Guide 03 — Conducting the On-Site Audit

When to use: step 4 of the foreign certification workflow — the physical audit at the foreign facility.

Related: desk review · criteria pages · findings & report

1. Before departure

• Re-read the desk-review memo; build the on-site agenda from its open findings (audit = verify the open questions, not re-read the file).
• Confirm scope: which products/lines are audited, which are excluded (and why) — an exclusion must be recorded.
• Logistics: interpreter confirmed, factory appointment, PPE per site rules, camera with GPS/time-stamp, sampling kits and seals if sampling is planned, and your LPH’s sampling protocol (sample count, selection, sealing, transport to lab 🔎).
• Check travel/entry documents and LPH requirements for conducting audits abroad (notification/registration of the audit in SIHALAL as applicable 🔎).

2. Opening meeting (set the frame)

• Present: audit purpose, scope, criteria (5 HAS/SJPH), method, expected duration, and the NC classification convention used by your LPH.
• Confirm who accompanies: halal supervisor, QC lead, production manager; arrange Chinese/EN translation.
• Request a brief plant presentation — it often reveals discrepancies with the flowchart before you walk.

3. Walkthrough — the line is the truth

Walk the physical flow from goods receiving to dispatch and compare with the flowchart and the written process documents (工艺文件/作业指导书). At each step, ask: which material enters here, from which supplier, is it on the approved matrix?

China-specific watch points:

• OEM/分装 reality — is the goods being made here, or assembled/repacked from elsewhere? Are there other brands’ products in the same line/warehouse?
• Canteen (员工食堂) — pork commonly cooked on site; must not contaminate production/storage; check airflow/doors/cleaning between canteen and food areas.
• Shared/rented warehouses — segregation and cleaning evidence; FIFO and storage integrity.
• Employee hands & habits — observe operators, utensils, shared containers; halal assurance lives in habits, not posters.
• Cleaning reality — check CIP/COP records against a short “surprise” inspection of equipment (residue under covers, filters, dead legs).
• Rework loops — returned/off-spec product re-entering the line must use approved materials only.
• Animal-derived equipment items — brushes/bristles, fat-based release agents, filters (e.g., gelatin-coated), lubricants.

4. Verification techniques (beyond looking)

1. Records reconciliation (the strongest tool). Pick 2–3 products and a sample window (e.g., 3 months). Reconcile: purchased volumes (采购 + invoices) → batching records (投料/批记录) → finished goods → sales/dispatch (销售/发货台账). Volumes must tell one story. Unexplained gaps = unapproved materials, moonlight production, or paper compliance.
2. Batch traceability. Take one finished batch number and walk it backward (materials + suppliers + storage) and forward (customer, quantity, dates). Also test the reverse.
3. Label vs batching. Compare a sample of labels (配料表) with the batch records and the approved material matrix — labels must not hide animal/alcohol items behind collective names.
4. Interviews. Ask operators what they actually do at critical steps (thawing, frying oil, cleaning between products) — compare with the documented procedure.
5. Material-cerf spot check. For every critical material observed: certificate issuer on the live LHLN list? scope matches supplier/product? valid on the audit date?
6. Sampling. Take samples per LPH protocol where lab evidence is needed (porcine DNA/protein, alcohol). Seal and document chain of custody (photos, seals, log); confirm which labs the file accepts 🔎. See China labs and the detection & testing primer for method-vs-matrix choice and report reading.

5. Evidence capture

• Photographs: facility entrance/signage (identity vs registry), lines, storage, canteen, labels, certificates on walls, anything NC-related — all GPS/time-stamped.
• Collect stamped (盖章) copies of records you cite; note file/document numbers so findings are re-checkable.
• Keep a running findings log during the day; do not rely on memory.

6. Closing meeting

• Summarize findings by criterion; read each NC aloud with the evidence and the requirement it violates.
• Distinguish clearly between: (a) NC that must close before certificate recommendation, (b) observations/improvements, (c) items carried to surveillance.
• Agree on owners and target dates; do not accept verbal “we will fix it” without a written commitment record.
• Sign the attendance/audit record with the company.

7. Post-visit discipline

• Same-week draft of the audit report while memory is fresh; photos matched to findings.
• Follow up the sampling chain of custody and lab results; incorporate into the report.
• Update the file: what was verified, what remains open, what the certificate recommendation will be.

8. Auditor independence (non-negotiable)

• Accept no gifts or hospitality that could compromise objectivity; Chinese business hospitality norms differ — politely decline anything beyond working meals, and record it.
• Decline to “adjust” findings; if the company wants to challenge an NC, the route is evidence, not persuasion.