The news that ASDA is to commence unannounced audits on its suppliers presents significant challenges for hundreds of food companies. In my previous blog on the subject I explored some of the general impacts on both the auditor and company arising from a system where no previous appointment or notification is provided. Here I will address the specific impacts on the food company and what it can do to properly prepare and maintain standards sufficient to pass an audit comfortably.
Why Unannounced Audits Make Sense
The rationale behind unannounced audits is simple. They provide a more objective picture of the actual standards and level of compliance in a food business. Where audits are announced the company has time to prepare. The physical and hygiene standards of the operation can be raised for the day of the audit, while the food safety management system can be reviewed and brought up to date where gaps are identified. This allows the company to present its business and controls in the best possible light for the day of the audit and can result in fewer non-conformances and a better audit outcome.
In cases where the audit is unannounced, the company is subject to an assessment of what the current standard is today. It is argued that this approach allows the auditor to report on the standards and level of compliance representative of the business day to day and therefore the actual risk of using a particular supplier. If the day-today standard of the company is not sufficient to meet the minimum requirements of the customer or certification scheme then likelihood of more non-conformances and failure increase.
Internal Business Culture
The change in the nature of the audit program goes to the core of how food safety systems are managed in many food businesses. These systems, depending on how they are designed, can be complex and depend heavily on key personnel physically checking and remembering which tasks are due for completion. When you add to this the busy nature and limited resources in a company it is almost evitable that jobs and task get overlooked or omitted. It is these tasks that tend to be unearthed and result in non-conformances in an unannounced audit. The difficulty arises where the non-conformance is significant in nature or where the number of non-conformances is high leading to a failed audit result.
I spent a number of years conducting unannounced audits on food companies on behalf of a food retailer. During this time I observed the same issues reoccurring in many companies as a direct result of the unannounced nature of the site visit.
These may be summarized as follows:
- Gaps in Records: It was common fact that daily routine checks, audits and inspections were not completed at the scheduled time e.g. hourly checks. It was apparent that in a lot of cases a series of hourly checks would be completed by the responsible person at the end of the day or shift.
- Sanitary and Housekeeping Standards: Another common observation was the actual housekeeping and sanitary standards in production and storage areas including failure to complete cleaning activities on time; product and packaging remaining on production floor; waste and garbage accumulating in production areas; uncontrolled chemicals and machine parts left on equipment; external doors maintained open.
- Personal Hygiene Standards: This was a frequently occurring issue. Hand washing practices not being observed by staff; protective clothing not being worn or replaced; jewellery being worn; evidence of eating and drinking in production areas.
- Internal Audits: This issue lead to consistent non-conformances. The internal audit program as defined by the company was seldom up to date.
- Management Reviews: Again the requirement to complete various reviews such as HACCP and management reviews was met.
- Corrective Actions: Follow up actions were usually incomplete over extended periods of time.
These are just some of the more common issues observed but there were many more. What is interesting about these non-conformances was the fact their root cause usually indicated the failure to complete an action at the required time. They were also issues which could be addressed prior to the completion of an audit in circumstances were it was announced. This is key Point! For companies to prepare for unannounced audits they must address the practical issues resulting task not being completed when required including:
- Manual paper based systems which need to be physically checked to determine tasks to be completed.
- Lack of a system which alerts and notifies team members of tasks which are due and overdue.
- Lack of a system which gives management an instant picture of compliance without the need of an internal audit.
- The One-Day Compliance Window
In short, if companies are to prepare properly for unannounced audits they must reflect on the fact that manual and paper based systems make it difficult to stay on top on compliance day to day. Why? Because the unannounced audit reduced the window for compliance to just 1-day as opposed to 6 months or 1 year depending on the frequency of the announced audit program. In other words the company must be compliant each day, every day of the year.
How Technology Can Help You Deal With Unannounced Audits
This is where IT solutions and technology come into play and become a compelling option to meet the new demands of unannounced audits. Safefood 360 contains a number of standard features which allow a food company to culturally and practically adopt a system which meets this one-day compliance window.
Let me explain:
- Dashboards: Safefood 360 provides a number of dashboards which clearly shows for all sections of your food safety system the level of compliance and tasks to be completed.
- Alerts: The alerts facility allows management to define when alerts are sent out to specific members of the team when actions are completed on time or certain conditions are met e.g. failed CCP. Alerts can be sent out to each employees My Alerts dashboard, by SMS text or email.
- My Actions: This feature allows individual employees to see in one list all the jobs and tasks currently due and overdue against them.
- Corrective Actions: The corrective actions module ensures that all actions remain open and visible until they are formally closed out by each individual and senior manager.
These facilities and features make it practical for a food company to ensure it remains compliant day to day and where tasks are slipping they know about it in real time. Moreover, senior managers can access their system from anywhere in the world at any time. Compliance is maintained even when senior and responsible managers are off site or are responsible for food safety in multiple plants.