Q: Why would a company think about changing auditing methods if their current process is working well?
Kari Hensien: Simply put, you don’t know what you don’t know. Many companies believe they have a strong auditing program because they have not yet seen a problem. However, that doesn’t mean that an unsafe or noncompliant behavior hasn’t happened, it only means that it hasn’t surfaced.
Problems may arise that are more difficult to catch in an audit. Factories are tired from repeating the same audit for multiple clients, auditors are exhausted from long days and doing the same work twice, and this type of audit fatigue can lead to audits being rushed or errors being introduced in data entry.
Companies have gotten comfortable with more manual auditing processes – clipboards, spreadsheets, binders – as they’ve evolved over several decades. Any change to the status quo will cause some degree of discomfort, so there’s an understandable reluctance to make a change without a major catalyst.
In this case though, the catalyst may not have been within a company, but rather changes to the industry the company operates in. Regulations are stronger than ever, supply chains have become more complex, and suppliers and brands are asking more questions about where their food comes from and how it’s processed. Further, standards bodies have begun the process of requiring digital audit submission for better tracking and that trend is likely to continue.
These changes are happening because manual or traditional auditing creates blind spots in the quality, safety, and risk management program.
Data collected manually is difficult to aggregate, which makes spotting trends difficult and delays catching potential issues before they become problems.
Manual audits create audit fatigue because results can’t be shared across certifying bodies or inspectors, and suppliers must complete the same audit for each customer.
Corrective actions become time consuming and difficult to track without automation.
Q: What options are available to strengthen audit programs?
Hensien: Companies should not have to give up an auditing program they like to adopt new technology. In fact, having a strong process is an advantage when looking to improve the process already in place. This means bringing in technology will be additive rather than disruptive.
Companies that are looking to modernize their quality and risk auditing programs have a variety of options. Digital auditing solutions run the gamut from simple online forms to full enterprise platforms. Here are some of the features companies may find in modern auditing solutions.
Digital auditing forms. These are one step above the manual process. Auditors can input data directly into the form and skip the step of then having to transcribe results.
Comprehensive reporting. Holistic, timely reporting is a key advantage of moving away from manual audits, and more enterprise quality management platforms will include it. A centralized data warehouse of audit data makes it easy for companies to have visibility into whatever matters most.
Data integration. For companies monitoring large supply chains, complex business structures, and external quality indicators, integrating multiple data sources gives a comprehensive look at the factors that contribute to quality and safety. Data integrations bring in information from partners, third-party auditors, and more to get a full view of critical information.
Automated corrective actions. Mistakes are inevitable, but how they are handled can make or break a business. Having corrective actions, and their follow up, automated when something is out of compliance takes the guesswork out of whether it’s been handled effectively.
What matters most is that any company looking to improve their existing model take the time to identify what risks exist and how new technology can help mitigate those. For example, not every company needs to bring in data from external sources. But if a standards body they work with recently began requiring digital audit submissions, then digital forms are a logical choice to avoid any audit-fatigue related errors when transcribing data into the submission portal.
Finding the capabilities available to reveal the blind spots that existed in the manual auditing process reduces the friction and fatigue in auditing. Administrators are able to better see and understand all parts of quality and safety management, auditors can spend more time thoughtfully working with those being auditing, and suppliers and factories can share digital audit results with multiple customers rather than repeating the same audit many times.
As president of RizePoint, Hensien is championing a new continuous quality initiative. Since travel and interpersonal interactions have been devastated by COVID-19, it’s been challenging for businesses to obtain regular third-party audits, which are integral to access and analyze key data and ensure safety compliance across the enterprise. Hensien is facilitating an increased self-assessment auditing model, where businesses and their locations can use RizePoint’s digital platform themselves, resulting in more frequent audits and broader visibility during the pandemic and beyond.
Last month, federal authorities enacted a recall process for all Real Water brand products from AffinityLifestyles.com Inc., as a result of a fatality and multiple illnesses that might be linked to the product. In addition to the recall, there are a number of court orders being enacted to retrieve records, documentation and other information from the company. The product in question is bottled water that is chemically treated to enhance its “benefits.”
Over the last 20 or so years, as with many other food and beverage categories, the bottled water market has exploded. It began with Natural Spring Waters, then emerged into what was termed “purified waters.” Over time, carbonation and flavors, both natural and imitation, were added to enhance the products’ appeal to different demographics and to capture market share. The trend has continued to illustrate how both SKU proliferation and catering to the changing needs of the consumer has complicated the industry and made it increasingly complex. Complexity, of course, adds risk.
The Real Water situation brings to light potential issues both for the bottled water segment and for the food and beverage manufacturing industry on the whole. Beverage and food products often utilize additives to enhance flavor, add nutritional benefits, etc. In addition to these additives, many food and beverage products are produced with “reactionary” processes that claim to supercharge, enhance, and/or re-engineer something to a so-called better state. Government regulators monitor these processes to ensure that they do not cause health risks. Enhanced and more stringent labeling laws were enacted at the end of the Obama era and just recently, President Biden signed the FASTER Act that requires manufacturers to list sesame on their labels, as it is now a known allergen. In addition to additives, regulatory agencies monitor the new chemical and reactionary processes used in producing products to ensure that the integrity and safety of these products are not put at risk.
Lessons Learned from the Real Water Recall
Where does the industry go from here, and what lessons can manufacturers take away from the Real Water incident and from the increasingly complex state of food and beverage manufacturing? First, we know regulations will continue to increase, especially as incidents become more commonplace. The industry has been on high alert since the outbreak of COVID-19. Governments and industry will continue to try to determine if the virus can in fact be transmitted through food or food packaging. As food manufacturers experiment with plant-based food alternatives, employ new technologies and react to recalls, they should prepare for continued scrutiny and regulations which will impact how businesses are run.
The question that needs to be answered is: What should food and beverage manufacturers do to prepare for future changes to regulations and prevent potential safety issues?
The answer is: They should implement a quality management system and related business processes and systems tailored for the unique challenges of their industry.
F&B Manufacturers Can Improve Quality Systems to Prepare for Future Regulation and Safety Changes
Many manufacturers already have parts of this system and the processes in place, but it is surprising how many have not integrated them with their other systems. If we use the Real Water issue as a case study, there are a number of things that a manufacturer needs to do from a quality perspective in terms of processes, procedures and systems.
Traceability. Accuracy and timing is critical in the face of any recall. Track and traceability functionality built into the central manufacturing and/or quality system is an absolute must. Technology is available to visually track and trace every lot that goes out the door, whether from a company facility or a co-packer, and note where in the market it has been distributed.
Document Control. The government demanded that AffinityLifestyles.com Inc. turn over all documentation related to its products’ ingredients, processes, etc. Manufacturers need to ensure their document management systems include food safety precautions and that all process and product information needs to be in place.
Product and Process Change Management. Integrating inspection processes with control plans ensures that inspection requirements stay connected during change management. This coupled with non-conformance creation based on inspection failures results in reductions in the cost, time and complexity of change management.
Audit Processes. To comply with ever-changing regulations, effective internal audit programs must be implemented to drive compliance and continual improvement. A closed-loop system should address product, process and system audits to help manage any findings of non-conformance prior to external audits and to allow for corrective actions to be implemented before an issue arises.
Supplier Quality Management. Food safety issues can often be due to a material or food ingredient issue. Monitoring all activities with suppliers by requiring and instituting best practices can help ensure supplier conformance.
Ensuring Ongoing Success and Profitability for F&B Manufacturers
All businesses operate to make money. Food and beverage manufacturers are no exception. But, when the products being made are consumables, the top priorities have to be safety, quality and food integrity. The food and beverage market is changing and evolving. Due to increasing customer demand, consumer preferences, sustainability initiatives and government regulations, manufacturers face more pressure to improve quality. These market changes have resulted in faster life cycles, shorter lead times, and the need for manufacturers to deliver more products faster than before, which puts pressure on the entire organization. Manufacturers in the food and beverage industry are under intense scrutiny to consistently produce safe food. Occasionally, issues occur that are out of a manufacturer’s control, but the producers of food and beverage products still have a responsibility to ensure that all precautions are in place to meet the safety needs of the end consumer. Efficient processes and systems to manage food safety not only meet the required compliance requirements but are a huge step in ensuring ongoing success and profitability.
This week’s episode of the 2021 Food Safety Consortium Virtual Conference Series will discuss the challenges that the industry faces in managing the supply chain, including in the realm of audits. The following is the agenda for this Thursday’s session:
Food Safety as a Supply Chain Management Problem, with John Spink, Ph.D., Michigan State University
Supplier Certification in Today’s Supplier Quality Management Programs: A Discussion with Gary van Breda, McDonald’s; Jorge Hernandez, Wendy’s; and moderated by Kari Hensien, RizePoint; Sponsored by RizePoint
What Needs to Change in Food Safety Certification: A GFSI Panel Discussion moderated by Erica Sheward, GFSI
Auditing Update in the Age of COVID: FDA Standards and Regulations Alignment Pilot, with Trish Wester, AFSAP
This year’s event occurs as a Spring program and a Fall program. Haven’t registered? Follow this link to the 2021 Food Safety Consortium Virtual Conference Series, which provides access to all the episodes featuring critical industry insights from leading subject matter experts! Registration includes access to both the Spring and the Fall events. We look forward to your joining us virtually.
Q. What are some of the most common pitfalls that you notice during your audits that could be handled better before the audit?
Don Milne: I’ll give you actual examples of situations that resulted in non-conformances during my audits. Although the examples are from FSSC audits, most of the GFSI standards audits have similar requirements that make these examples relevant for any size plants.
One of the neglected areas in many plants are documents and records. We sit in the office, and we look at a nice list of documents, and we don’t find problems while in the office. Then we get into the plant, some have control rooms, where they maintain records. It is fairly common that you find a bookcase with obsolete instructional manuals, – “What are these?”. “We don’t use them any more…”, is the answer. Well, someone could use them if they were never withdrawn from service. It is particularly true when you have large equipment. Over the years this equipment might have had modifications, sometimes it changed hands once or twice, and the manual is not even updated or relevant. This manual might be used by someone who is not aware of this. Make sure obsolete manuals are marked “for reference only” and are not in service.
Records must be correctly filled out. People do make mistakes. To eliminate that, do a single strike and initial it. Standard does say “records must be legible” but there are lots of corrections with ballpoint pens, obliterating the original entry, which can’t be deciphered.
A couple of other points: sometimes Operators pencil in a column with extra information. If this information is needed by other people, it is not acceptable to add or modify information in a controlled document.
Sometimes, I’ve seen operators use pieces of paper to keep their own records. I’ve seen a case, when an operator needed a tally sheet, and he photocopied one, he found elsewhere, and everyone was using it. When I asked about this document, I was told, it was not a document at all, it was unofficial. But if everyone needs such a document, an organization should develop an official template for one.
Q. Internal audits should prepare a plant for your visit, can you share if there are any prevalent mistakes made during internal audits that lead to a non-passing score at external ones?
Milne: This is an interesting subject, because everyone does internal audits. What I find is that the focus is mainly defaulted to GMPs, housekeeping with added things. Oftentimes, it does not look at the whole system and its effectiveness. Internal audit is one of the principal means of verification and validation of your system. One problem we get is that a lot of auditors in large plants have been trained to perform internal audits, you get teams of 30-40 auditors or more, and internal audits are broken down into manageable elements or modules, and teams do these parts one by one over the year. Within a year the whole plant is covered. This is a good idea, but the issue is, not the whole team has received a detailed training. Using FSSC 22000 as an example, we get critical, major and minor non-conformances, depending on the severity of the issue. This standard no longer allows for a written observation. (observations are considered issues, which, if left to deteriorate further, could develop into minor non-conformances). However, a plant can decide to list observations during their internal audit. Observations do not need corrective actions, but when you look at the audit findings it often seems like there are an excessive number of observations. If everything is an observation and if you don’t have the root cause, you get repetitive audit findings that each time are noted to be improved, but they are not. One plant I visited had 260 findings for the year. When I finished my audit, I found 5 or 6 findings, but the plant team got distraught, because their goal was not more than 3 findings. But where was the disconnect, if they found over 200 themselves, and I found only half a dozen, and they were still unhappy? Have a look at your internal program and see, if you are falling into that pitfall of having a weak internal audit that does not look at things deeply enough. Consider auditor calibration training so the audit team are rating their findings in a consistent manner.
About Don Milne
Currently DNV GL’s Senior Lead Auditor qualified in FSSC 22000, BRC, ISO 9001, RSPO and formerly an Executive Manager, Don possesses extensive experience in the TIC (Testing, Inspection and Certification) and in food industry. With over 22 years in the food industry, Don has been in executive roles at multinationals like Unilever (Birds Eye Foods Division), Union International (Table Top Foods), Beechams Food (Bovril Foods Division) and SGS (Qualitest Food Consultancy Division). His areas of expertise include product development, process and product support, manufacturing, quality management and management of a supplier surveillance audit program for a major supermarket chain. He has been living and working in the USA, UK, South Africa, Colombia, Argentina and the Eastern Caribbean area (US Virgin Islands, Puerto Rico).
In today’s digital-first world, it might be surprising for those outside of the food manufacturing industry to learn that paper and pen are still considered state-of-the-art documentation tools. Answering food safety and quality questions such as: “What was the underlying cause of this customer complaint?” or “What caused the production halt this morning?” still require hours of research across paper documents, emails and spreadsheets. Maybe even the odd phone call or text message.
The good news is that many food safety and quality problems can be solved by leveraging modern-day technology. The challenge is taking that first step. By applying the following best practices, organizations can take small steps that lead to substantial benefits, including optimized food safety and quality programs, happier employees and safer operations.
Digital Transformation Best Practices
What if all the information food safety professionals require could be accessible through one unified interface and could proactively point to actions that should be taken? It can, with the right mindset and the right strategy.
While there is no “flip of a switch” to become digitally empowered, best practices exist for where to start. And, early adopters are injecting innovation into food safety programs with simple, but powerful technology.
Look Inward
Too often, food safety professionals push forward on a path to digital transformation by evaluating software and business applications against features and/or cost. But before taking this approach, it is important to look at existing food safety programs, identify where incremental improvements can be made and determine the potential return on a new technology investment.
Self-awareness is a beneficial leadership skill, but it’s also the key driver in understanding an organization’s business needs for food safety. Food safety professionals need to get real about common pain points, such as inconsistent or insufficient data, non-standardized practices, and delayed reporting. This is not the time to gloss over problems with processes or tools. Only by clearly documenting the challenges upfront will organizations be able to find the best solutions.
As one example, a common pain point is managing different formats and timing of reporting across facilities. See if this sounds familiar: “Well, Dallas sends an Excel spreadsheet every week, but Toledo only sends it on a monthly basis, while Wichita sends it monthly most of the time, but it’s never in the same format.”
Start out by identifying similar problems to help define the business objective, which will help determine how technology can be most effectively applied.
Eat, Sleep, Food Safety, Repeat
Food safety processes should constantly evolve to enable continued improvements in food safety outcomes. With that in mind, it’s helpful to dust off the corporate SOP and review it, especially if an organization is moving to a digital program. A common mistake many food manufacturers make is asking technology providers to configure an application based solely off the corporate protocol, only to discover at go-live that users don’t follow that protocol.
To avoid this situation, consider the following questions:
Why are food safety professionals not completing processes by the book?
Is that similar with every site?
Why has it been that way for so long?
Why did food safety professionals start to stray?
By locking down processes and identifying the desired way forward, leaders can configure a new application with the latest information and updated decisions. At a minimum, this step will help identify current issues that should be addressed, which can become measurable goals for the use of the new technology, ideally emphasizing the most pressing problems.
Less is More
Digital transformation doesn’t always need to become a “fix-all” project. Instead, it may revolve around a single operational initiative or business decision. For example, food safety professionals often maintain a spreadsheet with usernames and passwords for countless applications, some of which overlap in functionality and/or require a separate login for each facility. This is not only a safety concern, it’s an easy entry point when moving to a digital approach.
Consolidation of applications is a natural step from the standpoint of feasibility and fiscal responsibility. So, look for digital transformation opportunities that result in fewer applications and more consolidation.
Don’t Rush It
While digital transformation is inevitable, Rome wasn’t built in a day and neither should be an organization’s digital strategy. Unfortunately, the decision to go digital is often made, and a go-live date chosen, before determining what transformation requires, which is a clear-cut recipe for failure.
Technical vendors should play a key role in developing an effective implementation strategy, including sharing onboarding, planning, configuration and go-live best practices.
While technology is here to help the world become smarter about food safety, it is not here to replace human experience. Food safety leaders should continue to augment processes through supplemental technologies, rather than view technology as a full takeover of current approaches.
Barriers to entry for digital transformation are being lowered, as the ease of adoption of the underlying technologies continues to advance and access via cloud-based applications improves.
What to Do With All This Data? 5 Outcomes Food Manufacturers Can Achieve
Food manufacturers have benefited from digitally transforming environmental monitoring programs (EMPs) using workflow and analytics tools in a variety of ways. In the end, what matters is that the resulting data access and usability enables new insights and accelerates decisions that result in reduced risk and improved quality. Keep in mind these key outcomes that food manufacturers can achieve from digital transformation.
Enhancing an internal audit framework with digital tools will greatly reduce the burden of ensuring compliance for schemes such as BRC, SQF and FSSC food safety standards. Flexible report formats and filtering capabilities empower users with the right information at the right time.
Imagine, no more sifting manually through binders of CoA’s and test records to find a needle in a haystack. Exposing teams to a digital means of performing internal audits will not only boost confidence to handle requests from an auditor but will also help drive continuous improvement by providing easier access to insights about the effectiveness of internal policies. At the same time, digital tools will help ensure that only the required information is shared, reducing confusion and uncertainty as well as audit time and cost.
Outcome #2: Proactive Alerting and Automated Reporting
Threshold-based report alerts are an excellent way to reduce the noise often associated with notification systems. Providing quality and safety managers with automated alerts of scheduled maintenance or pending test counts can help them focus on activities that need attention, without distractions.
The benefit of threshold-based reporting is that it is a “set it and forget it” method. While regular “Monday Reports” are still a necessity, alerts and reports can be generated only when attention is needed for anomalies. A great example of this is being able to set proactive alerts for test counts in a facility that are approaching nonconformance levels. Understanding the corrective action requirements needed to control an environmental issue before it impacts quality, production and unplanned sanitation measures is a critical component of risk management and brand protection. In addition, reports can be automatically generated and delivered on a regular schedule to help meet reporting needs without spending time collecting data.
In other words—imagine a world where data comes and finds users when needed, rather than having to search for it in a binder or spreadsheet. Digital tools can provide email reports showing that a threshold has (or has not) been met and link the user directly to the information needed to take action. This is called “actionable information” and is something to consider when deploying technology within an organization’s food safety program processes.
Outcome #3: Optimize Performance with Tracking, Trending and Drilling
The Pareto Principle specifies that for many outcomes, about 80% of consequences come from 20% of causes. Historical data that is digitized can be used to quickly identify the root cause of top failures in a facility in order to drive process improvements. Knowing where to invest money will help avoid the cost of failure and aid in the prevention of a recall situation.
Dashboards are a powerful tool that organizations can use to understand the risk level across facilities to make better, data-driven decisions. Reports can be configured through a thoughtful dashboard setup that enables users to easily identify hot spots and trends, drill down to specific test locations, and enable clear communication to stakeholders. Figure 1 provides an example of a heat map that can be used to speed response and take corrective actions when needed.
Figure 1. Pathogen Positives by Zone and Location Heat
Outcome #4: Simplified Data Governance and Interoperability
Smarter food safety will drive standardization of data formats, which allows information to flow seamlessly between internal and external systems. One of the major benefits of shifting away from paper-based solutions is the ability to be proactive to reduce risk and cost. FSQA managers, within and across facilities, can benefit from a 360-degree operational view that reveals hidden connections between information silos that exist in the plant and across the organization. This includes:
Product tracing through product testing to environment monitoring and sanitation efforts
Tracing back a product quality issue reported from a customer to the sanitation efforts
Understanding why compliance is on track but quality results aren’t correcting
Outcome #5: Reduce the Cost of High Turnover
Successful GMPs, SSOPs and a HACCP program require leaders that continually ensure that employees are properly trained, which can be difficult with high turnover rates. To address this challenge, digital tools can aid in providing easily accessible documentation to empower users and reduce the cost, time and risk associated with having to re-train new employees on the EMP process. While training cannot be replaced with technology, it can be accelerated.
For example, testing locations within facilities can be documented with images and related information enabling new employees to visually see the floorplan and relevant testing protocols with accompanying video and click-through visualization of underlying data. Additionally, corrective action protocols can be enhanced with videos and standardized form inputs to ensure proper data is being collected at all times.
The Path Ahead
As the digital transformation of the food safety industry continues, food manufacturers should seek out and apply proven best practices to make the process as efficient and effective for their organization as possible. By avoiding common pitfalls, companies can achieve transformation objectives and realize substantial benefits from more easily accessible and actionable food safety data.
The COVID-19 pandemic has disrupted operations for food processing facilities and their food safety protocols. A failed audit can tarnish your business’s reputation and even lead to lost profits. During this webinar board-certified entomologist Frank Meek will discuss tips and best practices to be ready for the pest control portion of your food safety audits.
Over the past 9 years, the Food Safety Consortium Conference & Expo has built a reputation for delivering perspectives and insights from the most knowledgeable and influential experts in food safety. As a result of the COVID-19 pandemic, last year’s event was converted from an in-person event into a 14-week series of virtual themed-episodes during the fall. Continuing the momentum from 2020, the 2021 Food Safety Consortium Virtual Conference Series will take place as a four-week Spring and five-week Fall program. Both the Spring and Fall programs will feature critical thinking topics that are for industry veterans and knowledgeable newcomers.
“As you know, the online experience is very different than in-person, so last year we deconstructed our in-person program and re-engineered it for virtual. Instead of having a virtual conference for three straight days, we set up our program in short 2.5-hour themed episodes that ran every Thursday in the fall. We received great feedback from attendees, speakers and sponsors. I think we were one of the few conferences that successfully pulled off the pivot to virtual,” says Rick Biros, president of Innovative Publishing and director of the Food Safety Consortium.
Building on the strong success of the 2020 Food Safety Virtual Conference Series, the 2021 Consortium will be presented into two seasonal programs. “This will allow us to continue the conversation throughout the year, while also taking into consideration the busy lives of food safety professionals,” Biros adds.
Food Safety Tech is the media sponsor and will feature exclusive content from the event.
The Spring Program will run every Thursday in May, with each episode starting at 12 pm ET. The weekly episodes will tackle a range of critical topics in foods safety, including FSMA and traceability, food protection strategies, COVID-19’s lasting impact on the food industry by segment, audits and supply chain management. Frank Yiannas, FDA deputy commissioner for food policy and response, is the confirmed keynote speaker for Thursday, May 6.
The Fall Program will run every Thursday beginning on October 7 at 12 pm ET through November 4. Episode topics include food safety hazards (emerging threats and new technologies), food defense strategies, an FDA update, and personal development, training and mentorship.
Companies that are interested in sponsoring a 10-minute technical presentation during the series can contact Sales Director RJ Palermo for more details.
About Food Safety Tech
Food Safety Tech is a digital media community for food industry professionals interested in food safety and quality. We inform, educate and connect food manufacturers and processors, retail & food service, food laboratories, growers, suppliers and vendors, and regulatory agencies with original, in-depth features and reports, curated industry news and user-contributed content, and live and virtual events that offer knowledge, perspectives, strategies and resources to facilitate an environment that fosters safer food for consumers.
Since 2012, Food Safety Tech audiences have learned to respect and expect our high-quality content—via FoodSafetyTech.com, our weekly newsletter and by attending our educational programs. Food Safety Tech keeps professionals current with the latest information about technology, best practices and regulations, and how innovative solutions and approaches can be leveraged to further advance food safety across the globe.
About the Food Safety Consortium Conference
The Food Safety Consortium is an educational and networking event for Food Protection that has food safety, food integrity and food defense as the foundation of the educational content of the program. With a unique focus on science, technology and compliance, the “Consortium” enables attendees to engage in sessions that are critical for advancing careers and organizations alike. Over the past 9 years the Food Safety Consortium has built a reputation for delivering the most knowledgeable and influential perspectives in food safety. The speaker line-up has driven key food safety decision-makers to the event (both in-person and virtually)—facilitating an environment for vendors, suppliers, food industry professionals, and consultants to network and build long-lasting business relationships.
Due to COVID-19, the 2020 Food Safety Consortium was converted to a virtual conference series that featured specific topics in a weekly episode series. The 2021 Food Safety Consortium Virtual Conference Series will feature a Spring and Fall program, running in May and October, respectively.
The coronavirus pandemic has impacted the food industry on several fronts from production to consumer purchasing habits to in-restaurant dining adjustments. While facility operations might look different, the demand for product is certainly still high, so operations should be tighter than ever.
Unfortunately, pest activity has not slowed down during the pandemic. From rodents and cockroaches to stored product pests and birds, your facility is susceptible to pest disruptions. With shipments coming and going and limited staffing, it’s also highly likely you don’t have time to prioritize your pest management program. An unchecked, contaminated shipment leaving your facility and making it into the homes of consumers is all it takes to wreak havoc on your business.
Your goal, and the goal of your pest control partner, should be that your facility is ready for an audit at any time. (Image courtesy of Orkin)
If you already have an integrated pest management (IPM) program in place, you’re heading in the right direction with securing your facility. IPM programs help food processing facilities keep pests from entering and destroying your product by applying preventive measures such as identifying potential and existing sanitation opportunities and regularly evaluating the state of facility maintenance.
The last thing you need right now is a failed audit due to preventable pest issues. Failing a first, second or third-party audit can lead to many consequences such as a damaged reputation, reduced profits and worst of all, lost customers. With most regulators resuming on-site audits, offering remote options or a hybrid of the two, ensuring your facility stays within regulations is still possible, and highly encouraged. After all, pest control plays a significant role in all major food safety audits and can account for up to 20% of your score.
Food Safety Audits during the Pandemic and New Changes
Not only do facility managers have to regulate operations during a pandemic, but they also must maintain strict food safety standards to ensure that the food supply chain stays healthy. With the arrival of COVID-19 vaccines, there is some hope that the pandemic may be under control soon, but it is not over yet, and food safety audits should not be avoided because of a pandemic. To accommodate, many auditors implemented new measures such as remote and hybrid audits for food processing facilities, in addition to on-site audits.
If your facility is still unable to conduct on-site audits at this time, special accommodations can be made. The following auditors have made updates to their food safety audits amid the pandemic:
BRCGS: In addition to blended audits, BRCGS is offering certificate extensions for up to six months with a risk assessment and review. Although not benchmarked by GFSI, remote assessments are also available and involve a video audit of your facility’s storage and production areas in additional to reviewing internal audit results and documentation.
SQFI: SQFI is postponing certifications for extenuating circumstances and implemented additional processes for risk assessments. Certifying bodies will have to conduct risk assessments to determine whether a certificate extension is needed.
FDA: After temporarily suspending all facility inspections last March, the FDA has resumed domestic inspections on a case-by-case basis when safe to execute. Foreign inspections have not yet resumed so, take extra care if your facility regularly receives foreign shipments.
FSIS: Inspections of meat, poultry and egg facilities continued through the pandemic. These regulated facilities continue to require sanitation SOPs to help maintain food safety and prevent the spread of diseases.
Whether your facility is able to resume onsite audits or needs to switch to a remote or hybrid option, pests will still be trying to take advantage. Working with your pest control provider to ensure your documentation and pest management measures are in order is one of the best ways to ensure any audit or risk assessment goes smoothly. While each auditor has specific requirements, here are some key considerations for your next third-party inspection.
Implement an IPM Program
We cannot stress enough the importance of a proactive pest management program for food processing facilities. The best way to reduce pest issues is to build them out. Your pest control partner will identify and communicate to you on ways to reduce, or in some cases even eliminate food, water and harborage for pests. Ensure your contract specifies the roles and responsibilities of your pest control partner and you, the scope of service and a risk assessment plan. If you’re unsure of what your contract entails, now is the time to get in touch with your pest control partner.
Invest in Your Employees
Train your staff to spot and record signs of pest activity so you can address them immediately with your pest control partner. This is particularly important if you had to adjust employee schedules during the pandemic to enforce proper social distancing. Fewer staff means fewer opportunities to spot pest issues, so making sure all employees are trained can help you in the long run.
Keep Up with Documentation
Your documentation is an integral part of your audit process because it shows third-party auditors that you can verify that you have an effective pest management plan in place. Three types of documents are needed for your audit: Proof of training and certification, pesticide documentation and general facility documentation. Most pest control providers now maintain digital documentation for their partners which makes it easier to track and monitor for pest trends, treatments and updates to your plan. Even with a proper pest management program in place, facilities can still lose points for not having proper documentation so don’t overlook this part.
Hold Practice Runs
A good pest control partner will encourage test audits to ensure you’re prepared for the real deal. An annual assessment is one of the best ways to make sure your pest management program is still working and to address any gaps if it isn’t. Don’t forget to review your documentation during test audits in addition to joining your pest control partner for a physical inspection of your facility (socially distanced, of course).
Prepare your Facility
Your goal, and the goal of your pest control partner, should be that your facility is ready for an audit at any time. However, if you have an upcoming scheduled audit, a week before your audit, work with your pest control partner to conduct interior and exterior inspections as well as a documents review. Make sure you are familiar with how to access your customer web portal so that you can access data if requested. During these inspections, make sure any monitoring devices meet auditor requirements and are properly placed and maintained. The day before your audit, make another run through the facility to be sure your facility is ready. You don’t want your auditor finding cobwebs in your storage room or debris showing up in the background of a video audit.
Food safety should be a top priority for your business—your reputation depends on it after all. As the food industry continues to navigate operating in a post-pandemic climate, maintaining a successful pest management program and updated records will give you a head start when it comes to audits no matter the format. With public health concerns at an all-time high, consumers and suppliers alike will be grateful for your increased attention to maintaining industry regulations.
Starting in late March, based on travel restrictions and the risk of COVID-19 infection transmission, GFSI released direction to the food industry on the possibility of recertification extensions. The extensions enabled a one-time, six-month grace period to prevent certification loss.
In June GFSI updated guidance to allow up to half of the recertification process to be completed off-site using remote technology, while requiring completion of an audit’s on-site inspection within 28 to 30 days. In exceptional circumstances, a certification program could allow a maximum of 90 days for the on-site audit portion. As these “blended” audits began, fewer facilities sought extensions.
The remote portion of an audit, which includes program and record review as well as interviews, may increase audit time compared to pre-COVID audits, as all involved adjust to the use of technology and accessible electronic formats for records and programs.
After COVID-19, it is conceivable to predict that a portion of the audit could remain virtual. However, in food production, auditing requires the use of sight, touch and smell, not yet replicated without human observation. And, while COVID-19 has forced an audit evolution by pushing “virtual” adoption based on business needs, remote capabilities will still require a significant investment in technology, time and re-education of the industry. In the meantime, expect audit schedules to be disrupted for the next 9 to 12 months.
As the industry seeks to adapt for the future, we will likely see an acceleration in terms of digitized quality management systems. In the short term, manufacturers are putting their energy and focus into keeping employees safe, maintaining production and meeting customer commitments.
Several leading food safety groups have issued guidance on best practices for blended audits and the use of technology. And while the answer to “Are blended audits are here to stay?” appears to be “yes” for the immediate future, audits are expected to evolve over time. Although certain sections within audits are better adapted to remote capabilities, facilities will continue to use on-site auditors until new technologies enable them to do otherwise.
Who would have even thought to put the topic of a pandemic in your business continuity plan? I know, I sure never thought of it, even as a senior auditor. I think that most of us are familiar with the typical subjects of tornados, floods, power outages and disgruntled employees, to name a few. We now need to focus on adding a pandemic to the to-do list of your plan, as this global issue has become a reality since early 2020.
It is quite likely that your plant has been affected by COVID-19 in some way, therefore your site has put into place actions to mitigate the risks posed by the pandemic. What may not be likely, is that any of these actions have been documented. I have currently seen plants evolve actions based on the severity of the pandemic in their locations. Travel restrictions, reduced work force, changing employee personal protective equipment, additional employee monitoring, and remote work environments are some of the examples directly affecting sites that I have witnessed during the first half of this year. As plants learn and experience more issues, they tend to adapt to how they are mitigating the risks in their facilities.
Capturing what actions went smoothly and what has gone astray will aid in strengthening your business continuity plan. Pandemics as well as other extraordinary events are handled by a multi-step approach that needs organization and good communication. That is why it is imperative to build and document actions, then verify how those steps are to be used. Involving key personnel–not just the quality manager–at the site is a best practice in getting a full grasp on what needs to happen during an emergency. In several instances, I have witnessed that key personnel are not informed about where a site’s business continuity plan is located; or the plan was updated right before an audit and after goes back on the shelf for the next 12 months, collecting dust. Employees should be trained on the contents of the plan, their responsibilities (if they are part of the business continuity team), current contacts, updates, and ways to initiate proper channels, if or when a time comes to do so. Hopefully, it never does, but it sure does not hurt to be prepared.
The business continuity plan is not a “one-size-fits-all” approach for plants. An important consideration, when defining what actions to take, if your area has been plagued by a pandemic includes determining what risks are brought by employees, visitors (i.e., contractors), location, and type of product being produced. Plant A making a high-risk open product may implement additional hand washing and sanitation, whereas Plant B making a low-risk closed product may implement additional health screening (i.e., temperature checks) for employees. You should ensure that it makes sense, and it is beneficial for your site and your interested parties, such as customers, consumers and stakeholders.
Your business continuity plan should be built to be a great resource to you in the time of need. And in return, you will have to put some elbow grease into shaping the document in a way that fits the ever-changing food environment. Keeping your plant current will assist your business to quickly respond to a negative event. In consequence, not having a plan that works for your site, or any at all, could lead to closed doors.
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About Kari Hensien
