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FSS 2022: Internal Audits and Moving Beyond “Checking the Box”

summit session audits
May 10, 2022
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On Tuesday, May 10 at the Food Safety Summit, food safety and quality assurance (FSQA) and operations professionals gathered to present a session on internal audits and the importance of moving beyond a “checking the box” mindset. The session covered the importance of food safety audits, the types of food safety audits that can be employed, and the benefits of sharing ownership of auditing. 

The Significance of Auditing

Jen Fernan, Director of FSQA Standards and Supply Quality at J&J Snack Foods Corp., first took the stage to discuss the significance of auditing, as well as the types of audits that exist and how they can be maximized for efficiency and accuracy. She highlighted verification audits as a key area of focus not only for ensuring compliance to requirements, but also for verifying the effectiveness of corrective actions. “It is beneficial to go back and verify that corrective actions are effective,” stated Ms. Fernan, when discussing how to discern if an issue’s root cause was addressed and make sure that no new issues arise.

Ms. Fernan also discussed how audits are important for identifying gaps in a facility’s food safety and quality (FSQ) systems. “If you’re not auditing, you can’t fix the problem before there is a bigger issue on [your] hands,” she said. 

Conducting employee interviews as can be useful not only for auditing, Ms. Fernan added, but also in cultivating a healthy food safety culture by “making sure employees understand the ‘why’ behind what you’re doing.” She then outlined the types of audits a facility can carry out, the frequencies for which should be based on risk:

  • Good manufacturing practice (GMP) audits
  • Process audits vs. larger program audits
  • Sanitation audits
  • Data audits
  • Critical control points (CCP) monitoring audits.

Ms. Fernan specified CCP process steps as procedures that carry significant risk and, therefore, should be audited with greater frequency.

Ms. Fernan also discussed tools that can aid in the auditing process. Examples of such tools included the senses (i.e., sight, sound, smell, touch), cameras, flashlights, and black lights. Additionally, Ms. Fernan explained how checklists can be extremely useful, especially for auditors who may have less experience or insight into a specific area of focus. Checklists that encourage greater recorded detail often result in more thorough audits. “When developing your checklists, you want to make sure they are targeting exactly what your auditors are looking for,” Ms. Fernan said.

Connecting the Dots

Mike White, Director of Operations at J&J Snack Foods, presented on the topic of how facility operations teams can support FSQA by partaking in daily Gemba walks. “Gemba” is a Japanese word for “the real place,” which, in industry, signifies where the “real work” happens. Mr. White asserted that it is important for operations to take the lead on Gemba walks rather than FSQ because a facility’s operations staff often greatly outnumbers its FSQA staff. Mr. White explained that the more people who are involved in auditing, the better a facility’s chances are for catching issues before they become problematic. Furthermore, Gemba walks, when done routinely with clear intentions, can provide managers and supervisors with a simple means of supporting the overall continuous improvement of facility functions. 

Mr. White laid out the TPOF method, a five-step system for effective Gemba walks:

  1. Team: Identify, train, and prepare the team
  2. Plan: Have a plan and schedule for your Gemba walks
  3. Process: Follow the value stream and focus on the process
  4. Observe: While walking in teams, ask questions and document observations
  5. Follow up: Share observations with employees.

In following the TPOF method, Mr. White stressed the importance of focusing on the “process” or “problems” rather than the “people,” as Gemba walks are meant to help employees improve food safety, not to catch them in wrongdoings. In fact, Mr. White explained that employees can be an asset to a facility’s Gemba walks. “If your employees are trained well, they will tell you where the issues are,” he said. He stressed the importance of actively listening to employees during Gemba walks.

Additionally, Mr. White warned against suggesting changes to employees during Gemba walks unless there is an immediate people or food safety issue; rather, issues observed during a Gemba walk should be addressed in a follow-up. Mr. White highlighted the importance of following up on Gemba walks, saying, “There is nothing worse than finding an issue and never talking about it again.” Mr. White ended by pointing out that, once Gemba walks are implemented, they should be maintained indefinitely and consistently.

FSQ is Not the Sole Owner

Joseph Meyer, Global Microbiology Lead at Kerry, followed Mr. White to discuss the importance of all of a facility’s functions sharing the ownership of auditing and food safety with FSQ. He highlighted that the responsibility of internal audits can go beyond FSQ or even operations; all relevant functions inside a plant can be involved in FSQA, and facilities can make use of external resources, as well. Mr. Meyer explained that not only can auditing be overwhelming if solely taken on by FSQ, but that there is also “…a better food safety culture within an organization when more people inside the organization are thinking about food safety.”

When facilities consider who can get involved with auditing, it is important to note which types of audits can be natural fits for certain functions or people. “It is the person, not the function that makes a good auditor,” said Mr. Meyer. Qualities of a good auditor include a balance of analytical and soft skills. 

While involving many functions with auditing can present some challenges in training and calibration, the benefits outweigh the difficulties, Mr. Meyer said. Recruiting many functions to take part in auditing can produce a better overall food safety culture. According to Mr. Meyer, staff that are not traditionally involved in FSQA can “become your best advocates,” when their eyes are opened to FSQ priorities. Furthermore, sharing ownership of auditing can open new career paths for individuals and help maintain food safety culture over time. “There is a tremendous amount of talent and knowledge that leaves the industry; [sharing responsibility for audits] is a good way to preserve and share some of that,” Mr. Meyer said.

Closing Findings

Kara Mikkelson, Food Safety Program Manager at Hydrite, rounded out the educational session by discussing the importance of “closing the findings,” which she defined as “procedures to be followed when a non-conformity is found.” Ms. Mikkelson expressed that closing the findings is important because, while some corrective actions can be developed in advance, it is not possible to anticipate all corrective steps. Steps to closing the findings include understanding the root cause of an issue, documenting the corrective action plan, establishing a timeline, and conducting closure and effectiveness checks.

It is not always possible to determine the root cause of an issue through corrective action. However, Ms. Mikkelson suggested the “Five Whys” as a method for root cause analysis. The “Five Whys” method involves asking “Why did this outcome occur?”, selecting one of the reasons that is determined to be an answer to that question, and repeating the “why” process several times until a potential, actionable cause is reached.

Documenting a corrective action plan was highlighted as a key step by Ms. Mikkelson. “If it is not documented, it is not done,” she said. A facility can prioritize corrective action plans by risk, and then determine short-term and long-term plans for addressing said risk. In addition to documentation, communication is crucial. Findings, corrective actions, and changes to processes and procedures should be communicated clearly to management and employees alike.  

Finally, Ms. Mikkelson explained that corrective actions should always be subject to effectiveness checks, which includes auditors physically examining that corrective actions have been executed. If repeated non-conformities continue to occur, it indicates that that the root cause may not have been successfully identified, or that there is a possible system failure.

The 2022 Food Safety Summit is taking place in person at the Donald E. Stephens Convention Center in Rosemont, Illinois from May 9–12. Stay tuned for more conference coverage!



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