Performing an Internal Audit is a great way to make sure the cGMPs and preventive controls the Sanitarians and QA Managers have in place are consistently being followed. It’s also a good time to reevaluate those controls and see if they can be improved at all. We sat down with Shannon Sked, our Board Certified entomologist and resident food expert to discuss the best way to perform one of these audits. As a Certified Supplier Quality Auditor, Advanced SQF Practitioner, and PCQI, we thought he was the perfect person to ask.
Q: Shannon, thanks so much for talking with us about this very important topic. First, can you tell us why a food processing plant would want to perform an Internal Audit?
A: Internal Audits are designed to assess current programs and practices in the Food Safety Plan and to take corrective actions before having any other audits that can cause business or safety risks. The idea is to prepare the operation so that it’s always audit ready and no brand or safety risks are present in the plant. While these audits can take many forms, they should always include the stakeholders who are part of the Food Safety Team. If a plant is ready for internal audits, then they are helping to institute the principles of food safety into the culture of the operation. Simply complying with food safety standards is a thing of the past. In today’s FSMA environment, food safety elements are a cultural shift for those organizations that are processing, delivering, or storing food, food packaging, or ingredients for the supply chain. So in short, the greatest benefit of internal audits (if done frequently enough and with the correct intentions) is to create a culture of food safety with ALL the players on the team, including your service providers from pest prevention to sanitation and facilities maintenance.
Q: That’s great info! So, our next question is: how would a food processing plant perform one of these audits?
A: It starts with creating your Food Safety Team. The individuals on the team should come from various interests in the plant operations. They should include internal food safety professionals like QA Managers and Purchasing Managers to better understand the cost impact of not making safety-related purchasing decisions, leaders in the organization for management buy-in, an operations field employee to understand the impact of food safety where the boots meet the ground, sales professionals so they can find the value statements in safety, and of course your contracted staff such as pest prevention professionals, sanitation managers, etc. These people will all bring their own focus to what food safety means to your facility offering a full 360-degree perspective on the audit’s function. Once that’s done, I’ve always created a 2-phase approach to the actual audit: (1) document reviews to ensure compliance with all aspects of food safety from validation, verification, and root cause analysis/corrective actions and (2) physical plant inspections to look for where there could be gaps and to ensure that the documents reflect what you see on the plant floor (inside and out).
Q: Thanks for those details – it will certainly help someone who has not performed an Internal Audit before. Last question for you. What should plant managers do with the results of this audit?
A: That’s probably one of the biggest changes I’ve seen in plants that have taken on a culture of food safety. There is no real end to it. The days of marking off a checklist and making changes until each one has a checkmark next to it are a time of the past. Today, we look at audits (and Food Safety Plans) as living documents that reflect perpetually ongoing improvements in quality and safety standards. This includes the following:
- Conduct a root cause analysis on every non-conformity or opportunity for improvement noted. Use fishbone analysis or the 5 Whys of lean management to get to the underlying cause (in lieu of just correcting the surface-level issues).
- Follow up on the root cause with a reflective corrective action that will not only correct the issue but resolve the underlying cause so repeat non-conformities do not occur.
- Use the audit as a training tool to conduct real-time training for all employees that have a role in what was found.
- Validate that changes instituted are based on science and technology.
- Verify the correct actions in place are indeed working on the root cause identified.
- Alter the Food Safety Plan by documenting what was changed and why.
- Go back and test the system again with a follow-up audit.
A good example is our Food QA Audit we at Western Pest Services conduct for our customers at certain times. We do a full review of the entire Food QA Logbook and records to ensure compliance and the best practices we instituted are in place. We then do a physical plant inspection, not just looking at the pest prevention pre-requisite (although that is the focus of ours) but also other cGMPs and pre-requisite programs that are tangential to pest prevention (e.g. sanitation, facilities maintenance, capital improvement, etc.). The findings are documented as an audit form, placed in the book, and as non-conformities are analyzed and corrected, they are marked off and initialed complete by the technician and then verified by the supervisors. We retest the system later to ensure those actions worked as intended.
So, as you can see, the culture of food safety is one that is cyclical now and is surrounded in diligence. As this becomes customary, the culture of food safety becomes a part of everything we do, even though we are contractually responsible only for pest prevention. Our culture is one that says in order to obtain pest prevention appropriately for the food industries, we must have a focus on ALL areas of food safety.
Internal Audits sound like the first step in ensuring a food processing plant’s Food Safety Plan is in place and working. It also sounds like it can help fix anything that isn’t working well. You can fail an Internal Audit with less consequences and hopefully fix any weak points before being hit with an audit that could damage your business. Thanks to Shannon for sitting down with us and giving us such a detailed description of an Internal Audit.