EFISC-GTP Through the eyes of an auditor.

EFISC-GTP Through the eyes of an auditor.
Issue: Internal audit (clause 4.4.6.)

When an external auditor requests a set of internal audit documents, it takes them just five minutes to understand whether the system is actually working within the organisation or whether the files have simply been created for the purposes of the audit. Internal auditing under the EFISC-GTP framework is your first line of defence. If you do not identify any non-conformities yourselves, the auditor will find them, but the cost will be much higher – potentially leading to the suspension of export contracts.
Let’s examine the standard’s requirements, the methodology for conducting audits, and the documentation you are required to provide.
1. Why is this necessary, and what does the standard require?
Clause 6.4 of the EFISC-GTP standard requires the organisation to carry out internal audits at planned intervals (at least once a year). The aim is to verify whether your management system complies with planned activities, the requirements of the standard itself and EU legislation (including Regulation No. 183/2005 on feed hygiene).
The two main principles of the standard:
•    Risk-based assessment: The frequency and depth of an audit of a specific production area should depend on its criticality. The meal dispatch or oil refining area should be audited more strictly and frequently than the documentation archive.
•    Objectivity (clause 4.4.6): Auditors must not audit their own work. If a quality manager has personally compiled the HACCP records, they are not authorised to audit them.
2. Documentation package: what does a GIC auditor check?
The auditor checks not just a single report, but the end-to-end logic of the process. You must present the full cycle of documentation:
1.    Order appointing the internal audit team: Confirmation of staff authorisation and qualifications.
2.    Audit Programme: An annual schedule showing which processes are audited, when, and at what frequency.
3.    Audit Plan: A detailed ‘minute-by-minute’ schedule for a specific audit (for example: 09:00 – traceability check at the grain elevator, 11:00 – audit of production processes).
4.    Non-conformity Report: Records of identified non-conformities. If your reports show ‘zero non-conformities’ for the year, this is a sign to the auditor that the audit is a formality.
5.    Corrective Action Plan (CAPA Plan): A document proving that you have identified the cause of the problem, rectified it, appointed responsible persons and set deadlines for follow-up.
3. How should you conduct and complete a checklist correctly?
The main mistake is giving ‘Yes/No’ answers or leaving boxes ticked without any details in checklists. For European auditors, this is a guaranteed non-conformity (a formality audit). A checklist must contain facts, dates and cross-references.
As part of its cross-border work in various countries, GUARD IS CERTIFICATIONS (GIC) uses up-to-date official checklists published by EFISC-GTP. We provide these to our clients in various languages to enable them to carry out a high-quality self-assessment.
Examples of correct and incorrect completion when preparing for an audit:
•    Nominal approach (Failure at audit):
o    Clause 4.4.1 (Documentation) — Is this being implemented? — Yes.
o    Clause 6.11 (Monitoring of CCPs) — Is this being implemented? — Yes.
•    Expert approach (Mature system level):
o    Clause 4.4.1 — Yes. Procedure P-03 dated 12 January 2026. The current version of the Master List is controlled in the ERP system; change log No. Zh-05.
o    Clause 6.11 — Yes. Critical control point CCP-1 (temperature control of the heat and moisture treatment of meal). Records are kept automatically by a Siemens controller (Verification Sheet No. 4 dated 15 May 2026).
•    Exceptions (Justification):
o    Clause 4.3.9. (Handling of non-certified feed and ingredients not intended for use in feed during production, storage and transport) — Not applicable. The scope of the company’s certification (Scope D) covers all product names, without exception. The justification for the non-applicability of this clause is recorded in the System Manual.

An internal audit of the EFISC-GTP system is not a punishment tool. It is a tool to protect your exports. If your documentation chain (Order ➔ Programme ➔ Plan ➔ Report ➔ Corrective actions) operates seamlessly, and the checklist is filled with facts rather than just tick boxes, the external audit will go perfectly.
Do you need the latest official multilingual EFISC-GTP checklist from the certification body to carry out an internal stress test? Request it from our specialists – market@certgic.com.
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All documents published on the website are public and freely accessible. The information, including documents, is valid as of the date of publication, March 2026.
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