[AIB Audit Prep] Last-Minute Audit Preparations Can Cost You

Quality and food safety managers have difficult jobs. On top of keeping employees in line, maintaining company food safety programs and managing the day-to-day activities of processing operations, they also are tasked with being prepared for customer and third-party audits. The week before audits occur, food plants usually take extra precautions to ensure that everything is functioning properly and in order. However, in some cases, it seems food plants have special programs they run to prepare for audits. 

Why are so many companies scrambling to make last minute preparations for audits? Is it simply to do a final review to ensure programs are functioning properly and no obvious errors have been overlooked? Or, are facilities temporarily raising their food safety and defense program standards to the levels they are expected to operate at daily?

When I provide in-plant food safety and food defense training, I observe incidents that I would not see during an actual audit. I recently provided in-plant training on how to do self-inspections. During the self-inspection, I witnessed four incidents that probably would not occur during a routine audit.

SCREEN THE SEMI. First, a bulk semi-tanker was being unloaded at an outside receiving station. There was no company representative in attendance; only the driver was present. I noticed the top hatch was open and a screen was not in place. I asked the driver if he used a screen on this hatch during unloading and he indicated that it was only necessary during the summer months when insects are present. However, boxelder bugs were located along the entire south side of the building where the unloading was taking place. This company’s policy was to always screen the top hatch during unloading, regardless of the time of year.

SECURE THE SEMI. Next, I noticed a parking lot full of trailers. All of the trailers were secured, except for one that contained finished product that had been placed on hold and was located in an unsecured area. The company’s policy was that all trailers containing finished products must be sealed with a tamper-evident seal while in the lot.

UNSECURED UNIFORMS. The third event took place when the facility’s uniform supplier made a delivery. I noticed that the uniform truck was parked in front of the building with its doors wide open. Four racks of clean, uncovered uniforms had been left on the sidewalk along the street. The delivery personnel were inside the building in the locker room. The company’s policy was for all uniforms to be handled and delivered in a safe and secure manner.

EMPTY FOOTBATHS. The final event occurred as I entered the production area. The footbath at the entry point was dry. Plant personnel informed me that this usually does not happen and it must have just been “one of those times.” The company’s policy is for footbaths to be kept filled for effective biological control of shoes entering production areas.

BRING YOUR ‘A GAME.’ As an outside inspector, these events do not reflect well on this company’s daily operating practices. However, it is unlikely that any of them would occur during a scheduled food safety or food defense audit because that’s when most facilities bring their “A game.” But, will preparing for an audit at the last minute provide an accurate snapshot of a food plant’s normal standard of operation? I would argue, no.

Obviously, no facility is ever perfect. The purpose of conducting self-audits is to determine your facility’s overall compliance level. However, if you have to go out of your way to prepare your facility for audits, it’s time to look at the root cause of the issues at hand.

Audit preparation can be quite costly. The time personnel spend preparing can consume several hours and may require specific maintenance, cleaning and pest control tasks to be conducted. I have even seen companies stop production for a short time to prepare for an audit.

CONSTANT VIGILANCE. Quality and food safety managers must challenge personnel to be in compliance with company policies and programs on a daily basis, not just when audits approach. They obviously are important since they were originally developed to achieve company food safety and defense requirements. So, why are they not important enough to maintain on a daily basis?

The main challenge is to instill a culture of food safety and food defense at your organization by ensuring all personnel are trained and educated on company policies and procedures and by establishing accountability. Training involves explaining how to perform tasks and responsibilities; educating involves explaining why they are important. Programs are not effective when employees do not understand why they exist.

For example, shipping/receiving training would include informing personnel that trailers must be secured with tamper-evident seals after they pull away from the dock. Education involves explaining that seals limit the potential for unauthorized access to the trailer and prevent possible product contamination or theft.

IMPORTANCE OF ENFORCEMENT. Once you have trained and educated all personnel on company policies, the next step is to consistently enforce them. Employees should be held accountable for their actions once they have been trained and educated. Quality and food safety managers are responsible for overseeing the company compliance level. It must be enforced on a daily basis to limit the potential for food safety and defense issues to occur. Establishing a culture of accountability can be even more challenging in today’s world of lean manufacturing, but the cost of recalls, the value of brand protection, and the potential for injuries or death make it a necessary goal. 

A ‘CULTURE ISSUE.’ During a recent training session, I challenged a facility to consider securing the top hatches of the bulk liquid tanks located outside the facility. Some of the quality managers indicated that this was impossible, because they couldn’t even get employees to keep the covers closed, let alone locked. I suggested that the managers evaluate this as a culture issue. In agreement, their corporate quality manager said, “It is the responsibility of the quality manager at each facility to be the conscience of the company, point out challenges, find solutions to the issues and ensure they are practiced on a daily basis.”

CONCLUSION. The next time you conduct a last-minute self-inspection to prepare for an audit, look at the issues that are identified, determine why non-compliance is occurring and identify the root-cause. By correcting the issues or practices that lead to non-compliance, you instill a culture of accountability for food safety and defense. Present the issues to management and illustrate how the cost of last minute audit preparations is greater than the value of investing in a plant culture focused on food safety and defense. The real cost lies in the risk the company is willing to accept by operating with non-compliance issues at hand. Last minute audit preparations can be more costly than meets the eye.

The author is Director, Food Defense, AIB International.