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||188.8.131.52 GMP inspections|
The internal audit programme
The internal audit programme consists of GMP inspections and system audits. This article covers the process of completing a system audit.
Internal auditors must be trained to complete robust system audits. The requirements of training of internal auditors has been covered in the article managing the internal audit programme.
The purpose of system audits
You’ll have heard many external auditors say that they’re looking for compliance, not non-compliance. But when carrying out internal system audits, the auditor does need to look for problems.
Finding a problem is a good thing as that’s what a system audit is designed to do. The aim is to find the problems before external auditors do and before they cause a problem.
A non-conformance found on a system audit is an opportunity to improve, and one less possible non-conformance on external audits.
A problem seeking mind
Finding problems comes with experience. But below is a list of things that the most experienced auditors do:
- Don’t be rushed when auditing. If you’re in the factory or the warehouse – stop and look around. Look up to see if there’s anything that could fall and contaminate the product. Look behind things, under things and on top of things. Look inside cupboards, or inside anything that can be opened safely. Watch what people are doing. Train yourself to see things, as if you are seeing them for the first time. If you rush, you’ll not see what’s right in front of you.
- Auditing is no longer just about the risk to food safety, it’s wider than that. Product integrity is important too. Think about what the customer’s perception of the area would be. One technique is to think about what your mum would think (as a typical consumer) if they could see what you can see. Another useful technique is to frame what you’re looking at with your hands, like you’re framing a photo. Once you’ve framed it with your hands, think about what the implications would be, if that photo was to make it into the media. It’s a really good way of seeing things clearly, exactly as they are in front of you.
- Always ask for evidence. If you can’t prove something happened, in the auditing world, it may as well have not happened, so ask for records to prove the clause that you’re auditing.
- Process, process, process! If a process is required to complete a check or carry out a task – is it written down? If not, how do people know the right way to do it? A great auditor will think to themselves – “if I was having to do this job, would the information given to me – be enough for me to know what to do?”
- Always check training. Just like with evidence, you can have all the best procedures, but you need to be able to prove that the people who are carrying out these tasks are trained. Pick one or two procedures from each audit, look at the records from the procedure in question and then pick a couple of people who completed them – then follow their training through.
- Follow your nose. An experienced auditor won’t audit every single clause of an audit, one-by-one. They follow their instinct. They’ll start auditing against the clauses, but then if something doesn’t feel right, they’ll deep dive into that element. If something doesn’t feel right to you, follow your instinct, and look into it further.
- Walk and talk it through in practice. Ask operators to carry out their tasks for you, rather than just explaining. While they’re doing it, ask them to explain it to you, as if they were teaching you to do it. Compare what they’re doing to the procedure as they do it. You’ll find that this highlights lots of problems with the procedures and the interpretation of what’s required.
- Always check the document control. Every procedure or record form should have document control information – so a great auditor will check this on every document they look at. Compare it to the document control log to see if the one in use is the current version.
- Cross check! Wherever there are key pieces of information, settings or specification limits written in more than one place, cross check each document to make sure they’re all the same.
The system audit process
The system audit process consists of the following steps:
- Complete the system audit.
- Identify conformance and non-conformance.
- Document the report, proving evidence.
- Communicate the findings.
Complete the system audit
System audits must be completed at the frequency set. Therefore, it’s critical that they’re done on time. This means that the first key point – is that the internal auditor must complete the system audit at the right time.
Identify conformance and non-conformance
How to identify conformance and non-conformance is an essential skill that every auditor must learn. This topic has been covered in detail in Identifying conformance and non-conformance.
Document the report, providing evidence
The internal auditor must complete the audit report following the procedure. Evidence must be provided of both conformance and non-conformance.
Communicate the findings
The internal auditor should have completed the system audit in conjunction with the person that’s accountable for that topic, meaning that there should be no nasty surprises. Once the audit report is finished, it’s good practice to review it together, so that any non-conformances can be discussed. This allows the accountable person to clarify any points needed. This will streamline the process of completing any non-conformances that have been raised.