The Global Food Safety Initiative states that internal audits are one of the requirements that “add robustness and rigour to the base requirements of food safety principles and provide added confidence and further verification of processes” beyond the Codex General Principles of Food Hygiene.1
Audits are a planned, independent, and documented assessment to determine whether agreed-upon requirements are met, and the food industry relies on the audit function to provide safe food to their consumers.2 Many facilities organize their program into two categories: the external audit, performed by a third-party organization, and the internal audit, performed by employees of the facility. Most companies are familiar with the external audit—a high-stakes assessment in which the facility is too often focused strictly on passing the audit. This experience with auditing has resulted in misunderstanding or underutilization of the internal audit. Instead of viewing the internal audit as a requirement to pass an external audit, it should be considered a critical component of quality management systems for continuous improvement and validation of the food safety systems.
Benefits of an Internal Audit Program
While all audits help a facility to find and correct issues within their QMS, internal auditing has two extra benefits. First, a good internal audit program allows you to find and correct the issue before the external audit and demonstrates the facility’s dedication to customer safety. Second, the internal audit verifies continuous improvement and management commitment. Discovering nonconformances during an internal audit gives the facility the opportunity to demonstrate continuous improvement by implementing corrective actions. Senior management commitment to food safety and quality is easily demonstrated through the internal audit program. These programs require resources in the form of employee time (attending internal auditor training and conducting the audit) and financial expenditure to plan, implement, and evaluate corrective actions, including building or equipment repairs, increased sanitation efforts, and improved employee training.
Performing an excellent internal audit is difficult, however. A valuable internal audit requires that the facility be committed to performing the audit well and using the audit findings in a way that improves the production floor and programs. Here are some things to keep in mind:
- The internal audit should be viewed as an opportunity to improve, not just another nuisance to endure. By approaching the internal audit as an opportunity rather than an inconvenience, the facility can engage employees to improve their systems. Because this may require a culture change in the facility, support from senior management is critical.
- The internal audit should be an unbiased assessment. This is often more difficult than it sounds, particularly in smaller facilities. In these facilities, there may be only a few employees who are able to participate in the program, and when this happens, the facility should consider using an outside company to act as its internal auditor. The British Retail Consortium Global Standard for Food Safety Issue 6 clearly states that the audit may be conducted by or on behalf of the company for internal purposes.3 In other facilities, there may be departments less committed to food safety. The audit may be seen as singling out weak programs. To prevent these problems, each audit should be conducted by a multi-functional team composed of employees from different areas. Not only does this allow the facility to provide an unbiased assessment, but it also includes each department’s unique perspective on the nonconformances found.A final benefit is the opportunity for employees to enhance their professional development. The GFSI-benchmarked schemes generally require that internal auditors receive training in the principles of auditing, during which time the trainer stresses the importance of being unbiased. The entire team can be trained through an external organization, or one employee can be trained and then train others on the team. However this training takes place, an internal auditor should be thorough, detailed, knowledgeable about the process and system, and, above all, fair. An external auditor leaves after the audit is conducted, but the internal auditor must continue to work at the facility. Acceptance and support of the internal audit program relies a great deal on the professionalism of the auditor, and his or her unbiased approach is essential to the continuous improvement of the facility.
- The internal audit should be a full review of the programs. This requires more time; therefore, the internal audit should take longer than an external audit. Internal audits can be scheduled in two ways. One method is a multi-day event that takes place in one session—an excellent option for companies with a corporate audit team. For this method, the audit should last one to two days longer than the external audit. If a certification audit is usually three days in duration, then the internal audit should be at least four, or preferably five, days.The second method is an audit that takes place at scheduled intervals during the entire year. These audits should take a half day to two days per component and can easily be divided between prerequisite programs, the HACCP plan, and the quality system. When this approach is taken, it is best to schedule the audit for a fixed time each month—for example, the first Tuesday of every month. This prevents delays caused by scheduling issues. Figure 1 shows a sample schedule.
- An internal audit should be more intense than the external audit. External audits are a snapshot of the facility, and an external auditor has a limited amount of time to evaluate each program. These audits rely on discovery sampling and focus on areas where nonconformances are found. An internal audit, however, should be a deep dive into a program, looking at all the procedures and records. Each program and SOP should be evaluated based on its functionality and purpose, and all records should be reviewed. During an internal audit, the auditor has the opportunity to discover whether the procedure functions as expected, whether it executes as planned, and if the records document the activity. A good internal audit also interviews the employees involved in the activities. This has the added benefit of preparing the employees for the interviews conducted in an external audit.
Most companies are familiar with the external audit—a high-stakes assessment in which the facility is too often focused strictly on passing the audit.
Preparing the Internal Audit Reports
Internal audit programs require a thorough report, and many facilities use the report from their scheme, such as the British Retail Consortium Global Standard for Food Safety, Issue 6. An excellent internal audit program modifies this report to meet the needs of the facility. If there are activities not covered by its scheme, the organization should modify the report to include these items. Also, consider removing the scoring system in the report. One of the disadvantages to an external audit is its emphasis on the rating or score; a non-scored audit places the focus on nonconformances. Nonconformances should be rated by their severity (e.g., critical, major, or minor), but continuous improvement is better driven by reducing the number and severity of the nonconformances and not just by improving their score.
Closing the Loop
The internal audit program is of little value if nonconformances are not corrected. Failing to close the loop on a nonconformance not only allows an issue to continue, but it also results in the internal audit function losing credibility with the plant staff. After all, why would employees participate in the audit, either as auditors or interviewees, if their input and findings are not valued? Furthermore, the failure to implement a functioning corrective action indicates to an external auditor that continuous improvement is not occurring and the organization doesn’t have management commitment to the program.