Requirements for Additional
Traceability Records for Certain Foods” (Food Traceability Proposed Rule).

6. FSMA FRIDAYS
✔ GFSI Position
✔ SQFI Position
✔ BRC Position
✔ FSSC Position
✔ The remote audit experience - tips
Remote GFSI Audits

7. FSMA FRIDAYS
✔ On June 11th
, 2020, GFSI approved the amended benchmarking
requirements that will allow for the use of Information
Communication Technology (ICT) as part of the GFSI benchmarked
certification audits. The decision by the GFSI Board was made after
careful consideration and feedback from the various stakeholders
involved in the process.
✔ This is in response to the global COVID-19 pandemic, but was
developed to be a sustainable process, post pandemic.
✔ This will allow CPOs (Certification Program Owners) to begin to
use remote activities as part of the GFSI benchmarked certification
process.
GFSI’s Position on Remote Audits

8. FSMA FRIDAYS
The use of remote activities is not mandatory and must be mutually agreed upon between the audited
organization and the certification body. Part of the decision to use remote activities must also include an
assessment to ensure that the auditor and site have access and the capability to effectively use ICT.
The full audit objectives must be met and all parts of the audit process completed effectively and as a
combined process.
For GFSI recognition, the audit cannot be fully remote; the GMP component must be completed on-site.
Each CPO must define what parts of the audit may be carried out remotely, but the onsite portion must
include, at a minimum, the inspection/physical verification of the GMPs and verification that the food
safety management system addresses all parts of the operations.
GFSI Criteria for Remote Audits

9. FSMA FRIDAYS
The full audit (i.e. both the remote and onsite activities) must be completed within a 30 day
window. In extreme situations where this requirement cannot be met, the CPO is allowed to
have a program that would allow the timeframe to be extended to 90 days.
Each CPO may implement different criteria, but in all cases a risk assessment must be
completed to ensure efficiency and integrity of the audit will not be affected and additional
audit time may be required.
GFSI Criteria for Remote Audits (continued)

10. FSMA FRIDAYS
✔ SFQF follows the GFSI position but does allow the SQF audit to be fully remote with the
provision that the GFSI logo will not be permitted on the SQF certificate.
✔ SQF Audits can be completed with a Partially Remote Audit, providing a visit to the site
for only the physical component be carried out within 30 days. This will provide the full
audit to be completed with only 50% of the time on site, reducing risks.
✔ 100% remote SQF certified audits can be carried out. The Certification is legitimate but
the GFSI logo will not be on the certificate and this will not be a “GFSI audit”. Under the
current conditions of the pandemic, certain retailers are accepting these audits.
Despite not having the GFSI logo, there is no loss of certification and a GFSI audit can
pick up the next year.
Safe Quality Food (SQF) Standard

11. FSMA FRIDAYS
BRC Global Standard for Food Safety, Packaging, Storage & Distribution
✔ BRCGS also follows the GFSI position but does allow the BRC audit to
be fully remote with the provision that the GFSI logo will not be
permitted on the BRC certificate.
✔ Similarly, BRC Audits can be completed with a Partially Remote Audit,
providing a visit to the site for only the physical component be carried
out within 30 days. This will provide the full audit to be completed with
only 50% of the time on site, reducing risks.
✔ 100% remote BRC certified audits can be carried out. The Certification
is legitimate but the GFSI logo will not be on the certificate and this will
not be a “GFSI audit”. Under the current conditions of the pandemic,
certain retailers are accepting these audits.

12. FSMA FRIDAYS
FSSC 22000
•As of 5 October 2020, all FSSC 22000 licensed Certification Bodies can deliver FSSC 22000 auditing and
certification for food safety and quality based on full remote auditing. The requirements for full remote
audits are described in the newly published Addendum on remote audits.
•FSSC believe that remote auditing (full or partial) is a vital component of the auditing future and trust
that this will bring some relief to an already challenging situation while ensuring a robust audit and
certification process. With the launch of this Addendum, the Foundation is anticipating the future of
audit delivery and the widely shared vision that the use of big data solutions, new online verification
technologies, and ongoing limitations of traveling will have a permanent impact.
•Although the full remote auditing option is currently not GFSI recognized, it has broad support from our
primary industry & CB partners. It complies with GFSI benchmarking requirements except those for the
audit delivery process.
•For Partial Remote Audits, Stage 1 audits can be completed remotely, with GFSI acceptance.

13. FSMA FRIDAYS
Tips for Certified Sites for Remote Audits
Part 1 - Preparation
• Be prepared! The auditor is auditing from the standard – nothing more. Make sure all Policies,
SOPs, Work Instructions, Tables and a selection of records are available – preferably in an order
that follows the standard numerically.
• Become familiar with the use of audio-visual platforms such as Zoom, MS Teams, Bluejeans, Go To
Meeting.
• Ensure you have a computer with a camera and good working microphone.
• The auditor will ask for confidential file sharing on-line. Be prepared to use this. If you have a file
share system that you are comfortable with – offer this to the auditor as you do not have to use the
CB preferred file sharing platform. Some well-known file sharing platforms: Drop Box, MS One Drive
Google Drive and there are others.
• Opening and closing meetings will be completed virtually.

14. FSMA FRIDAYS
Tips for Certified Sites for Remote Audits
Part 2 - Documentation
• All documents should be saved as pdf files as they are not editable.
• Pre-load SOPs, support materials and records into folders that follow the standard. Ensure these
are available at least 24 hours prior to the document portion of the audit, so that the auditor can
become comfortable with the document availability and order before the audit starts.
• Create a selection of records – typically 4 or 5 of each element that requires a record. If more are
needed, they can be shown to the camera easily – so have other records available for this.
• If conducting the audit in a boardroom with a central microphone, ensure it is moved close to the
person speaking to allow the best volume for the person speaking.

15. FSMA FRIDAYS
Tips for Certified Sites for Remote Audits
Part 3 – On-Site
A. Partial Remote:
✔ The auditor arrives and basically picks up where the audit left off. The auditor may need to reference
procedure and documents during this period. The on-site component needs to be 50% of the expected
audit duration, typically.
B. Fully Remote:
✔ The auditor will perform the site inspection using ICT and will direct the site to visit locations in the plant at
his/her instruction.
✔ It is critical that WIFI be available. For full remotes, there is substantial cost savings from travel. It is
recommended that, where possible, extra routers be purchased and installed. These installations may be
of advantage later for plant surveillance and security. If the auditor cannot see most areas, including all
production areas, maintenance storage and chemical areas, the auditor may need to come on site. Note:
WIFI does not work well inside coolers and freezers.
✔ Test your WIFI and know where the no-reception areas are. You may need to re-configure your phone if you
walk through a no-reception zone.

16. FSMA FRIDAYS
Tips for Certified Sites for Remote Audits
A. Partial Remote:
✔ The auditor arrives and picks up
where the audit left off. The auditor
may need to reference procedure and
documents during this period. The
on-site component needs to be 50%
of the expected audit duration,
typically.
B. Fully Remote:
✔ The auditor will perform the site inspection using ICT and will
direct the site to visit locations in the plant at his/her instruction.
✔ It is critical that WiFi be available. For full remotes, there is
substantial cost savings from travel. It is recommended that,
where possible, extra routers be purchased and installed. These
installations may be of advantage later for plant surveillance and
security. If the auditor cannot see most areas, including all
production areas, maintenance storage and chemical areas, the
auditor may need to come on site. Note: WIFI does not work well
inside coolers and freezers.
✔ Test your WiFi and know where the no-reception areas are. You
may need to re-configure your phone if you walk through a
no-reception zone.
Part 3 – On-Site

17. FSMA FRIDAYS
Tips for Certified Sites for Remote Audits
Part 3 – On-Site
B. Fully Remote: continued
✔ The most common interface for on site remote inspections is the cell phone. The phone should
have access to the same audio-visual platform as is being used for the documentation part of the
audit. Other technologies such as Google Glasses may be used as well.
✔ The site representation should wear headphones wired or blue-toothed with the phone as phone
speakers may be difficult to hear in noisy environments. The headphones should have an
operational microphone.
✔ The site representative will need to hold the phone as steady as possible and do as the auditor
requests. Remember that the auditor and other team members are watching every movement.
✔ For interviews, ask the auditor if they can be conducted on a scheduled basis, where the employee
is invited to a quieter area
✔ It is recommended that you practice the on-site camera inspection prior to the audit in order to be
comfortable with the process and any limitations.

18. FSMA FRIDAYS
• SQF, BRC and FSSC accept both partial remote and fully remote audits.
• Fully remote audits are not permitted to carry the GFSI logo for any GFSI standard.
• Partial Remote audits are a permanent addition to the standards and will not be phased out
after the pandemic.
• Organize and plan documents and records and have them available prior to the start of the
audit.
• Check WIFI connectivity and plan to add additional routers, if connectivity is weak in required
areas.
• Practice the on-site inspection with your ICT so you can improve your technique in advance of
the audit.
Conclusion

19. Q & A
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20. ✔ FSMA Friday Session Recordings & Content Library
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Resources & Future Events
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February 26, 2021:
Dr Liliana Casal-Wardle, Ph.D., Senior Director Food Safety