"Audit" is not an endearing word. But a food facility audit need not be an anxiety-producing concept. In fact, audit preparation alone is a worthwhile opportunity to make sure your food processing facility and procedures are in tip-top shape. And if audits become a routine part of your food processing plant's operation, you'll sleep a lot better knowing you've made food safety a priority.
For those who missed Dr. Cordray's seminar, here are some takeaways worth noting:
- Take advantage of internal audits (monthly ideal but quarterly at a minimum) to keep your daily operations on track and help prepare for second party and third-party audits. Internal audits provide regular feedback on deviations and opportunities for improvement. Greater control equals greater opportunity for profit.
- Train and rotate your internal auditors.
- Document. Verify. Review. Have a written SOP noting how you will conduct your internal audit. Document the audit. Verify that procedures are followed (as per GMPs, SOPs, SSOPs and HACCP documents) and review all of these records. Verify also that you're using the correct forms.
- Pay close attention to personnel. Review and make sure employee training records are current. Dr. Cordray also recommends questioning individuals on the production floor. Ask them what they do and how they verify procedures.
- Tour the inside and outside of the food processing facility. Make note of any needed maintenance and repairs. Also, review corrective actions that have been taken since the last audit.
- Set improvement goals and review these plans during your internal audit.
- To prepare for a second-party audit, obtain a copy of the audit format and compare it against your internal audit format. Conduct a mock audit 2-4 weeks prior to the scheduled audit. Fix what needs to be fixed and document it.
- To prepare for a third-party audit (Quality and Food Safety/GMP, Food Defense, Animal Handling and GFSI Certification), conduct a mock audit 4-6 weeks prior to the scheduled audit. Again, correct deficiencies and document everything.
- When it comes to food defense, consider not only building security (cameras, key and electronic access, etc.) but documentation, traceability, crisis management and staff training to recognize disgruntled employees, etc.
- Global Food Safety Initiative (GFSI) is a sophisticated third-party audit. GFSI is not regulatory, but provides "increased assurance that a company's products are safe."
- Details regarding audits prompted by the FDA's Food Safety Modernization Act (FSMA) are coming in the near future.