VITAL An Auditing Perspective

by Majella Furey, NCS International

Majella described the key aspects of a third-party audit where VITAL has been used to support allergen labelling practices. Her primary message to auditees was to prepare well for the audit, to ensure all relevant documentation is at hand and can be presented to the auditor in a logical order.

Documentation includes the product formulation or recipe, raw material specifications, which could be presented on the Product Information Form (PIF), and documentation to show hazard analysis of the production lines has been undertaken, including all hang-up points, conveyor lines, mixing bowls etc. Copies of the final product labels, all VITAL calculations and evidence to support any assumptions that have been made in the process will also be required. Where products are known to contain allergens, the amount of protein from an allergen should be provided in ppm. Auditors will expect to see evidence that review of a VITAL has been undertaken every 6-12 months.

Auditees were reminded that in addition to VITAL, auditors will also expect to see a HACCP Plan in which allergens have been considered in the hazard analysis, and an Allergen Management Program that encompasses the activities of R&D, Engineering, Raw Materials, Rework, Production Scheduling, Packaging, Training, Labelling and Cleaning. Cleaning validation results will need to be presented during the audit.

This presentation can be downloaded here.