Ask anyone involved with food safety in the food and beverage industry and you will hear one uniform concern: Audits. The sheer number of audits – customer audits, GFSI audits, FDA audits, and the work involved in preparing for them. Of course, there is also the worry that despite preparation things will not work out as planned on the actual day of the audit.Companies will often hire a third-party firm to conduct audits of their facility, in the interest of being well prepared for these many audits they receive throughout the year, or to meet customer requirements in the hope that they may reduce the overall number of audits. With the abundance of different types of food safety audits, and the many organizations that provide these audits, it can be a challenging and confusing process. Due to customer demand many firms today are choosing food safety programs approved by the Global Food Safety Initiative (GFSI). Safe Food Alliance’s ‘s team of expert consultants and trainers worked together to address six common questions and help food processors understand and prepare for food safety audits.What is the biggest challenge for a company moving forward from traditional GMP audits to GFSI recognized food safety certification audits?

Here are the primary challenges companies need to recognize when moving forward from GMP audits to GFSI certification audits.

  1. More than GMP. Generally speaking, a well-implemented GMP program will address many of the requirements of a GFSI audit, but it is not enough to pass the audit. Companies need to implement a fully operational HACCP plan, as well as robust pre-requisite programs. There is also a need to fully understand the specific requirements of the scheme you have chosen – some of the most common gaps found in audits are requirements that staff were not aware of. The structure of a GFSI scheme can be visualized with GMP as a foundation, HACCP build above it, and GFSI at the pinnacle:
  2. Verification and Validation. This is done to ensure programs are in place and that they are effective. OF the two, Validation is the most time consuming and, if not done correctly, can cause the facility to have a major non-conformity on an audit.
  3. A living system. GMP audits are just a snapshot in time. Certification requires that food safety programs be fully operational 24X7, with all staff from top management down in full support, as well as continuous improvement of processes.
  4. Documentation. When first moving from GMP to a GFSI standard, many food companies are not prepared for the additional documentation and records required by these schemes. When developing them it is important that they truly reflect how business is done and are practical for use by employees.

What is the role of management in the audit process-whether GMP or GFSI?

Both the BRCGS and SQF schemes place a great emphasis on management commitment. But what does that look like? Direct participation by the highest-level executives in a specific and critically important aspect or program of an organization. Responsibilities of top management include:

  1. Establishing and empowering the food safety & quality committee (the HACCP team)
  2. Formulating and establishing food safety policies and objectives
  3. Providing resources and training for development of the system
  4. Ensuring implementation at all levels of the organization
  5. Evaluating and revising the program in light of results achieved.

For companies first looking into certification services, what criteria should they use in selecting a certification body (CB)?

Here is the criteria you should consider:

  1. CB Accreditation: Although many companies may state that they can issue a certificate to you, they may not be accredited (i.e. licensed) to do so – therefore, you need to check whether that certification body has accreditation, that is, if they have the appropriate accreditation from ANSI or an equivalent body.
  2. CB customer service: Although all accredited CBs must meet certain criteria, you may find that some are more responsive and more customer-oriented.
  3. Auditor Experience: Do they have auditors that know your product and process – not just the general category? Although you might think that an auditor with less experience will allow you to get by easily, it’s actually in your best interest to have an experienced auditor because you might miss some valuable insight. Additionally an auditor who knows your specific industry may be better able to make good judgments about your program and will be more likely to issue reasonable non-conformities. So, don’t be afraid to ask about your auditor; is is completely reasonable to request his or her CV and/or a list of companies he or she has audited.
  4. Reputation: A certification body with a good reputation, whose auditors are known to do a thorough job and make fair evaluations, can support the credibility of your certificate and help make your company even more marketable.
  5. Language: The audit will go much smoother if the auditor speaks your language, even if the certification body sends a translator as well. The auditor will be able to read and understand your documents much more easily, and you will be able to develop a better relationship if there is no language barrier.

What steps can a company take prior to an audit to give themselves the best chance for success?

Answer these questions:

  1. Have all staff been properly trained with respect to the scheme’s requirements, and appropriate to the role they play in the organization?
  2. Have you done all of the required internal audits and corrected any non-conformities?
  3. Do your documentation and facility meet the standard?
  4. Are you implementing what’s described in your documentation?
  5. Does your product meet all applicable regulatory requirements?
  6. Are the fundamentals or mandatory items implemented properly?
  7. Is all the relevant documentation readily accessible?
  8. Are the appropriate personnel on site during the audit?
  9. Have you acquainted your staff with receiving external auditors and answering their questions?
  10. Did you accommodate your auditor’s dietary needs (where applicable)?

As an additional consideration, some companies find that they do not have the resources or on-site expertise to develop a GFSI-compliant program along with their usual job duties. In these cases using a third-party consultant through a company such as DFA of California can be very helpful in closing the gap to compliance.

If the company disagrees with an auditor or the audit findings, what should they do?

Disagreements do happen, and they can be difficult—awkward at best, disastrous at worst. You should have two goals in mind whenever you disagree with your auditor: (1) resolving the disagreement, and (2) clearly understanding the scheme requirements to help avoid future disagreements.
Most issues fall into one of two categories:

  1. The auditor’s assessment of the situation is incorrect, in which case you should gather as much evidence as you can to help the auditor truly understand the situation.
  2. The auditor’s understanding of the situation is basically accurate, but you don’t agree it’s a problem, or you believe that you do meet the requirements while the auditor does not, or you don’t want the problem to appear on a report. In reality, this is the more common type of manager/auditor disagreement. Unfortunately, it tends to spark less productive discussions, since it challenges auditor judgment, not findings.
  3. A successful strategy for swaying auditor opinion should focus on the tone of the conversation, issue significance and action plan. If you can’t sway the auditor, you can always challenge the finding with the certification body. Never become argumentative with the auditor, simply state your point and move on.

What are some other concerns regarding audits against the backdrop of FSMA proposed rules and GFSI?

GFSI compliance does a great deal to help organizations to prepare for the implementation of this law, as there are many key areas that are common to both.

Some of the common areas shared by FSMA and GFSI include:

  • Compliance to domestic and destination laws
  • Records access, document control and record keeping
  • Preventive controls, HACCP, verification and validation
  • Crisis Management, food defense and recall
  • Supplier Controls
  • Transportation controls

With several key areas common between GFSI approved schemes and FSMA, GFSI compliance will certainly help organizations prepare for FSMA compliance. Adhering to a GFSI certified food safety system will lead companies in the right direction, helping to ensure safe and high quality food, meeting customer demands, improving brand reputation and aiding in continued regulatory compliance.