[AIB Audit Improvements] Raising the Bar

One goal of many food facilities is to improve the scores and ratings received during third-party and customer food safety audits. As an AIB auditor, I am often asked, “How can we improve our audit scores?” The easy answer is make sure your facility is in compliance with the relevant audit standards. However, this answer is not especially helpful for the audit that is already in progress or has just been completed. At the end of each audit, I review all the specific improvement opportunities discovered during the process. But again, this information only helps the facility after the audit has concluded. The following common opportunities for improvement will help facilities better prepare for upcoming audits.

FLOOR AND WALL JUNCTURES. The plant’s food safety team should routinely inspect the floor/wall junctures. Look for anything that may indicate a lack of attention to GMPs and other components of the food safety management system (including food defense deficiencies). Focus a good amount of time in this area looking for:

• Soil and debris
• Evidence of pest activity (live and dead insects, insect trails, rodent droppings, rodent rubs, etc.)
• Roof leaks
• Condensate drips
• Unsecured pedestrian doors
• Openings to the outside (gaps at the bottom of doors, holes in screened vents, etc.)
• Hose bibs that have not been equipped with backflow protection
• Evidence of other GMP violations (candy and gum wrappers, beverage containers or tops, cigarette butts, etc.)

Pay special attention if the area is somewhat hidden behind storage racks or pallets of stored equipment and supplies. If a sanitation perimeter has not been maintained and a section of the floor/wall juncture is not accessible, this represents an improvement opportunity.

WAREHOUSE AND STORAGE AREAS. Storage areas frequently receive less attention than processing areas. The idea seems to be that since the materials stored in these areas usually are protected by some type of packaging material or covering, or the materials are maintenance and sanitation supplies, they are not subject to the same risks that would be assumed if these materials were in the processing areas of the plant.

During inspections, I have found improvement opportunities in storage areas, especially near stacks of “old” ingredients, spare parts, obsolete packaging materials, forgotten R&D materials and display devices. Look for evidence of pest activity. Stored product pests may be living in the old ingredients or merely subsisting off the organic dust that has accumulated on and in non-food materials that have been stored for a long time. Rodents and other insects may find harborage in areas such as these that are not frequently disturbed by humans. I once found a collection of unused scales that had been placed on pallets and covered with sheets of plastic. However, the scales had not been thoroughly cleaned prior to storage and a significant population of German cockroaches had developed in the area. In addition, much of the leftover soil was supporting colonies of mold.

Pedestrian doors located in seldom-visited areas of warehouse spaces are subject to bottom gaps and ineffective locking devices or may be used as access to non-designated smoking areas. In one instance, a rainwater leak had created a shallow puddle just inside a poorly sealed pedestrian door and a large population of psocids had developed in the area. Similarly, due to the presence of poorly sealed overhead doors at the loading docks, flying insects frequently gain entry to the building and spider populations can develop nearby to take advantage of this food supply. Accumulations of webbing and dust on overhead and wall structures near the dock doors are a common finding in such areas. Once again, make sure your internal inspectors are thoroughly reviewing the warehouse and storage areas in your facility.

DOCK LEVELER PLATES. Gaps at leveler plates and accumulations of spillage and debris in the pits under the plates are two common issues that will reduce your audit score. This involves only the horizontal style plates with “pits” underneath. These pits are open to the outside and are thus accessible to all sorts of insects, rodents and other vermin. Once a pest has accessed a pit, it is very easy for it to gain entry to your building if the seals at the rear and sides of the leveler plate are not tight. However, I frequently see another problem with these devices. When installed, a steel angle-iron framework is mounted to the concrete at the floor edges of each pit (sides and rear). While being installed, this framework is adjusted to provide a “squared” opening in which to install the movable leveler plate. When the installation is complete, the framework becomes a fixed part of the leveler assembly. Frequently, the ends of the rear frame do not fit flush with the side frame-members. This creates additional gaps that can be difficult to seal.

I have observed pieces of leveler plate seals, caulking material and pieces of rubber stuffed into these gaps. Eventually, all of these materials degrade and the gaps return. Small pieces of steel, properly welded in place, create a permanent fix to this problem and eliminate some potential pest entry points. It is also important to keep the pits clean and free of debris so pests do not find food and harborage.

CHEMICAL STORAGE. Chemical storage is a food safety and food defense issue. Sanitation, maintenance and janitorial chemicals must be stored in a secured manner when not directly under the control of an authorized user. I frequently find trigger-sprayer bottles containing glass cleaner, sanitizer solution or general purpose cleaner and containers of lubricants being stored on a shelf or in an unlocked cabinet next to exposed products or ingredients. In some plants, production workers do some minor cleaning/lubricating during change-overs or mechanical downtimes. However, if the chemical is not approved for food contact, most food safety/defense audit standards require that it be secured while production is running and that access be restricted to authorized personnel. These chemicals represent a potential source of accidental or intentional product contamination.

It also is strongly recommended that an ongoing inventory of all non-food-grade chemicals be maintained to provide a record of the user, the chemical type, the amount used and when it was used. This allows supervisory personnel to spot sudden spikes in chemical usage that may indicate a leaking container or a more serious issue. Make sure your food safety team is routinely inspecting shipping/receiving areas and maintenance shops. These are the areas where uncontrolled cans of aerosol paints and pesticides, such as wasp spray, are found. Once again, these items must be stored securely and their usage must be properly documented.

TRASHCANS. If indoor trashcans are overflowing or contain decaying organic material, this represents a sanitation problem. In some cases, I have found populations of small organic breeding flies (e.g., fruit or phorid flies) in or near trashcans that are not emptied and washed frequently enough. More often, the trashcans contain things like empty beverage containers, gum and candy wrappers or empty snack food bags. These findings indicate a lack of compliance to plant GMP policies and may signal a need for more thorough food safety training programs and enhanced supervisory monitoring.

GLASS AND BRITTLE PLASTICS. Most food plants do a very good job of eliminating non-essential glass and protecting or monitoring any that remains. However, sometimes these efforts are focused mainly on the food storage and production areas. For example, it is not uncommon to find unprotected glass lighting components (i.e. incandescent bulbs or fluorescent tubes) in support areas such as break rooms, restrooms, maintenance shops and equipment/supply storage rooms. While food products, ingredients and packaging supplies typically are not stored in or transported through these rooms, they are in close proximity to areas that do contain sensitive materials and plant personnel travel through these support areas frequently.

Broken glass that reaches the floor in a support area can be easily transported to areas of the plant where it may enter the product stream. This may occur on the soles of shoes, on the wheels of tool carts, or on non-food supplies that are transported through production areas. I have found broken glass fragments in production areas where unprotected glass did not exist within a 100-foot radius, except on the other side of a nearby pedestrian door that served as an exit from the parts storage room where fluorescent tubes were not protected. Shielding or otherwise protecting glass to prevent dispersion if accidental breakage occurs should be plant policy.

SCALES. Many food-manufacturing processes require the use of scales to weigh ingredients or confirm the weights of intermediate or finished products. Scales are frequently located in ingredient handling areas, near production lines, at quality check stations, and in packaging areas. Typically, spare scales are stored somewhere in the building. Depending on the designs of these scales, significant opportunities for sanitation and pest harborage issues can exist in and around the devices. When doing self-inspections, lift the top plates from scales and check underneath. Sometimes accumulations of old products or ingredients, mold and insect populations are found. Also, check under the scale bases and inside drawers or cabinets in stands used to support the scales. The items you find stored in these areas may surprise you. If you have floor scales, the same precautions apply. Older style floor scales may involve a pit that requires periodic cleaning and newer scales will have a removable top plate. If scales are taken out of service for some reason, remember to thoroughly clean them before storage.

UNSEALED ELECTRICAL BOXES AND CONTROL PANELS. While sanitation and maintenance managers in most facilities understand that unsealed electrical boxes and control panels can be a source of pest problems, they often do not receive attention. Dust accumulations and all life stages of pest populations, such as confused flour beetles, often are found in these enclosures. On occasion, I have found the inside panel to be clean and pest free at first glance. However, upon closer examination, a carton containing spare electrical parts was stored inside the panel and soil accumulation and insects were inside the carton. Frequently, manuals and schematics also are stored in the panels and can harbor dust and bugs. Make sure you examine the contents of all electrical boxes and control panels routinely and maintain the inside of these units as a hostile environment for insects.

CONCLUSION. While this list is not exhaustive, it does represent some common potential issues represented in many food plants. If your food safety management team directs greater attention to these areas, you may find that your facility is much better prepared for your next audit experience.

The author is Food Safety Auditor, AIB International.