Audit Pitfalls and Recommendations

Recommendations

• Run your own food safety system & learn to validate, audit, defend it!
• Accurate information presented to audit companies equals more audit value

Documentation Requirements

• Staff cannot access/unaware of required documentation
• Documents inadequately controlled, e.g. no approval, outdated/obsolete documents, inconsistent versions
• Relevant documents of external Origin not identified, e.g. food regulations, customer specification, standards etc.
• Distribution of external documents not controlled
• Improper data correction -obliterated/erased data or liquid paper

Management Responsibility/Resource Management

• Commitment statement does not mention conformity to legal, regulatory & customer food safety requirements.
• Review documentation does not detail inputs/outputs; objectives not measurable or not tracked
• Communication procedures not in place/not effective; personnel to communicate with external parties not defined
• Food safety issues/changes not communicated to food safety team promptly
• Emergency preparedness/business continuity plans not in place or not tested annually
• Staff/back up personnel training/evaluation not documented
• No review of competence for outsourced activities

Processing/Product Realization

• PRPs not in accordance with PAS 220 or not well documented
• Supplier review for hazard controls not documented
• Food safety team/meetings not documented
• Insufficient information on raw material characteristics to conduct hazard analysis
• Product descriptions/end product characteristics incomplete
• Process flow diagrams/plant schematics not accurate or missing steps like water treatment, waste & rework
• Food Safety hazards reasonably expected to occur not identified
• Control measures for hazards identified not adequately defined
• Hazard assessment/prioritization not adequate
• CCPs not logically determined or not capable of being monitored
• Information required for OPRPs (FSSC 22000) or HACCP plans not adequately defined e.g. inaccurate critical limit, incomplete monitoring procedure, correction and corrective action not clearly defined
• Incomplete corrective action documentation or no segregation/identification/safe disposition of affected product
• Missing informationl1ests for traceability from raw materials through in process/finished product to next level of distribution

Validation, Calibration, Verification, Continual Improvement

• HACCP/OPRP plans not validated or not properly documented
• Key measuring equipment not calibrated at least annually
• Internal audit not carried out at least annually or all standard requirements were not covered
• Internal auditors not consistent or not trained
• Corrective action not performed in response to internal audit non-conformities or not verified to be effective
• Results not analyzed to confirm overall effectiveness of FSMS & identified opportunities for improvement/updating