How to prepare for a GFSI food safety audit
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So you have GFSI audit scheduled and you and your staff are nervous. Here are some tips to help in preparing.
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As a food safety auditor, I’ve had the opportunity to visit many companies in the Americas and Europe to review their HACCP plans, GMPs, good agricultural practices and other programs. In recent years my clients have shown varying degrees of readiness for audits and in this blog I’d like to highlight what makes for a successful BRC food safety audit.
The sites that perform best are those that have spent a great deal of time preparing. I was surprised when I asked for a document and the QA manager and general manager told me that the last auditor never asked them for that.
“Are you working from the same standard? We’ve never heard of that. You are being difficult! You auditors are from the same certification body!”
These comments were uttered in the 4th year of the standard which was a clear indication that management may not have bothered to read the clauses that were not “interesting” to them.
I could never speculate on the reasons. While auditors work from the same food safety standard, in a two-day auditor it’s not possible to review every clause in the standard. The audit is thus a sampling of the food safety requirements and each auditor may do a slightly different sampling.
If you have done a detailed preparation for the audit, then you would never be surprised by any requirements. There would be no need to make up excuses and cast blame on anyone. Blaming others for not knowing clauses in the standard is a clear indication of lack of preparation – we can even question management commitment on this.
Five main steps include the following:
- Get a hard copy of the up-to-date standard
It’s important to have an up-to-date copy of the standard. I once went to audit a site and the general manager was working from a hard copy of version 6.0 while being audited against version 7.0 of the food safety standard. Since BRCGS is now offering free downloadable copies of the standard from their website, one can have no excuse for not owning a copy.
I’ve found it useful to write notes on my own hard copy. Some sites I’ve visited refuse to print a hard copy; however they haven’t mastered how to quickly find information in a soft copy. Others state that their consultant has a copy, so that’s enough. However if the HACCP coordinator doesn’t know what’s in the standard and is waiting for the consultant to answer questions, what is the benefit?
- Start preparation many months in advance with detailed internal audits
Conducting detailed Internal Audits against the food safety standard are the best way to ensure that all conditions are met. This is the most important step in preparing for the audit and detailed audits should be spread over many months to prevent overload. In addition, a team of trained internal auditors would be beneficial since several eyes would be able to critique you programs.
Every clause in the standard should be considered. “Have we met all the conditions in this clause? If not, what is missing?”
Once a non-conformance is identified, corrective actions should be implemented immediately and verified by QA and the responsible parties to ensure all conditions are met.
Systematically looking at all clauses in the standard will prevent surprises during the audit.
If the standard asks for metal detectable bandages in a colour that is easily identifiable, you should not decide that you’re not going to do this because you don’t have a metal detector. What about your end user. If you’re manufacturing ingredients, your customer may have a metal detector and be able to catch a chance bandage that had fallen into a bag of product. Follow the requirements of the standard. They were created by a host of industry stakeholders for many reasons which may not be evident to you and your business.
The standard asks that you conduct traceability exercises during the year on each product group. Why would you resist doing this and tell the audit that you had a REAL RECALL, so you don’t need to do a test? This short cut answer does not impress anyone and doesn’t demonstrate that your company is able to function during a crisis.
- Train production staff and practice
If you have to implement new program, then staff should be trained and re-trained so they are aware of changes.
Many sites conduct annual food safety refresher training and expect everyone to remember at the September audit, what was discussed in the January refresher training. This generally doesn’t work unless you have ongoing evaluation and reinforcement programs.
If it’s possible to do continuous assessment and retraining during the year then this should be done. In addition a refresher training and assessment before an audit would prevent surprises like the employee freezing when asked a question. I remember asking one person who was responsible for monitoring CCPs what did the letters CCP stand for. I also ask, “What is HACCP and why is it important?”
Some QA managers are surprised when staff doesn’t know what to say. “We went through this before!”
The meanings may be in QA’s head, but has this knowledge transferred to staff? That is the question that should be answered BEFORE the auditor arrives.
- Train back up staff for key roles
Suppose the QA manager is ill during the audit, does everything have to stop? It’s necessary to have alternate staff for various functions and people who are familiar with various QA roles. If the QA manager announces that he’s going on vacation the day after the audit, I would like to know that there’s sufficient back up. This way, the food safety program doesn’t default to zero for a week or two.
Key staff can explain simple food safety concepts if they are well trained and they practice. I’ve heard some non-English speakers explain CCPs and food safety in a nutshell after rigorous training.
“He doesn’t really speak English” is not an appropriate excuse if this is the main form of communication onsite. Get a translator and practice answering food safety questions in the person’s native tongue.
- Ensure senior management is familiar with the company’s food safety program.
Section 1.0 of the BRC standard requires that senior management and owners know about the food safety programs in the company.
It’s still surprising to me that many owners leave everything to QA and are not able to answer basic questions about the BRC standard and the programs implemented at their site.
If the general manager or owner doesn’t know and appreciate the food safety requirements of the standard, then how could he provide funds to run programs effectively?
- Book your audit when you think you are ready
Many companies book their audits during the audit window and hope to “wing it” by hiding facts from the auditor and putting on a “good show”.
Extra staff from other sites are brought in to answer questions and a consultant is asked to sit in the audit to answer any question the staff has no clue about. This shows desperation on the part of management at a company. If you’ve invested time and money in your food safety programs, why would it be necessary to act, lie or do any stage performing during an audit? Many auditors can see through a well scripted performance or the warm printed page of a brand new SOP fabricated in five minutes during the audit. Blaming an auditor for your lack of preparation; not implementing documented risk assessments for your programs, and forgetting to train staff, would not improve food safety at your plant. In the end, the consumer could suffer.
- Relax and Enjoy
If you have done the necessary preparation, even under stress, the audit will go very well. You would feel comfortable in knowing that no stone was left unturned and chances are that the auditor would only find a minor non-conformance of no significant food safety importance.
Enjoy your next audit!
Here’s a great reference on SLIDE SHARE