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Key issues in unannounced inspections

2021-09-04View Original

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1. Verify the legal status of inspection and testing institutions: For inspection and testing institutions with independent legal person status, special attention should be paid to the validity of their Business Licenses. The finances of such institutions must be accounted for separately; Clarify the legal responsibilities for providing test data and results with evidentiary value to the public. 1. Inspect the usage of qualification certification marks. Pay particular attention to whether the use of such marks by testing and inspection agencies complies with relevant regulations. It is necessary to verify whether the testing items and the applicable standards are listed in the agency’s approved list of qualified items. Some testing and inspection agencies lack awareness; they often believe that obtaining a qualification certification proves that the agency has the capability to conduct testing activities externally. The inspection of key personnel focuses on the following: Technical supervisor: Must possess a mid-level or higher professional technical qualification in this field, or have equivalent capabilities. In large, comprehensive laboratories, the technical supervision can be handled by a single person overseeing all technical operations; alternatively, multiple technical supervisors may be appointed to manage technical operations in different specialized areas, so as to meet the requirements of various testing activities. Authorized signatory: Must possess an intermediate or higher relevant professional technical title or equivalent capabilities. Requirements for inspectors at food inspection agencies: The proportion of personnel with intermediate or higher professional technical titles (including intermediate level) or equivalent capabilities must be no less than 30%. Such personnel must hold valid certificates to perform their duties ; Technical management personnel working in food inspection agencies should hold a mid-level or higher (including mid-level) technical title in a relevant field and possess equivalent capabilities, with at least three years of experience in food-related work. Unauthorized signatories shall not issue inspection and testing reports. The authorized signatory must be approved by the competent authority for qualification assessment before performing their duties. Personnel who are employed by two or more inspection and testing agencies at the same time shall not be used. 4 Inspection of facility environments: Special attention should be paid to whether testing and inspection institutions have supporting documents such as proof of property ownership or housing lease contracts for their fixed, temporary, mobile, or multiple testing locations. When environmental requirements are explicitly specified in the standards, effective isolation measures must be taken regarding spatial separation, electromagnetic field isolation, and biosafety, etc., to prevent any impact on test results. The facilities and equipment in the food testing laboratory should be effectively isolated to prevent cross-contamination. The facilities and environment in the laboratory should be properly arranged, with proper ventilation, lighting, sprinkling systems, and waste disposal measures in place. 5 Inspection of testing equipment Testing and inspection agencies shall properly equip themselves with instruments, equipment, software, and reference materials required for testing in accordance with the product standards. Testing and inspection agencies shall formulate an annual overall plan for instruments and equipment, clearly stipulating the procurement, acceptance, verification and calibration, use, and maintenance of the equipment. It should be ensured that the equipment inspection/calibration is within the validity period and bears a qualified inspection label. Inspections for changes in locations, personnel, and standards: Special attention is paid to any changes in the name, testing location, or legal status of testing and inspection institutions ; There are changes in key personnel such as the legal representative, top management, technical director, and authorized signatory of the inspection and testing agency ; Self-revocation of qualification-recognized inspection and testing items ; In cases where inspection standards or method standards undergo changes, an application for such changes must be submitted in a timely manner to the administrative approval authority responsible for qualification accreditation. 7 Inspection of management systems and operational records: The management system of inspection and testing institutions shall be established in accordance with relevant requirements such as the “Administrative Measures for Qualification Accreditation of Inspection and Testing Institutions”. Their operational records must be standardized and meticulous. The retention period for all records shall be 6 years, and the management system and internal documents shall be duly controlled.

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