Q. Several of our major customers have asked us to have unannounced audits, but management is concerned that it will be a problem if key company personnel are not on-site during these audits. What are the benefits for unannounced audits? Why would our customers prefer them?
A. Audits are a way of life in our industry and the debate about announced vs. unannounced audits has been going on for years. Regulators and customers fully expect that all food products are produced under sanitary conditions at all times and that any unsanitary condition would be immediately corrected and prevented from reoccurring.
Some companies put significant effort into preparing for audits. This preparation can take the form of performing extra cleaning and maintenance tasks, reviewing and updating records, preparing personnel to answer questions, preventing audits from occurring at peak production times (e.g., around holidays), and other actions that could influence the audit results.
If a company tries to enhance its food safety appearance or prepare records prior to an audit, it is likely sending its employees the message that it is acceptable to operate at a higher level when audits are being performed. Operating at two different levels of food safety could have a detrimental effect on fostering a consistent food safety culture if you aren’t operating your food safety systems in the same way every day.
From a third-party audit perspective, companies that have adopted unannounced audits generally relay that they have a consistent, positive impact on their food safety culture. Think about it, all employees are empowered to meet the challenge of being compliant for any type of audit, whether regulatory, customer, or third-party. Management feels secure that any auditor can walk through the door, and there will be no need to perform additional audit preparation to achieve a good result. By expecting plants to be audit ready every day, the company communicates that there is only one acceptable food safety level that must be in effect at all times.
You can address the concern about key personnel not being in attendance by cross-training personnel so that your company could effectively handle unannounced audits. All too often, the absence of a QA manager, HACCP coordinator, or department head makes record access or program information difficult or incomplete. Cross-training would resolve that issue and strengthen your organization.
Since regulatory inspections by state and federal agencies are unannounced, it would be advantageous to have a system in place that has proven that you are ready for an unannounced audit event. With the Food Safety Modernization Act (FSMA) being issued this year, regulators will challenge food processors to take a fresh look at reducing preventable recalls through Hazard Analysis and Risk-Based Preventive Controls (HARPC). Operating your facility on a consistent sanitary level and having a positive food safety culture will provide a higher confidence level.
If an organization cannot agree to unannounced external audits, consider having unannounced internal audits and GMP inspections to prove that the organization is in a constant state of food safety readiness.
The author is Global Innovation Manager, Food Safety Services Innovation, AIB International.