At a minimum, a food safety/GMP audit should cover the following: Food safety programs and training, pest control, operational conditions, building and equipment conditions, building and equipment cleanliness, and food/plant security. The food/plant security portion should cover management of food security, raw materials and packaging, finished products, facility security, employee security, computer security, water and air security, laboratory security, and chemical security.
GMP audits and other food safety audits at the processor level are much more complex than those carried out at the retail level. While retail food products are generally purchased and consumed shortly after arrival at the retail location, products from processors can remain in the food chain for up to a year. Thus, the safety of those food items must be ensured for their entire shelf life.
While comprehensive retail-level food safety audits typically take a half day or less to complete, the complex nature of food processing means that GMP-level food safety audits may take as many as four to five days to complete. A large percentage of that time is spent reviewing the documentation for a plant’s HACCP and GMP programs and making sure that those programs are not only properly documented, but properly implemented as well. Microbiological testing, which remains rare at the retail level, is another important component of GMP-level food safety audits.
Concurrent with the changes in the type of food safety audits being conducted, auditing technology has evolved as well. Until recently, processor audits were decidedly low-tech affairs. Auditors used pen and paper to take notes during an audit session, and facilities generally needed to wait for days or even weeks to receive a written evaluation and report. Today, handheld computers, portable printers and the 24/7 nature of the Internet allow detailed information and final reports to be shared with the audited facility and/or its customers immediately, sometimes even before the auditor has left the premises.
In addition to expediency, technology affords the ability to slice and dice audit data in a variety of ways. C-suite denizens can view top-line and trend data, while plant and department managers can drill down for more details in order to target specific corrective actions.
Ultimately, the quality and value of an independent GMP or any food safety audit depends to a great degree on the quality, calibration/consistency and expertise of the individuals involved.
The best auditors have advanced degrees in microbiology, chemistry, environmental health, food science, dietetics or nutrition as well as food safety training and certification from an organization such as the National Environmental Health Association (NEHA).
For GMP audits, advanced GMP training, coupled with subject matter expertise/ experience and commodity certification (dairy, low-acid canning, USDA meat and poultry, etc.), help ensure that the auditor has the necessary technical expertise.
Consistency and calibration should be hallmarks of the audit process; standards must be interpreted consistently and should follow written audit protocols. For example, the auditor should have written instructions and clear explanations behind policies for each audit line item. The audit process also should be consultative and educational, with a strong emphasis on process improvement. Corrective actions should be recommended and those areas should be re-inspected at a subsequent audit.
In an April 18, 2005 USAToday article, USDA and FDA officials credited the recent decline in rates of food-borne illness to “strengthened scientific testing and safety plans, [as well as] increased training and oversight in factories that produce food.” Such oversight – in the form of independent GMP and Quality Assurance audits – will continue to be a key factor in ensuring both a safe food supply and a sustained decrease in food-borne illnesses.
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