Is Your Plant Ready for a Third-Party Audit?
Fresh Cut
November 2004
Practical Advice from a Professional Auditor
By Andrew Flanders, Ph.D.
The Steritech Group
From farm to fork, the food industry has made significant
food safety gains in recent years as processors, retailers and consumers
increase their awareness of food safety issues. As regulations have tightened,
food processors, restaurant chains and retailers are increasingly using
audits as a means of ensuring that they comply with these mandatory requirements
as well as those of downstream customers. As a result, our food supply
has become safer, and food safety problems have become easier to track
and manage.
While meat, fish and dairy processors have been typically considered "higher
risk" industries than the fresh cut produce industry, produce is
now no longer considered low-risk, as evidenced by a number of high-profile
food-borne illness outbreaks associated with fruits and vegetables. The
fact remains that, even with the improvements being made, food safety
concerns still exist, and food-borne illnesses continue to occur.
Biological (or microbiological) hazards are of primary concern to the
fresh produce industry. Processing plants may receive their produce from
a number of different farms, increasing the risk that different soil-borne
pathogens may be present, including E. coli, Salmonella sp and hepatitis
A. Poor handling procedures, inadequate cleaning and sanitation, and contaminated
water increase these risks at the processing plant. And, fresh produce
processors - like other suppliers and retailers in the food chain - continue
to remain "at risk" for cases of deliberate tampering and/or
bioterrorism.
Unfortunately, it can be difficult to determine the exact frequency of
food safety problems and food-borne illness outbreaks, because many food-borne
illnesses - particularly the mild or minor cases - are seldom reported.
However, most experts agree that the number of cases is much higher than
the statistics show. It is therefore important that fresh-cut fruit and
vegetable processors recognize that they must implement the same type
of sophisticated food safety and sanitation programs as in other segments
of the food industry.
One way fresh produce processors can improve their food safety programs,
comply with government regulations and meet their customers' vendor assurance
programs is by implementing a regular schedule of independent food safety
audits. Increasingly, buyers of fresh produce (often the major retailers)
are doing this at the producer and processor levels. Such audits will
identify food safety problems and help to chart a course of corrective
action for continuous improvement.
Preparing for an Audit
Buyers of fresh produce are now engaging reputable, third-party auditing
firms as a first step in qualifying their new suppliers and maintaining
their existing ones. When evaluating auditing firms, check for depth of
experience. Does the firm specialize in food safety audits, or are such
audits simply one in a laundry list of services the company provides?
Does the auditing firm use only in-house auditors, as opposed to "contract
labor?" Evaluate the firm's and auditors' knowledge of food safety
issues. How are their auditors trained and certified, and how often? Are
they current with the most recent FDA Food Code as well as local and state
regulations? How well do they understand and accommodate the specific
needs of your company?
The best auditing firms use a combination of local, state and federal
regulations as well as customer "best practices" to develop
a custom auditing system specifically for your needs. Consistency and
calibration are key. It is important that the auditor inspecting a facility
is using the same criteria, approach and consistency as an auditor evaluating
another facility across the country. Also, find out how long it will take
to issue the final report. Waiting days or even weeks may be too late.
Producers or processors undergoing the audit should make sure their food
safety systems are well designed, completed and fully implemented. Because
third-party audits can be either announced or unannounced, don't place
yourself in the position of doing everything you can to pass at the very
last minute. Instead, embrace the concept of "constant readiness"
in terms of quality assurance and quality control system implementation.
After all, ensuring that safe and wholesome food is delivered to your
clients and their clients is your responsibility. Readiness should be
an integral part of your day-to-day business.
Over and above meeting regulatory requirements, understanding the expectations
of your customers, who may be mandating and paying for the audit, is essential.
These expectations are pivotal in the customer's vendor assurance program.
Most of your larger customers will probably have their own set of requirements
and specifications. Make sure you know what those requirements are well
in advance. This gives you time to review and understand what the company
considers important, revisit what you are doing, and then check to see
if any critical procedures are being overlooked. Do an internal audit,
or use a third-party audit company to conduct an assessment before the
scheduled audit.
While every audit is different, most typically look at the overall condition
of your facility, including processing and employee restroom/break areas.
The audit will most definitely review the processor's Hazard Analysis
Critical Control Point (HACCP) plans, Good Manufacturing Practices (GMPs),
allergen control program, cleaning and sanitation program, pest control
practices and recall system. It will likely review how you evaluate and
approve your suppliers. Ask yourself: Have the CCPs (Critical Control
Points) been properly selected and are they being monitored exactly according
to the HACCP plan? Is your pest control program adequate? If not, now
is the time to call your pest control company to update or upgrade your
program. Are your metal detectors working properly and currently calibrated?
Are employees and management adequately trained in safe food handling?
Do they practice what they've been taught?
It is important to keep in mind, however, that while a food safety audit
is a snapshot in time, you should assume that every single aspect of your
operation could be audited at any moment.
The Importance of Procedures and Records
We say: "Do what you write, and write what you do." Your GMPs,
training, sanitation and HACCP procedures must be fully documented, and
comprehensive records must be kept. This is the only way to prove to your
customers that you have a systematic approach to food safety. Shipping/receiving
data, temperature control, plant condition and maintenance, pest control
data and details of cleaning and sanitation are just some of the records
you should be keeping. Food safety procedures and training are often overlooked.
Make sure you have written programs, and remember to keep details of training
courses, attendees and test scores. The auditor will want to review historical
data -going back at least 12 months.
If detailed records are not in place, there's no time to start like the
present. An auditor will recognize when you are making an effort to implement
sound practices and that doing so is now a part of your day-to-day operations.
Most processing plants will have some deficiencies-at least during an
initial audit. It is important that any known deficiencies be identified
(and not hidden) and a plan of action to correct them is in place and
documented. Any critical deficiencies would normally need immediate attention.
Continuous improvement of all your safety procedures should be a part
of your corporate culture. Indeed, one of the key elements of any food
safety audit should be the development of a plan for corrective action.
Subsequent audits will evaluate your progress in those corrective action
areas.
Whether the audits are being driven by the processor or the processor's
customers be open with independent food safety auditors. Remember, they
are working on their client's and your customer's behalf. They are not
there to hinder business relationships by finding problems. Their purpose
is to help facilitate business and establish partnerships of trust through
objective and timely reporting. Use their knowledge of best practices
within the industry. Take advantage of their consistent, calibrated approach
to food safety. In the end, you will be in a better position to ensure
the safety of the produce you supply. Safe food is simply good business.
Editor's note: Dr. Andrew Flanders, Miami, Fla.,
is an experienced consultant and auditor with The Steritech Group, a leading
third-party food safety auditing company based in Charlotte, N.C. The
Steritech Group will conduct more than 30,000 food safety audits in 21
countries during 2004. As vice president of National Accounts, Dr. Flanders
helps companies design, develop and implement their food safety programs.
He is also responsible for training and calibrating other Steritech auditors.
Steritech can be reached at 1 (800) 868-0089 or via the company's Web
site at www.steritech.com.
© 2004 Columbia Publishing
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