Lessons Learned from GFSI Audits

Maintenance: A common finding is the use of tape for temporary repairs, a practice that jeopardizes food safety. After maintenance operations, most standards require a clearance to ensure that equipment is clean and that no parts or tools remain. When buying new equipment, keep all food grade certificates provided by the machinery provider. Make sure that the maintenance department monitors steam and compressed air.

Staff facilities: Most GFSI standards require clear segregation between outdoor clothing and work clothing. A regular and thorough inspection of locker rooms is needed to ensure compliance with this clause.

Chemical and physical contamination: Chemical auditors usually observe unlabelled containers and missing MSDS. The most common contamination issues are glass registers that are hard plastic or are not regularly checked.

Pest control: These requirements are usually very detailed in GFSI standards. A close reading of the standard should allow you to dodge the traps. Auditors often observe the lack of trending and outdated bait maps.

Product Control Issues

For the GFSI standards considered product certification (vs. system certification), auditors will strongly focus on product compliance.

Product design: New products should undergo a hazard analysis prior to being placed on the market. Because product legality is also part of the audit scope, labeling must comply with regulations of destination countries.

Allergens and similar: Even though the trend is toward allergen avoidance, keep record of the training course for staff who handle some of these materials. Ensure that your reworking rules and practices are not compromising allergen status.

Product packaging: Packaging material must be suitable for food, and the related certificate must be readily available to the auditors. On the floor, ensure that partial boxes/pallets of packaging material are properly protected before returning them to storage.

Product inspection and testing: Whether testing is performed on site or contracted, react quickly when results are not satisfactory. Too often we observe test results without interpretation or a pass/fail conclusion. Testing reliability should also be ensured through proficiency testing and accreditation of laboratories. Some standards require an ongoing assessment of shelf life.

Nonconforming product: GFSI standards aim to prevent nonconforming products—whether in raw material, packaging, test kits, or finished goods—from proceeding in the manufacturing process. For this purpose, all nonconforming products should be identified as such. Furthermore, the correction (what you did with the product itself) and corrective action (what you did to avoid recurrence of the issue) should be recorded.

Process Control Issues

Product quality control relies on testing and on process control. For example, continuous monitoring devices such as metal detectors should be tested, and appropriate records should be available. Calibration is sometimes overlooked, but many findings could be prevented with a thorough reading of standards requirements. Make sure your measuring equipment is properly identified with up-to-date calibration status. In addition, GFSI standards demand that you investigate the validity of previous measurements in the event of unsatisfactory calibration results. This requirement is often misunderstood or forgotten.

Personnel Issues

Product quality and safety cannot be ensured without properly trained and competent staff.

Training: Be prepared to show training records for hygiene, food safety, and handling of allergens. Not knowing exactly where all these records are kept could cost you some easily preventable findings, maybe even minors. GFSI standards require a view of the effectiveness of training courses. These training courses can range from a traditional quiz that ensures understanding (but not efficiency) to the yearly performance review with supervisors.