Survival Guide for Avoiding Common Audit Mistakes

Without a sustainable management system, the results of your hard work toward meeting the requirements of SQF, BRC, or FSSC 22000 certification could begin to degrade between routine audits. With so much at stake and competing demands from regulators, customers, and consumers, securing a sustainable Global Food Safety Initiative (GFSI) system can be a challenge.

The following guidelines can help your company stay audit-ready 24/7 while continuing to advance your GFSI systems.

Robust GFSI Internal Audits

GFSI standards require an internal audit of the entire system at least once per year. Prudent companies manage internal audits on a set schedule. Start by dividing sections of GFSI code, and then schedule an internal audit of each section on a monthly or quarterly cadence. Be sure that your schedule enables you to cover the entire code over the course of the year. By auditing smaller sections of the code on a more frequent basis, internal teams can take more time to assess programs, analyze records, and review facility conditions as necessary. It is important for internal auditors to be properly trained on what to look for, how to record results, and how to follow up on possible corrective actions needed. As a best practice, have a third party complete an internal audit of your system prior to your recertification audit. External resources will provide an objective view and assure all programs are at their best.

Detailed Plant Inspection Internal Audits

In addition to the GFSI system audits, detailed plant inspection audits should be conducted based on risk. This typically includes monthly inspections of processing audits. These inspections include assessments of Good Manufacturing Practices, product handling, and facility condition. Detailed plant inspections and internal audits help promote continual compliance with GFSI standards.

Verification/Validation of Prerequisite Programs

GFSI standards require all prerequisite programs, such as sanitation, maintenance, calibrations, pest control, and others, be verified and validated at least once a year. The verification process should include a review of the written food safety program, records and supporting evidence, and documented plant inspections. The validation process should include a review of test results, customer complaints, non-conforming products, and other relevant information to ensure the program is achieving and maintaining the intended control over identified hazards. Prudent companies set schedules to verify and validate a certain number of programs each quarter.

Automated Program Management and Recordkeeping

Companies should seriously consider taking advantage of automated food safety and quality management systems to sustain GFSI compliance. Companies must adopt 21st-century methods and technology to provide QA departments with the ability to manage the massive number of programs and the amount of critical documentation associated with food safety and quality assurance systems. An electronic, cloud-based system can save time and make complex recordkeeping much simpler. Companies often already have systems for enterprise resource planning (or ERP), preventive maintenance, and master sanitation schedules. QA departments should employ similar tools to organize and manage food safety programs, maintain records, and drive internal auditing efforts.

Comprehensive Food Safety Plan Reassessments

Annual food safety plan reanalysis or Hazard Analysis Critical Control Point plan reassessments are not completed by simply changing the date on a cover page—something auditors see all too often. Food safety plans must be kept up to date throughout the year. Be sure the plans incorporate any changes related to new ingredients, finished products, or equipment. During the plant’s annual review process, the entire food safety system should be reviewed and audited to verify that the plan is being followed as intended. The plan must be written correctly and validated with testing to demonstrate control over identified hazards. When completing the reassessment process, review all written programs for accuracy. A detailed plant inspection and audit of critical control points or preventive controls must be performed to show compliance with the food safety plan. Finally, confirm the consistent implementation of your food safety plan with a review of all related records from the past 60 days. Take the time to scrutinize whether or not adequate corrective actions have been taken where needed. Once all this information has been gathered, submit a reassessment report with a complete summary of all changes made as a result of the reassessment.

Effective Management Reviews

GFSI standards require regular management reviews. These management reviews must consider the GFSI policy manual, internal and external audit findings, customer complaints, and corrective actions. As a best practice, management reviews should happen quarterly. During that time, assess the results of the GFSI system with a trend analysis then compare current results with prior periods. This helps identify areas that need to be addressed immediately to repair deficiencies or negative trends, as well as areas for continuous improvement. Management reviews must engage senior leadership so they are aware of the GFSI system performance and can provide additional resources as necessary.

Coordinated Change Management Procedures

Products, formulations, equipment, and other assets change rapidly in most manufacturing plants. There must be a coordinated change management process to assure these changes are communicated to all necessary parties. Be sure that modifications are properly documented, verified, and validated in the GFSI system, and confirm all changes have been fully implemented throughout the company.

Positive Food Safety Culture

Continuous audit readiness cannot be achieved without a positive food safety culture. Top management must share vision and commitment. All employees must be trained on not only what to do, but why they need to do it. This approach solidifies employees’ commitment to follow programs and handle products properly all the time, whether there is anyone watching or not. Perform food safety culture assessments routinely to measure and drive continuous improvement.