Inspection Checklist Syndrome

During a recent training program with a group of food plant supervisors, several participants asked for a copy of the checklist I would be using to inspect their facilities. When I told them I did not use a checklist to conduct an inspection, there appeared to be confusion and apprehension about what to do. This was further emphasized when we came across a liquid running down a cover over a product conveyor and into the process flow. They took pictures of it and were ready to move on to the next area. Without a guide to point out the importance, they did not assign any significance to the issue. This became an immediate educational opportunity for them.

Later, during the review of inspection findings, the supervisors were very confused about the standard I was using to evaluate the issues found. Were they major or minor issues? Compliant or non-compliant? When told I used the GMPs, along with their own prerequisite programs and policies, they seemed confused. Their concern was where they could get this list of things to check.

This was the very reason I was in the plant. Too many significant issues were being overlooked, resulting in product loss and additional costs. Someone had realized that the supervisors and managers no longer had the knoawledge needed to simply go find the issues. They had become blinded by the checklist mentality and conditioned to look at only what was listed.
 

Hands-On Education
Checklist inspections seem to have removed the curiosity aspect needed to conduct an inspection. A true inspection is an in-depth search for real or potential issues. One needs to investigate a finding to determine if it is of immediate concern or has long-term consequences. It involves physical exertion where you get on your back to look under equipment, move around on your knees picking and prodding at residue buildup to find pest activity, or climbing silos to look around on the top for issues. It is a tiring and often dirty experience.

Inspection skills cannot be learned from a classroom setting or by reading through standards. They are taught by hands-on experiences where the trainer explains the issue and how it could impact food safety.

You can give a uniform, flashlight, and notepad to just about anyone, send them out to search, and they will return with a considerable list. The skill that is lacking is recognizing when to dig deeper to discover significant issues that affect the product or process.

During training inspections, I often use the checklist the company uses to point out issues where they come up short. One common checklist item I often find is "Is the equipment clean?" The superficial cleaning that is easily conducted and seen in the areas often satisfies plant inspectors who mark the checklist as yes. It is only when they are instructed to crawl under the machine and collect a handful of product residue or open a side panel and find an insect infestation in the accumulated product debris that they realize they have not been inspecting the equipment with a critical eye.

If I were to put a label on what I commonly see being called plant inspections, I would have to term it a "passive walk through." We often do not recognize the space between our knees and feet as a potential area for issues to exist, so we spend little to no time on our hands and knees looking. Conversely, ladders or other equipment used to reach overhead areas are often ruled as too dangerous to use, so overhead areas are not inspected.

I was recently denied access to a six-foot-high, small platform behind a piece of equipment because I did not have fall protection. When I asked where and how I would attach the lifeline, they had no idea, but stated that if I climbed off the floor I would need a fall protection harness. I pointed out that by their interpretation of the safety policy, the person using the ten-inch platform to dump ingredients into the system would need a harness. Basically, people come up with a number of reasons to remain standing on the floor and convince themselves they did a great inspection.

Good, thorough inspections of food plants are just as important, if not more so, as looking at documented programs. Separately, each only gives a limited overview of conditions. However, when properly combined and done by trained personnel, they are powerful tools. They can be a proactive resource used to prevent minor issues from developing into significant concerns.

Every process has vital components that are monitored very closely. It is no different for the inspection process. Identify your most sensitive areas and place them on the watch list. Spend more of your inspection time focused on critical areas for the in-depth evaluation.

Many of the peripheral areas may not require an in-depth inspection based on your history or the condition they are in, so they require less time to confirm that no issues are present. A well-cleaned and maintained floor does not require hours of hand and knees inspection to confirm it is OK.

Inspection focus points should include product contact surfaces, product zones, and immediate product areas. Applying this concept allows you to evaluate the most likely source of product risk. Though product residue may collect on the exterior of a kettle, it is not likely to be introduced back into the product. However, the residue accumulation on the inside of the cover is a more likely threat. Realizing this as a location of concern, make a point to inspect the inside of the cover to determine the condition and age of this residue.
 

Trust Your Instincts
The checklist inspection is a great learning tool, but there comes a time when we have to step away from the restrictive list and understand the possibilities that exist in our facilities. Grab a flashlight, notepad, and a few simple tools, and go investigate below the surface. Learn from your experiences, but also challenge your knowledge by researching and broadening your knowledge. Trust your instincts through verification.

Dr. Bobby Corrigan, a respected industry consultant, once asked, "What is the difference between a good inspector and a great inspector?" His answer was simple, but profound: Great inspectors are keen observers. They ask questions, explore, experiment, think, analyze, and draw conclusions based on research data. Your value and contribution to a facility increases when you educate yourself and become a great inspector.

The author is Head of Food Safety Education, AIB International.