Ensuring the Integrity of a Food Safety Program

An internal audit should include:

• • Assessment of the procedure for any needed changes and to ensure it meets regulatory and certification requirements;
  • Observation of the operation on the production floor, on all shifts;
  • Completion of staff interviews to confirm their understanding;
  • Review of training records to verify staff are suitably trained per program requirements;
  • Review of through sampling of records of the program, looking for any relevant trends or issues that have arisen;
  • Evaluation of customer or consumer complaints that looks for anything relevant to the program; and
  • Consideration of any other processes potentially affected by this one, and review those programs as well if relevant.

A thorough internal audit, like described above, is a great way to validate a program—thereby ensuring a high level of confidence on the controls’ effectiveness.

Actionable Takeaways

Get the whole food safety team involved, and others if relevant. Validation isn’t something one person can do on their own, it takes a comprehensive approach that only a team can provide.

Validate the program as a whole when it’s first created, then at least annually thereafter or on any significant changes.

In order to validate a plan as a whole, review all programs first. Then take a look at everything together and judge if the program is working as designed.

Validating controls means reviewing any potential hazards in the ingredients or raw materials, finished products, and processes. Follow the HACCP approach:

• Identify any potential hazards—do this thoroughly, using relevant resources;
• Evaluate significance of each hazard—determine what sort of control is required;
• Identify the right control—evaluate what is currently in place to confirm it’s the appropriate control;
• Set up critical parameters for each control, and implement programs for monitoring, corrective actions, and verification; and
• Reference FDA’s guidance on the Preventive Controls rule, particularly Appendix 1.

In addition, create a schedule for all verification and validation activities for the year, and issue assignments to responsible parties (activities should be saved on employees’ calendars). This needs to be a team approach. If another meeting or activity takes precedent, make sure the event is rescheduled, not ignored.

Kimble, the senior food safety manager for Safe Food Alliance, leads voluntary facility audits in the SQF, HACCP, and Costco schemes. Reach him at [email protected].