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Reviving Food Safety Audits

 

Diversey’s Lead Consultant, Auditor and Tutor, Abhijit Patil highlights the importance and conduct of Food Safety Audits

 

Filed under
Food Hygiene
 
June 23, 2021
 
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Reviving Food Safety Audits
 

Abhijit Patil, their talented Lead Consultant, Auditor and Tutor

With the current upsurge of consumer demands for food safety and security, legal regulations are further fine-tuned, which ultimately demand that food businesses be more credible, transparent and effective in the way they execute business. 

Diversey Consulting is at the helm, providing trusted mentorship to businesses and individuals to help them unleash their true potential and make their businesses safe and compliant. Apart from their comprehensive and integrated approach to project consulting and employee training, they pride themselves in their approach to auditing.  While the use of modern internet technology and data analysis has been a way of life for over a decade, their best resources are their people who bring to the forefront mature time-tested auditing skills.

From processes and products to systems and technology, their audits focus strongly on the ‘people-factor’ and their behavior allowing major reasons for failure to come to light. This enables audit reporting to be extremely valuable to the senior management and corporates, as it presents an unbiased reflection of how day to day situations, compliance matters and emergencies are handled from the shop floor to higher management levels.

Abhijit Patil, their talented Lead Consultant, Auditor and Tutor, dares to share some of his experience based skills that has made him one of the most formidable auditors. “My keen belief in life protection, hygiene and a  drive for excellence in whatever I do,  motivates me to be an accountable individual and keep learning,” is a belief that Abhijit lives and reiterates every day at Diversey Consulting. 

Abhijit Patil, Lead Consultant & Auditor Diversey Consulting 

Abhijit has a diverse 17 year career in multiple disciplines ranging from management systems consulting & training; third party auditing and certification; dairy manufacturing; confectionery manufacturing / R&D and retail quality management. His consulting career with Diversey Consulting  for over 8 years and his third party auditing & certification experience in India & the Middle East for over 4 years has exposed him to various types of businesses namely hospitality, food and beverage manufacturing, retail, trading, etc. across India, Middle East, Levant, Europe and South East Asia. He has been witnessed by the Dubai Accreditation Centre (DAC) and the Joint Accreditation System of Australia & New Zealand (JAS-ANZ) as a Food Safety Auditor.   

Abhijit has completed his Master’s Degree in Food Science with a Post-Graduate Diploma in Food Safety & Quality Management and a Diploma in Dairy Technology. He is a Lead Auditor in ISO 22000 / HACCP & ISO 9000. 

AUDITING STRATEGIES FROM DIVERSEY CONSULTING

Note: These may be applied to all kinds of audits including internal, second party and certification, as applicable

Sr. No.

Considerations for Effective Auditing

Experience-based Suggestions

1.

Awareness and clear understanding of the audit objectives

Seeking to clarify the audit objectives prior to the audit helps in planning the audit methodology including audit focus, depth, time, questioning techniques, etc. Generally first time audits must target compliance and sufficient levels of awareness whereas surveillance or follow-up/ routine audits may focus on verifying workplace culture and system effectiveness.

2.

Correct interpretation of and alignment of the finding with the audit standard and audit criteria

 

The auditors must be in total alignment with what they are supposed to audit and not what they want to audit. This is to prevent oneself from going off-track, e.g. quality management criteria do not necessarily correlate to food safety criteria.

Disputes may be avoided by ensuring that objective evidences are explained and agreed upon at the place of the audit. If there is an operational concern which cannot be attributed to a straightforward clause in the standard or company documentation, it is best raised as an improvement area.

In general, follow the rule: no requirement=no nonconformity.

3.

Accurate and fair presentation  of the audit finding

A fairly presented finding will accurately guide the senior management about their team performance, build trust and direct the team to develop targeted supervision capabilities. There is a huge difference between ‘floors were found to be dirty’ and ‘under equipment areas were found to be dirty’. The latter simply means that under equipment areas are missed out during cleaning while the former appears to convey that the cleaning was not done.

Finding description must include the 5-W’s and 1-H, as applicable: What (specific batch, ingredient, process criteria); Where (department, activity, area or equipment); When (date, time, frequency); Who (designation / position – avoid names); How ( factual details of occurrence). The last W is about correlating the occurrence against the standard clause reference / document requirement which justifies the finding. Remember to pinpoint the exact reference, e.g. 4.3(b) and not just 4 or 4.3. 

Photographs speak for themselves, so try to incorporate them as a part of your internal audit reporting.

4.

Auditor selection based on risk-based industry knowledge

This ‘one size, fits all’ approach to auditor selection is dangerous to the wellbeing of both the parties. Auditors experienced on a fully automated low risk process (e.g. bakery, spices, tea, etc.) cannot be deemed competent to audit a high risk food handling operation managed manually (hospitality, catering, etc.). The result is either concerning levels of ‘under-auditing’ leading to a superficial audit missing out on critical areas or unnecessary ‘over-auditing’ leading to findings that demand resources not justified.

5.

Auditor screening based on auditor agility or physical fitness for the respective project

Some auditors find comfort in performing desktop documentation audits and record verification with little scope for performing live process audits on-site. The reasons could range from genuine health concerns to extreme lethargy and in some cases drudgery over another day’s audit. Tolerating cold environments, trouble bending down and verifying under equipment cleaning, mental boredom when auditing similar environments, etc. are some of the challenges. To make it worse, a poor quality verification is further aggravated with a report where customers are told what should be done generally to comply rather than what is not done specifically to comply with a requirement.

6.

Balance between documentation and on-site process audits

While some auditors may insufficiently audit the process on-site, still others may insufficiently review documentation for adequacy. Hence the common belief “Documentation is not as critical as the process”. It is hard to comprehend how the documentation aspect can be devalued, especially when this very documentation represents your management intent and the operating standards for business execution. Also,  it is essential to move out of the comfort of your seat and withstand the pressure of being on your feet while you :

-      Interview: relevant staff across the organization including suppliers and customers, where appropriate

-      Observe: actual practices, hardware, facilities, equipment metrics, etc.

-      Examine : supporting documents and records to  correlate observations with instructions and data

7.

Time management

Despite prior planning, unexpected occurrences may occur needing more time for a function verification. With the support of the audit team and the auditees, an audit program may be amended midway to accommodate the sudden need.

8.

Use of organoleptic  / sensory evaluation

To enhance your auditing techniques, use sensory evaluation as one of the methods of gathering evidences, e.g. observation / visual inspection; listening carefully to the auditees or equipment vibrations; smell check for food freshness or ambient air for moulds /stagnant drains ; feel for ambient temperature, loose floor tiles, etc. All of these may not be measurable / quantitative but are still qualitative and must be agreed with those concerned.

9.

Bahaviour based food safety auditing

This technique is the pinnacle of audit maturity and focusses on people behavior which ultimately defines the organizational culture. While no single approach is perfect, auditing cues may include hygiene behavior of food handlers during work / break times, use of garbage bins ( anti-littering) in locker rooms & back of the house areas, timely reporting of failures, etc.

10.

Making your ‘sixth sense’ objective

The sixth sense or gut feel which increases with maturity, experience and age gives us a dreaded feeling that all is not right but is still not regarded as ‘acceptable’ in an audit due to the lack of objectivity. Nevertheless, the power of sixth sense can guide us towards areas of further interest which may unveil a real objective finding. A few experience based examples include:

-  severe discrepancies in date coding integrity, e.g. staff information differing from date labels, pasting extended shelf life date labels exactly on top of expired food labels, etc. Label peeling, selecting hard to reach foods, interviews may help in establishing facts.

- fabricated records, e.g. readings for 30th Feb / 31st April, omission of numbers after a decimal point for temperature probes or gauges, cooking temperatures for stock at 75℃ ( should be higher), etc.

11.

Auditing across the hierarchy & related functions

To evaluate the complete system, always cover the generally neglected areas like top management, customer complaints, staff change rooms, personal lockers, staff cafeteria, waste handling areas, food service at lounges / take away, treatment of domestic water which is used for food preparation or cleaning of food premises, etc.

12.

Use of the required auditing tools

Access to the right tools such as thermometers, torch, etc. must be ensured which will enhance your ability to gather evidences. A torch is priceless when it comes to checking cleanliness levels under the sinks or behind and under equipment, pest infestation, etc. where poor lighting or shadows leads to reduced visibility.

13.

Make it creative; keep it exciting; foster team learning

Audits must attract the auditees to the subject and the greater good. The focus is on processes and not on the person. Relooking at audit techniques, audit flow (forward or the backward approach), allowing internal auditors / process users to evaluate their own activity provide an understanding of their own self-awareness and competence at the workplace and is a method of validating real time internal audits or supervision by the auditor.

14.

Lead by example without compromising your own credibility

Apart from the many good auditor traits which we learn in numerous internal auditing courses, the least talked about is the need to maintain undisputed personal hygiene standards. These include professionally styled clean, comfortable and safe clothing covering the body and footwear; personal grooming / hair secured and covered; absence of bad breath and body odour; clean and short nails free from nail varnish; restricted or no jewelry in process areas;  bad unconscious habits like scratching nose or hair; hand washing as required; habits that prevent contaminating food contact surfaces, etc.

 

Diversey Consulting takes fair advantage of its positioning as a non-third party certification body to courageously report truths in a constructive manner, present possible root causes as detected and  suggest recommendations following a prescribed hierarchy of controls. This consultative reporting helps businesses to investigate failures more accurately and identify the closest corrective actions enabling them to be spot-on and more effective. 

“At Diversey Consulting, our aim is to share learning, build talent, foster responsible behavior and earn success responsibly as we continue to grow with the industry and community and jointly contribute to a safer, cleaner and sustainable environment,” according to Nina Da Costa, Diversey Consulting Manager- MENA.

Diversey Consulting is your trusted ‘Sustainability Business Partner’ to protect your triple bottom-line, namely the  ‘People – Planet – Profit’. Our consulting, training and auditing expertise fortifies your  Food Safety, Health & Safety, Environment and Quality Management enabling you to build a responsible and sustainable business for a safer and greener tomorrow.

 

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