TIPS FOR SUCCESS ON YOUR NEXT FOOD SAFETY AUDIT
So, you have a GFSI audit scheduled and you and your staff are nervous. Here are some tips to help in preparing for a successful audit.
As a food safety auditor, I have 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 would like to highlight what makes for a successful food safety audit.
The sites that perform best are those that have spent a great deal of time preparing. I was surprised during an audit, when I asked for a document and the QA manager and general manager told me that the last auditor never asked them for it.
“Are you working from the same standard? We’ve never heard of that. You are being difficult! And you auditors are from the same certification body!”
These comments were uttered during the 4th year audits of a standard. It was an indication that management may not have bothered to read the clauses that were not “interesting” to them.
While auditors work from the same food safety standard, during a two-day audit, it is 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 detailed preparation for your 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 shows a lack of preparation – we can even question management commitment on this.
Some major steps companies can take to have a smooth audit experience include the following:
- Get a 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. We were comparing applies and oranges. Some scheme owners provide free downloads of standards or one can invest in a soft copy or hard copy to implement a food safety program that not only meets the standard but also legal requirements. There is no excuse; get your copy of the food safety standard you will be audited against.
I’ve found it useful to write notes on my own hard copy. Some sites prefer to go paper free. However, they have not mastered how to quickly find information in a soft copy. Others state that their consultant has a copy, so that is enough. The HACCP coordinator and food safety manager are required to understand the standard and answer questions during an audit. One cannot rely on a consultant to answer questions. It is a major “test” in the audit. Do you know your programs well?
2. 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. I have heard stories like, “We didn’t have to do this because we had an actual recall and did some trace.”
Why would you resist doing a Mock Recall and traceability exercises? Taking short cuts would not allow you to test your systems to help in continuous improvement or during a crisis.
3. Train production staff and practice
If you must implement a new program, then staff should be trained and re-trained, so they are aware of changes.
Many sites conduct annual food safety refresher training in January and expect everyone to remember during the September audit, what was discussed at the beginning of the year. 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, an 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 asked, “What is HACCP and why is it important?”
Some QA managers are surprised when staff have no idea what to say. “We went through this before!”
The meanings of the acronyms may be in QA manager’s head, but has this knowledge transferred to staff? That is the question that should be answered BEFORE the auditor arrives
4. 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 is going on vacation the day after the audit, you would like to know that there is sufficient back up. This way, the food safety program does not 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 language use in communication onsite. You can also get a translator and practice answering food safety questions in the person’s native tongue
5. Ensure senior management is familiar with the company’s food safety program.
The first section of a food safety auditing program requires that senior management and owners know about the food safety programs in the company.
It is still surprising to me that many owners leave everything to QA and are not able to answer basic questions about the 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?
6. 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 have invested time and money in your food safety programs, why would it be necessary to act or do any stage performance 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 others for 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
7. Relax and Enjoy
If you have done the necessary preparation, even under stress, the audit will go very well. You will feel comfortable in knowing that no stone was left unturned and chances are, the auditor would only find a minor non-conformance of no significant food safety importance. The food safety audit could be a time to show off your company’s expertise, your staff’s commitment, and you amazing Food Safety Culture!
Enjoy your next audit!