What to Expect When Expecting a Consultant

Documentation.

• Program review and/or development. During the course of a visit, the consultant will likely ask to see programs germane to the production environment. Program revisions and development are to be expected. One program that is likely to be developed is a Corrective Action/Preventative Action plan that describes and documents practices that immediately correct and further prevent/mitigate a harborage (or other situation) from occurring in the future. This program can, and should, be applied to all other departments as well.
• During the testing phase while waiting for microbiological results is a good time to reassess the HACCP plan. The entire HACCP team will need to be available for this portion of the process.
• The end result of any project is a detailed written report provided by the consultant. In lieu of a report, a letter to the FDA or USDA answering a 483 or Notice of Intended Enforcement/Notice of Suspension, respectively, may be written by the team. If a report to the company is written, it should include background, scope, and outline the findings and next steps of the project. The report, generated in a timely manner, would be expected to include procedures and policies developed or reviewed by the consultant. These documents become the property of the company, which will approve programs, train employees, and implement the procedures. The documents are to align with the company’s current document control policy.

With the Food Safety Modernization Act regulations underway, some companies are seeing gaps in their current programs, especially related to their food safety, sanitation, and HACCP plans. Having a set of fresh eyes look at systems may be of tremendous value. Consider having a food safety professional visit the company. However, setting expectations before, during, and after the visit will improve the outcome of the exercise and experience.

Dr. Deibel is director of microbiology for Covance Food Solutions. Reach her at [email protected]. Baldus is lead trainer/microbiology consultant for Covance. Reach her at [email protected].