Fundamentals of the Audit Process

A major key to success for any bottled water company is the ability to produce a consistently high-quality product, without risk to the consumer. That simple objective is hard to achieve, and even harder to maintain. To the uninformed observer, taking water from a source and putting it into a bottle may seem easy, but the reality is very different, as there are numerous hazards to overcome. This challenge, however, can be a lot easier with the help of NSF International.

NSF has been working with the bottled water industry for more than 20 years. Its overall auditing and product certification programs are used today in more than 100 countries worldwide, and NSF annually conducts more than 500 plant audits. From the smallest home and office delivery (HOD) plants to the world’s largest bottling plants, NSF’s services are valued for the benefits they continue to provide.

Initial Audit Process

After NSF receives an Application for Services from a bottling company and the necessary paperwork is completed, arrangements are made for an NSF auditor to visit the bottling plant on a date agreed on with the customer. This first visit, the Initial Audit, is an important occasion, usually lasting one full day.

The auditor will first sit down with plant managers to explain how the audit will be conducted and reported. The NSF Checklist, a detailed questionnaire based on a number of well-recognized standards or regulations governing the bottled water industry worldwide, will be explained in detail. The checklist contains almost 200 items relating to good manufacturing practices and good hygiene practices in the bottled water industry. It also contains items relating to Hazard Analysis Critical Control Points, the science-based system required by law in the European Union, as well as the basis for all modern food safety systems in the food and beverage field.

The auditor will ask a number of questions at the start of the audit and will ask to see several documents. These relate to the nature of the company’s operations, the type of water produced, its source, any treatments employed, the equipment used and the types of containers filled in the plant. Other questions relate to personnel, such as their training, personal hygiene and supervision, and to other matters, such as pest control, and storage and transportation of final products.

Then the physical inspection of the whole process begins, usually by “following the flow” of water from the source (natural spring, borehole or even public water supply) through to final product storage and transport. Any treatment involved is carefully reviewed, including iron, manganese or arsenic removal; filtration—including any sub-micron filtration; and disinfection processes (UV, ozonization, etc.). Container production follows, including the handling, washing and disinfection of returnable bottles. Filling, capping, labeling and inspection, storage and delivery of the final product conclude the “walk through” part of the audit. Further questions may then follow, relating to such matters as sampling and analysis of both raw source water and final product water. Here again, records and results may be reviewed by the auditor.

Audit Report & Scoring

When all items on the NSF Checklist have been covered, the auditor will usually ask to be left alone for a period of time in order to complete his or her report before leaving the plant. This is important because NSF prefers to provide the Audit Report immediately after the audit and before leaving the plant. This provides the opportunity to discuss the results of the audit in detail, particularly in regards to any items of non-compliance noted during the audit.

Each item on the NSF Checklist is given a numbered mark, or score, with any non-compliance having marks deducted (depending on the degree of non-compliance noted). Some items are expressed as Control Points, and failure to comply with one of these incurs additional deductions. At the end of the report, all scores and any deductions are calculated to give a final score as a percentage, and each item of non-compliance includes a written explanation of the reason for failure.

For the Initial Audit, it is not uncommon for the customer to find the final score lower than expected, but the report is very helpful in identifying where and how improvements can be made. The audit is then repeated annually; many NSF customers take great pride in working to improve the previous year’s audit score.

It is important to stress that the NSF audit is very supportive, educational and informative, and not in any sense penal or critical. The NSF auditors are not “sanitary policemen” but experienced professionals who will work hard to help and encourage clients to achieve greater success; however, they are not consultants but impartial, third-party assessors.

Many NSF customers prefer to go further than the basic (but important) NSF Bottled Water Auditing Program and apply for NSF certification. In addition to the annual audit described previously, NSF will take annual samples of product water (and source water if necessary) to be analyzed in NSF’s own labs. Companies found to be compliant with all aspects of the certification program requirements are then certified. Their company names and addresses and their certified products are listed on the NSF Bottled Water Listing (www.nsf.org), and their products are required to carry the distinctive NSF Mark on their labels.

A major key to success for any bottled water company is the ability to produce a consistently high-quality product, without risk to the consumer. That simple objective is hard to achieve, and even harder to maintain. To the uninformed observer, taking water from a source and putting it into a bottle may seem easy, but the reality is very different, as there are numerous hazards to overcome. This challenge, however, can be a lot easier with the help of NSF International.

NSF has been working with the bottled water industry for more than 20 years. Its overall auditing and product certification programs are used today in more than 100 countries worldwide, and NSF annually conducts more than 500 plant audits. From the smallest home and office delivery (HOD) plants to the world’s largest bottling plants, NSF’s services are valued for the benefits they continue to provide.

Initial Audit Process

After NSF receives an Application for Services from a bottling company and the necessary paperwork is completed, arrangements are made for an NSF auditor to visit the bottling plant on a date agreed on with the customer. This first visit, the Initial Audit, is an important occasion, usually lasting one full day.

The auditor will first sit down with plant managers to explain how the audit will be conducted and reported. The NSF Checklist, a detailed questionnaire based on a number of well-recognized standards or regulations governing the bottled water industry worldwide, will be explained in detail. The checklist contains almost 200 items relating to good manufacturing practices and good hygiene practices in the bottled water industry. It also contains items relating to Hazard Analysis Critical Control Points, the science-based system required by law in the European Union, as well as the basis for all modern food safety systems in the food and beverage field.

The auditor will ask a number of questions at the start of the audit and will ask to see several documents. These relate to the nature of the company’s operations, the type of water produced, its source, any treatments employed, the equipment used and the types of containers filled in the plant. Other questions relate to personnel, such as their training, personal hygiene and supervision, and to other matters, such as pest control, and storage and transportation of final products.

Then the physical inspection of the whole process begins, usually by “following the flow” of water from the source (natural spring, borehole or even public water supply) through to final product storage and transport. Any treatment involved is carefully reviewed, including iron, manganese or arsenic removal; filtration—including any sub-micron filtration; and disinfection processes (UV, ozonization, etc.). Container production follows, including the handling, washing and disinfection of returnable bottles. Filling, capping, labeling and inspection, storage and delivery of the final product conclude the “walk through” part of the audit. Further questions may then follow, relating to such matters as sampling and analysis of both raw source water and final product water. Here again, records and results may be reviewed by the auditor.

Audit Report & Scoring

When all items on the NSF Checklist have been covered, the auditor will usually ask to be left alone for a period of time in order to complete his or her report before leaving the plant. This is important because NSF prefers to provide the Audit Report immediately after the audit and before leaving the plant. This provides the opportunity to discuss the results of the audit in detail, particularly in regards to any items of non-compliance noted during the audit.

Each item on the NSF Checklist is given a numbered mark, or score, with any non-compliance having marks deducted (depending on the degree of non-compliance noted). Some items are expressed as Control Points, and failure to comply with one of these incurs additional deductions. At the end of the report, all scores and any deductions are calculated to give a final score as a percentage, and each item of non-compliance includes a written explanation of the reason for failure.

For the Initial Audit, it is not uncommon for the customer to find the final score lower than expected, but the report is very helpful in identifying where and how improvements can be made. The audit is then repeated annually; many NSF customers take great pride in working to improve the previous year’s audit score.

It is important to stress that the NSF audit is very supportive, educational and informative, and not in any sense penal or critical. The NSF auditors are not “sanitary policemen” but experienced professionals who will work hard to help and encourage clients to achieve greater success; however, they are not consultants but impartial, third-party assessors.

Many NSF customers prefer to go further than the basic (but important) NSF Bottled Water Auditing Program and apply for NSF certification. In addition to the annual audit described previously, NSF will take annual samples of product water (and source water if necessary) to be analyzed in NSF’s own labs. Companies found to be compliant with all aspects of the certification program requirements are then certified. Their company names and addresses and their certified products are listed on the NSF Bottled Water Listing (www.nsf.org), and their products are required to carry the distinctive NSF Mark on their labels.

Bob Tanner is international auditor, EMEA Region for NSF.

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