This article is written to meet the following sections of the Standards:
|BRCGS Food Safety Issue 8||3.4.4 Documented inspections|
|BRCGS Packaging Issue 6||3.5.5 Hygiene and fabrication-based inspections|
|BRCGS Agents & Brokers Issue 3||n/a|
|BRCGS Storage & Distribution Issue 4||3.2.5 Documented inspections|
|FSSC22000 Version 5.1||2.5.12 Site inspections|
|IFS Food Version 7||5.2.1 Site and factory inspections|
|SQF Edition 9||184.108.40.206 GMP inspections|
If you’re a food site, a food-contact packaging site or a storage and distribution site, you need to do GMP inspections.
Agents and brokers don’t need to complete GMP inspections as they don’t have a physical facility to check. Non food-contact packaging sites can complete GMP inspections if they wish to (it would definitely be good practice) but the BRCGS standard doesn’t state that they must either.
A GMP inspection, is not a systems audit, so you don’t have to record evidence of conformance. It’s a more practical assessment, which is why we call it an inspection (not an audit). A format which allows conformance or non-conformance to be ticked, is acceptable. Where there’s a non-conformance, then what was wrong and what to be done to correct it must be documented.
As a minimum GMP inspections must look at hygiene, clean as you go, equipment, fabrication and personal hygiene.
For more information on the scope of GMP inspections refer to Managing the internal audit programme.
There are a lot of requirements in the standards about how system audits must be carried out, but no requirements about how GMP inspections must be carried out. They state what the inspections must look at and that inspectors must be impartial – but that’s about it. So here is a guide about what must be checked and key points about completion of GMP inspections.
How often GMP inspections must be completed must be based on risk, but this doesn’t mean you need to have a huge risk assessment. Think of it as a level of risk – from high-risk areas being the riskiest, to external areas being the least risky. Therefore, high-risk areas must be done frequently and external areas infrequently – with other areas fitting in order of risk in-between.
The standards and retailers also have specific requirements around the frequency of the GMP inspections. For example, an additional fabrication inspection and a hygiene inspection must be carried out once every 3 months.
The following provides an outline of the type of good manufacturing practices and practical controls that must be assessed during the GMP inspections.
Records must be completed following the procedure and all data entered onto records must be legible. Data recorded must be accurate.
Staff, visitors, and contractors must adhere to personal hygiene and protective clothing rules.
Fabrication, equipment, and tools
The fabrication in the area, equipment and tools, must be clean and not pose a foreign body risk.
Wooden pallets must not be present in open product areas.
Engineering equipment must be correctly stored away when not in use.
Allergen equipment must be used and stored correctly.
Knives must be labelled and in good condition. Snap off blades must not be present.
Spills must be addressed at the earliest opportunity.
Pooling water must be cleared away regularly.
Hosepipes must stored off the floor. Drains must be clear and not smell.
Cleaning equipment and chemicals must be correctly stored away when not in use.
Waste must be segregated and emptied regularly.
Pest monitors must be in good working order, secure and clearly labelled.
Where access controls are required, these must be in place.
Digital systems must not be left unsecure.
Any materials that are non-conforming must be clearly labelled, so that they don’t get used by mistake.
Completing the GMP inspections
The GMP inspector must be trained so that they know how to follow the internal audit programme procedure and complete the related GMP inspection records.
It’s also a good idea to train inspectors on how to:
- Organise the inspection with the person that’s responsible for the area.
- What to look for, including good manufacturing practices (GMP) as detailed above, and practical controls (CCPs, process controls and records etc.)
- How to identify and record non-conformances.
- Communicate the results.
- How to close out any non-conformances that are completed during the inspection.
- How to submit the inspection.