Audits should never come as a surprise. The Food and Drug Administration could arrive at any time for a food safety inspection. Or a customer may require an audit from the Safe Quality Food (SQF) Program or the British Retail Consortium, which are both recognized by the Global Food Safety Initiative (GFSI). Quality assurance/control managers — and all other employees — must be aware of food safety regulations and remain ahead of the curve.
“Depending on the type of audit, assessments generally include quality systems review, validation/verification activities and housekeeping, or good manufacturing practices (GMP),” said Dominic DeBlasio, vice-president of quality assurance and food safety, Hearthside Food Solutions, Downers Grove, Ill. “Typical internal and external audits cover incoming ingredients, in-process manufacturing, warehousing and logistics.”
Customers seem to be requiring more audits, and they apparently are getting more involved, said Jesse Yachouh, director of quality control and food safety at Clifton, N.J.-based International Delights.
“The GFSI umbrella of food auditing systems such as SQF, BRC and Food Safety System Certification 22000 is a recent requirement that is gaining attention,” he said. “Even the basic GMP audits are getting more intense.”
To ensure it doesn’t miss any rules, International Delights reviews all manuals of the certified organizations doing its audits.
“We review the requirements — and they’re pretty extensive,” Mr. Yachouh said. “Then if we have any questions, we contact the organization for clarification.”
In addition to external auditing, baking and snack companies can conduct a self-assessment, or internal audit, at least once a year. This action can uncover food safety negligence or how internal requirements can further be improved before being audited by a second or third party.
Going back to the beginning
Preparing for food safety audits includes validating suppliers. This can be done in a few ways — a third-party audit or onsite one — depending on risk assessment and geographical location.
Schaumburg, Ill.-based Gonnella Baking Co. relies on a Supplier Management Software, third-party/GFSI certificates and self-audits, according to Alicia Pulings, quality compliance manager, Gonnella. The company also does onsite audits for suppliers who are high-risk or critical to its operation.
When it comes to approving new suppliers, International Delights first sends questionnaires that ask about operation specifics. The company also requests a list of documentation: specifications of the product, letters of continued guarantee, certificate of insurance, safety data sheets, letters of origin, valid third-party audit certificates, GMP programs and internal training proof as well as any non-G.M.O. records and special diet considerations like kosher.
International Delights also makes inquiries about the supplier’s Hazard Analysis and Critical Control Points (HACCP) program and Food Safety Modernization Act (FSMA) compliance process, including preventive controls, Pathogen Environment Monitoring and allergen control programs.
“Certificates of analysis are further verified by sending samples to independent labs for testing,” Mr. Yachouh said. “You need to check certain ingredients for potential adulteration. There are some ingredients that have the potential for adulteration, for example, honey, milk, olive oil and spices.”
Mr. DeBlasio said he has noticed that the supplier-approval process is easily overlooked by companies. Hearthside uses TraceGains Inc., a quality management software, which he said is beneficial for showing the company’s approval process.
An additional challenge comes from customers requiring social compliance audits.
“The trend we’re seeing with large retailers is the adoption of social compliance standards to eliminate intolerable working conditions or environmental hazards resulting from the manufacture of consumer goods in countries where regulations are not as common and employees can be exploited,” Ms. Pulings explained. “While most social compliance requirements are easily achievable in the U.S., the standards we have seen recently are not suited for a one-size fits all approach.”
To stay on top of audits, baking and snack companies should ask their customers if they have specific requirements, audit suppliers and review all instructions — and they must train employees.
More than a crash course
Quality assurance/control specialist positions aren’t always easy to fill. The amount and variety of necessary training can be extensive and includes experience with FSMA and GFSI, along with a Preventative Controls Qualified Individual certificate.
“It is very difficult to find knowledgeable and qualified quality professionals in general,” Mr. DeBlasio said. “It could take six to eight months to fill a quality assurance management position.”
International Delights prefers its quality control specialists to have a degree in a scientific discipline such as biology, chemistry, food science or microbiology in addition to previous experience in the food industry.
“A quality person needs to be detail-oriented and able to work independently as well as within a team,” Mr. Yachouh said. “This is a multitask position where you will be dealing with various departments. Therefore, good communication skills are important.”
Many companies promote more specific training. Gonnella requires its quality assurance managers to have an internal auditor certification. But rather than this being nonnegotiable when hiring, the company is willing to teach employees this specification as long as they have the other major qualifications.
Sometimes, despite training and experience, food safety personnel will need additional expertise. This is where a third-party consultant comes into play.
“With all the new regulations and requirements, it’s good to leverage a third party for assistance when needed, such as consultants and academic experts,” Mr. Yachouh said. “For specific technical inquiries, academic staff are very helpful.”
Preparation for audits isn’t just left to quality assurance/control management though. Line operators and supervisors should also be trained in certain areas to have confidence during audits. Hearthside Food Solutions teaches all hourly employees routine allergen control, HACCP and GMPs.
International Delights trains all employees periodically. New hires are trained in the following: GMPs, sanitation and food safety, HACCP/FSMA, allergens, food defense, ingredient adulterations and Hazard Communication Standard — or HazCom. Lastly, employees are instructed in record keeping.
“It’s important to keep good and clear records,” Mr. Yachouh said.
Good documentation includes filing employee education.
“Auditors have consistently asked for evidence of training,” Ms. Pulings said. “While auditing our internal audit records, they specifically ask for the training records of the person who performed the internal audit.”
Not only is proper training in record keeping audited, but it’s key to keep a company on its toes.
The cycle of compliance
There isn’t a start and end point to an audit program; rather, actions are taken on a daily, weekly and monthly basis.
“We verify sanitation daily with swabbing and test for allergens frequently,” Mr. Yachouh said. “We conduct our own internal audits such as food safety and GMPs and are audited annually by a third-party auditing body for SQF certification. One out of every three years we have an unannounced audit.”
To keep this continual process in line, regularly updated documentation is crucial. All records should also be in a central location so that when an auditor arrives, the company doesn’t have to search for the proof of compliance.
“As food safety compliance becomes more complex and tedious, it’s important to have all your documentation organized, paperless and easy to present to an auditor,” said Ryan Mead, sales manager, Focus Works.
The SQF-Sentinel from Focus Works, Inc. collects all inspection and maintenance data on a table or computer to verify employees have finished compliance.
“This allows auditors to see exactly when each task was done, if there was a noncompliance and the corrective action that was taken in the event of the noncompliance,” Mr. Mead explained.
The technology can also be integrated with temperature probes, ovens and metal detectors, and this information is automatically processed into a report for an auditor.
With requirement changes being inevitable, employees should always double check that they have the latest version of forms, so an old form doesn’t slip by.
Ms. Pulings calls it “the dreaded uncontrolled document.” Using an old form often occurs when employees make copies of the documents or procedures that aren’t updated. She suggested retrieving the forms directly from the document control software to ensure a current form, allowing a company to be audit-ready 24/7.
It never hurts to go above and beyond what’s required.
“Start early, be organized and have the tools you need to be compliant with food safety standards in place,” Mr. Mead said. “So when the audit does take place, nothing is a surprise.”
Article via Baking Business https://www.bakingbusiness.com/articles/48264-bakeries-take-on-audits-in-the-new-era-of-food-safety