In the third piece of the GMP Checklist Template Series, we focus on training, education, allergens, and traceability.
In order to be in compliance with FSMA, all registered processors need to comply with GMPs (Good Manufacturing Practices). Below is a checklist for your internal audit process. Check the boxes and fill the notes section while making plant observations when doing the internal audit to confirm that your GMP program is up to snuff!
Training & Education:
When doing an internal audit on training, first review the current written procedures in place for training, instruction, and evaluating competency. Make sure all training is documented. If it is not documented, it did not happen!
It is important to train personnel so that not only do they know how to perform a task, but they also know the WHY behind it.
Allergen cross-contact means the unintentional incorporation of a food allergen into a food product.
Food allergen controls include procedures, practices, and processes to control food allergens. Food allergen controls must include those procedures, practices, and processes employed for: allergen cross-contact, labeling, sanitation controls, cleanliness of food contact surfaces (including utensils and equipment), and prevention of allergen cross-contact and cross-contamination, supply chain controls, recall plan, and other controls.
When we look at traceability, we consider the procedures that ensure final products are coded and labeled appropriately. Making sure materials (incoming and outgoing) and documents are traceable is very important in situations such as handling a recall. This includes raw materials, work in progress, and packaging.