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Preparing for a Third-Party Food Safety Audit
by Zia Siddiqi, PhD, BCE
Editor’s Note: This is the first in a five-part series of articles that will provide a practical approach to various pest control topics.
Imagine you’re a student who is aware of a major exam scheduled for the end of the month. Instead of studying throughout the week leading up to the exam, you decide to cram the studying into the final 24 hours prior to the exam. You might be thinking to yourself, “That leaves far too much to chance—what if there isn’t enough time to cover a certain concept in-depth, or to ensure a full understanding of the subject on the whole?”
Those are the same concerns that come along with preparing for a third-party food safety audit. If a facility manager leaves preparation for the last few weeks leading up to the audit, it will most certainly spell t-r-o-u-b-l-e for his or her food safety audit score. Because business success hinges on an outstanding audit score, it’s easy to understand the dangerous consequences a lack of audit-readiness can bring.
Three of the most common third-party audit standards for food processing facilities are Safe Quality Food (SQF), the British Retail Consortium (BRC), and American Institute of Baking (AIB). Third-party auditors such as NSF and others use those standards to ensure facilities are compliant with the criteria of the Global Food Safety Initiative (GFSI), which was created in 2000 by a group of international food retailers to help ward off food safety hazards. Although GFSI does not conduct audits, major retailers like Wal-Mart require all suppliers to meet GFSI standards. That means your facility needs to meet or exceed audit standards every time.
Pest management can account for up to 20 percent of the total audit score, so ensure you are proactively preventing pest activity by implementing an ongoing, comprehensive Integrated Pest Management (IPM) program. With a focus on strategies like sanitation and facility maintenance, IPM helps keep facilities pest-free, which is exactly what auditors like to see. However, without proper documentation that spans a length of time, it will be virtually impossible to prove the success of your pest program.
Although the varying audit standards and criteria can be confusing at times, don’t let them “school” you. Keep in mind the following top five audit problems when it comes to pest management documentation in order to be audit-ready at any time and achieve high scores.
- Lack of training or certification proof for pest management professionals. Although your pest management professional may have the proper training or certification required to perform the job, it won’t mean anything to auditors if that evidence is not housed at your facility. Auditors may require any or all of the following documents as part of their audit:
- A photocopy of the registration or certification document for every individual who regularly executes pest management services on the property, if required locally
- Confirmation of Good Manufacturing Practices (GMPs) training for all individuals who are held accountable for performing pest management processes
- Written evidence that the IPM provider was trained in the proper and safe use of pest management materials
- Written proof of changes to service and materials, following signing of the contract. Successful IPM programs are dynamic rather than static and change over time based on a number of factors, so it’s important that you remember to document all changes to the program after you sign the contract with your pest management professional. Written proof of even the slightest changes to the elements of your current pest management services, and reasons for the changes, is required. Also consider including a list of roles and responsibilities that explains the duties of your facility’s staff against those of the pest management provider’s team.
- Corrective actions are not based on pest sighting and pest activity reports. Ensure that your pest trend analysis and recommendations for sanitation and building maintenance issues provide the basis for all corrective actions that help manage insect activity at your facility. Third-party auditors often deduct points from audit scores when facilities do not have written documentation of pest sightings and pest activity, accompanied by an explanation of the resulting counteractive efforts.
- No records of insects found in light traps and pheromone traps or corrective actions, although the traps are inspected regularly. Documentation of all services provided to light and pheromone traps are typically required by auditors. This includes the types of insects, as well as the quantities, that are found when the traps are checked. Although you may include this in your documentation, that doesn’t paint a comprehensive picture for auditors—they will also need to have an understanding of the corrective actions you took to manage the pest problem. It’s important that you can show written documentation of all steps:
- services performed to the light and pheromone traps,
- the results of each trap check, and
- the corresponding actions taken to help mitigate pest activity.
- Missing record of actions that were implemented following the annual pest control assessment. Almost all auditors require that pest management providers hold an annual facility assessment, which helps determine areas of improvement or necessary changes for IPM programs. Again, you should ensure that all of the corrective actions implemented after the annual assessment are documented, along with proof that those actions were actually executed. Without showing that the counteractive efforts were executed and completed, you may lose points on the pest management portion of your audit.
Now that you’ve armed yourself with this information on the top five common pitfalls when it comes to documentation, consider speaking with your pest management professional about how you can work together to achieve high audit scores. By working hand in hand to cover your bases, you’ll be on your way to acing your next big exam—your food safety audit.
Dr. Siddiqi is director of quality systems for Orkin, LLC. A board certified entomologist with more than 30 years in the industry, Dr. Siddiqi is an acknowledged leader in the field of pest management. Dr. Siddiqi can be reached at firstname.lastname@example.org.