Audit Tips: How to Think Like an Auditor and Avoid Risks, Fines, Shutdowns

A compliance audit is often an anxious time for a food and beverage facility manager. The last thing that manager wants is a shutdown, let alone one that could have been avoided by making a simple proactive coatings repair, for example. Yet, violations of the Food Safety Modernization Act (FSMA) flagged by a third-party compliance auditor are common and can lead to major operations interruptions if the problems cannot be remedied quickly.

The likelihood of flagged issues and stalled operations has risen in today’s environment of higher industry standards. This is evident in the amount of product flagged for contamination. Foreign-material contamination caused 23% of all recalls in 2018, up from 7% in 2015, according to a report published in The National Provisioner. Has the industry become more lax about allowing contaminants into food products? No; the more likely interpretation is that today’s stringent regulations lead auditors—and facilities themselves—to catch potential dangers previously left unchecked.

With companies of all sizes now in compliance with the more rigorous FSMA, the question becomes how well they can maintain these standards. That will be determined, in part, by company culture. In some companies, teams will do the minimum to remain compliant, making incremental updates just before an audit or emergency corrections thereafter to avoid a shutdown. This may be especially true for mid-sized companies, where a plant manager does not have the time or expertise to identify the optimal coatings products to fix specific conditions, for example. Most generalist facility managers will not know which floor coatings offer a fast return to service to minimize downtime or which wall coatings are the most durable against chemical washdowns.

However, in other companies, teams will adopt a more proactive approach. The facility manager will not wait for an auditor to point to a problem or learn on the fly how to repair an area. Instead, the manager will work with stakeholders and a third-party coatings expert, for example, to spot not just current violations, but also future vulnerabilities, and to develop proactive repair specs so the facility can address any deficiencies before they become an issue. As such parties anticipate how a facility could someday risk contamination or hazards, the facility manager will not only minimize the facility’s chance of FSMA infractions but will also create long-term peace of mind.

Four Key FSMA Audit Areas

One way for a facility manager to plan ahead is to take on the mindset, and even the checklist, of an auditor. By performing self-assessment walk-throughs that consider hazard analysis, sanitation, equipment preservation, and warehouse and distribution matters, the manager will mirror the checklist an auditor uses when visiting sites. This approach allows the manager not only to see current problems, but also to envision and create a strategy for future issues. By inviting a third-party coatings expert to participate in the assessment, the facility manager can better identify potential vulnerabilities, learn what products will enable fast returns to service and long maintenance intervals, and develop a proactive plan for making repairs.

1. Hazard Analysis & Controls

Personnel, hand carts, forklifts, and other machinery create heavy traffic throughout a facility, so one aim of a FSMA audit is to minimize the risk of employee injury. A coatings specialist can be especially helpful to a facility manager here by suggesting products that will limit injury risks related to slips from flooring hazards or burns from hot surfaces.

Slips and falls are among the primary hazards to employees. Although FSMA does not set any specific floor skid-resistance standards, a facility manager will want to work with a coatings specialist to determine what surface treatments can reduce the chance of unfortunate incidents, yet still meet other facility objectives. Skid-resistance options range from aluminum oxide to sand to a quick-texture system, a splatter coat created by a hopper gun. The latter is especially advantageous, as it establishes skid resistance, but without the pointy profiles that occur with other broadcast aggregates. The rounded, quick-texture profile allows better drainage following wash-downs and is potentially more durable, as pointier profiles created by other aggregates may break off over time.