Internal Audit — Guidelines & Recommendations
As more food manufacturing facilities continue to implement and comply with the Global Food Safety Initiative (GFSI) Audit Schemes, they are also required to conduct Internal Audits of their Foods Safety Management Systems. Meeting these GFSI requirements involves developing a strong internal audit program that utilizes internal resources and trained auditors to perform internal audits. Lack of a properly designed or implemented internal audit program is one of the most common GFSI non-conformances.
Internal audit is a complete review of the food safety system against major GFSI Audit Schemes, like SQF or BRC Standards. Internal audits are to be conducted by the company’s own trained staff and involves more than just a GMP inspection of the facility or verification of the Critical Control Points. The internal audit team should be multi-disciplinary, so that they can independently and objectively audit different departments, functions, and processes within the organization. The internal audit team should understand the audit plan, schedule, procedure, documentation and objective of the internal audit process, including the GFSI Checklist and Standard. Internal auditing involves a systematic, planned, independent and documented process for obtaining evidence to review and evaluate against pre-arranged standard requirements. There are many reasons a facility should conduct internal audits and some examples may include preparing for third party audits, satisfying program requirements, creating records of due diligence, driving continual improvement, identifying improvement opportunities, and verifying compliance to standard.
Key steps to conducting an Internal Audit consist of the Plan, Do, Check and Act (PDCA) Cycle, also known as the Deming Wheel. The PDCA cycle is a repetitive four stage cycle and is used for continuous improvement in many business processes.
Establish the objective or define the scope of the audit and create an annual schedule. Selecting and training of the internal auditors are also key components of the planning step.
Implement the plan or execute the process, which involves the collection of information for evaluation. Look for deviations in the implementation against the plan and check for appropriateness and completeness. This step involves utilizing the Internal Audit Checklist Tool for assessment and includes conducting risk assessment of non-conformities according to standard classification of Critical, Major, and Minor Non-conformities.
This step includes writing the non-conformity report and assigning responsibility and deadlines for conducting root cause analysis and corrective action.
Follow-up with the corrective actions in the check step and verify that the corrective actions are effective and will prevent future re-occurrence.
The internal auditor’s main goal is to verify and provide supporting evidence that the program audited either complies with or does not comply with the established requirement or standard. The internal auditor should not just interview the personnel but also review policy, procedures, and records; observe, and evaluate all the collected information to confirm that it is meeting the planned and established standard. Once the Internal Audit have been concluded; the auditor will conduct a closing meeting with the appropriate department staff, confirm the scope or area covered during the audit, read out non-conformities (where appropriate), assign responsibility, agree to corrective actions with deadlines and thank everyone for their time and cooperation.
There are many challenges facilities face when conducting internal audits and but there are some recommendations that will help overcome many of these challenges.
- Develop Internal Audit Program objectives with Senior Management to include reducing non-conforming product, promoting continuous improvement, passing the GFSI Audit, and meeting customer and regulatory specifications.
- Manage internal audits as a separate program that include procedures, trending analysis, formal training, cross department representation, and increasing the size of the internal auditing team.
- Ensure the internal audit is an official event and do not let other work interfere with audit completion or reporting. This includes making sure everyone treats this seriously and formalizing the audit to include a set schedule, opening meeting, closing meeting, audit checklist, and non-conformity report provided in a timely manner.
- Ensure internal auditors are objective and only collect evidence or facts. Do not attempt to voice opinion or argue. Do not provide advice and attempt to fix non-conformities during the audit (unless there are critical food safety hazards present). Do not interfere with production activities. Take pictures for training purposes and reduce audit bias by having a cross-function internal audit team.
- Train internal auditors to properly communicate by asking open-ended questions and avoiding sarcasm, tricky questions, leading questions, ambiguous questions and multiple questions. Internal auditor needs to be professional, objective, open, and honest when interviewing facility personnel. This also includes avoiding poor body language or facial expression and using an appropriate and respectful tone of speech.
- Internal Auditor must always remember to audit the system and not the person.
Internal audit non-conformity report must be written in a timely manner and provide routine updates to Senior Management.