This is the time to prepare for a year that’s quite different from the last two. Let’s face it; food safety teams have been distracted for some time and it’s easy for small things to slip in the crunch of a crisis. When the crisis lasts more than two years, a lot of small slips can add up quickly.
A great place to start is with a solid GMP internal audit, and an audit is only as good as the documents used to record its findings. Take the time to update your GMP internal audit documents before performing any physical audit activities, and make sure all related forms have been updated for any COVID-19-related practices and processes that have been added or procedures that were modified during the pandemic.
Now is also a good time to verify that all personnel trainings are current and identify any topics that need to be addressed with updated or new training sessions. Make sure these are covered in new hire orientations where needed. This should provide the foundation for an annual training plan that eliminates knowledge gaps or ensures that all groups of personnel receive the necessary training.
Once the audit documents are updated, schedule the actual audit as quickly as possible. Inspections are ramping up, as are third-party audits, so getting the audit completed takes on a new urgency.
The amount of time to complete corrective actions will vary from facility to facility, but each finding should have a deadline established when assigned to personnel for completion. Any findings that require extended correction time should be documented carefully and tracked to ensure they are effectively handled in a timely manner. Now is the time to catch up on any other items such that were postponed due to the pandemic, and that list may be bigger than normal.
It sounds simple enough: Update a few forms and perform the usual walk through, right? Under these extreme circumstances, this process could take far more time than expected, so build in some flexibility to help smooth out the bumps as things return to normal.
Given the supply chain issues, this is an area that could also be included in the internal audit. While supply chain issues may or may not be a regular component of a routine audit, if there have been instances of emergency sourcing or interrupted supplies, this would be a good time to check procedures and documentation to make sure they’re complete and up to date. In fact, this may need to be one of the first areas looked at since, an audit may be required for new suppliers of certain high-risk products, and getting audits completed on short notice these days can still be difficult.
The good news is these steps should put you well on your way to being ready for your next inspection or audit.