Developing Effective Internal Audits

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Developing Effective Internal Audits

• Richard H. Dougherty
• Washington State University
• Pullman, WA 99164-6376
• 509-335-0972
• dougherty_at_wsu.edu
• 103007

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What is an internal audit?

• An audit conducted by you (or your employees) on
  your company/facility us on us
• Vs a third party audit (independent audit on us)
• Vs a secondary audit (audit on us by a customer)

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Purpose

• Continuous improvement
• Corrective actions
• Assessment of effectiveness of overall (or
  portion of) programs
• Identification of problems before they get out of
  control
• Program requirement (SQF, BRC, GlobalGAP)

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How do we do internal audits?

• Frequency
• Ag operations 1-2 times /year
• Processing/packing facilities quarterly or
  monthly

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How do we do internal audits?

• Mechanism depends on company size and
  objectives
• Could be corporate internal audit or individual
  facility internal audit or both
• Who?
• One person does all audits
• More than one person splitting audits
• Alternating people
• Group of people alternating portion of the audits

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Characteristics of a good auditor

• Integrity
• Observant
• Inquisitive
• Non-confrontational
• Persistent
• Ability to deal with conflict
• Understanding of principles involved
• Familiarity with general operation
• Not directly responsible for audited area
• Trained

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Reporting/Documentation

• Observations
• Verbal during and at conclusion of audit
• Written within 1-2 days after audit
• Corrective actions
• Written what and timing
• Written - completion

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Developing the Check List

• Consider
• Food safety/HACCP programs
• Support programs
• Pre-requisites/GMPs/GAPs
• Food quality programs

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Check List Considerations

• At CCPs
• Monitoring methods
• Monitoring frequency
• Records
• Corrective actions
• Records review
• Calibrations
• Other verifications
• Record security

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Check List Considerations

• Flow diagram correct (?)
• Quality
• Monitoring methods
• Monitoring frequencies
• Records
• Corrective actions
• Records review
• Calibrations
• Records security

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Check List Considerations

• Personnel
• Hygiene and cleanliness
• Smoking, eating, drinking, chewing, toothpicks
• Hand washing and sanitizing
• Jewelry
• Gloves
• Protective clothing (aprons, smocks, uniforms,
  etc.)
• Hair restraints, hair nets, beard nets, etc.

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Check List Considerations

• Personnel (contd)
• Personal items
• Personal food
• Employee health
• Wounds, cuts, abrasions coverage
• Items removed from pockets above waist

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Check List Considerations

• Employee Assistance
• Drinking water available
• Designated area or hooks/hangers for protective
  clothing
• Lockers and surrounding areas clean
• Break rooms and contents clean (including
  refrigerators, microwave ovens, etc.)
• SOPs posted and current

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Check List Considerations

• Visitor Requirements
• Sign in/out
• Policies/guidelines for visitors
• Accompanied?
• Badges or identification

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Check List Considerations

• Potentially Hazardous Chemicals
• Storage secure and lockable
• Signage
• Handling instructions
• MSDS
• Transfer vessels
• Tracking
• Inventory/usage logs

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Check List Considerations

• Food Grade Lubricants/Chemicals
• Use
• Storage
• Separated from non-food grade
• Grease guns, lube cans marked
• Hand Dips, Foot Dips, Hand Sanitizers
• Monitored (records)
• Used
• Maintained (records)

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Check List Considerations

• Toilets and Hand Washing Facilities
• Clean and working
• Serviced and maintained (records)
• Warm water
• Soap
• Single use towels

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Check List Considerations

• Cleaning and Sanitation Program
• Master Sanitation Schedule current, maintained,
  and followed
• Procedures readily available and followed
• Cleaning equipment and materials properly stored
• Items used for cleaning and sanitizing
  appropriate for their use (no steel wool, wire
  brushes, etc.)
• Protective clothing appropriate, worn, cleaned
  and properly stored
• Verification (records)

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Check List Considerations

• Pest Control
• Free of evidence of pests
• Schematics/maps current and complied with
• Traps located properly and securely
• Traps numbered and functional
• Traps serviced (records)
• Service reports available
• Corrective actions completed

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Check List Considerations

• Pest Control (contd)
• Insect lights properly located
• Insect lights serviced
• Bird control
• No dogs, cats, etc.

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Check List Considerations

• Processing/Packing Areas
• Doors closed when not in immediate use
• Clean
• Free of flaking paint and corrosion that could
  contaminate products
• Food contact utensils off floor
• Walls, floors, ceilings clean and in good repair
• Overhead equipment and areas clean

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Check List Considerations

• Processing/packing areas (contd)
• Plastic strip curtains in good repair and working
• 18-inch internal walls perimeter maintained
• Lighting adequate
• Food contact surfaces free of cross contamination
• Food containers clean and sanitized (as
  appropriate)

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Check List Considerations

• Processing/Packing Areas
• Products, ingredients, raw materials, packaging
  free of and protected from contamination
• Floor drains clean free of off odors
• Free of standing water
• No product accumulation
• Waste and garbage addressed promptly and properly
• Free of cross contamination/product adulteration
  potential

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Check List Considerations

• Storage Areas
• Clean
• Floors, walls, and ceilings in good repair
• Utensils stored clean
• Doors closed when not in immediate use
• Pest proofed
• Temperature controlled and monitored (records)
• Atmospheres controlled and monitored when
  appropriate (records)
• Free of potential cross contamination and product
  adulteration

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Check List Considerations

• Maintenance and repairs
• Shop reasonably organized and clean
• Daily pre-op evaluations (records)
• Preventive maintenance program (records)
• Maintenance logs maintained and current (records)
• Cleaning after repairs/maintenance (records)
• Tools appropriate (clean, cleanable, etc.)
• Free of unapproved temporary repairs

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Check List Considerations

• Maintenance (contd)
• Free of excess grease/lubes on equipment
• Drip pans properly used when needed
• Spills addressed promptly
• Contractor policies and protocols being followed
• Compliance with hygiene and personnel practices
• Protocols being followed

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Check List Considerations

• Receiving
• Approved supplier program being followed
• Records and documentation
• Tracking incoming goods
• Integrity of vehicles and goods documented
• Seals/ locks (records)
• Product requirements met
• Procedures followed to storage

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Check List Considerations

• Shipping
• Records and documentation
• Tracking system (records)
• Seals/locks (records)
• Outgoing vehicles checked for cleanliness, good
  repair, etc. (records)
• Vehicle temperatures and other requirements met
  (records)
• Procedures followed from storage to loading

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Check List Considerations

• Exterior and Surrounds
• Free of litter, weeds, standing water, etc.
• Dust controlled
• Outside dumpsters, garbage bins, etc. covered
• Waste and garbage addressed promptly and properly
• Free of potential pest harborages

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Check List Considerations

• Foreign material
• Glass and hard plastics policy and protocol
  followed (documented)
• Glass and hard plastic inventory (records)
• Lights protected
• Metal detection and removal

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Check List Considerations

• Records
• Legible and permanent
• Free of white-out, erasures, pencil entries,
  ink-outs
• Secure
• Current and compliant with policies
• Free of falsification or appearance thereof

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Check List Considerations

• Employee information
• GMP signs
• Evacuation protocol
• Emergency information
• SOPs

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Check List Considerations

• Allergen Program
• Receiving
• Ingredient identification and storage
• Scheduling
• Utensils
• Cross contamination potential
• Cleaning procedures followed
• Labeling
• Right labels on right products
• Finished goods storage

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Check List Considerations

• Food Defense/Security
• Locked doors and gates
• Employee badges
• Records of key holders
• Outside lighting effective
• Cameras in place and functioning
• Security services

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Check List Considerations

• Other
• Water testing records
• Other calibrations (scales, penetrometers,
  refractometers, pH meters, etc.)
• Hold policy compliance
• Rework/repack handled properly
• Containers marked for their use
• Training logs current

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Check List Considerations

• Specific program requirements
• Marks, logos in compliance
• Verification of corrective actions from earlier
  audits

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• QUESTIONS?
• COMMENTS?