PET Food Processing - March 2021 - 21

AUDITcoming?
FOOD SAFETY

Mind the gap.

By Scott Wilson | petfoodprocessing@sosland.com

The US Food and Drug Administration's (FDA) sweeping Food Safety Modernization Act continues to reverberate through the pet food industry with a stern audit
forecast: not if, but when.
The law's mandate boosting preventive controls is
firmly in place, as is the Foreign Supplier Verification
Program (FSVP) - meaning the FDA has graduated " from an educational mindset to that of enforcement, " said Rick Barham, manager of the Food Facility
Inspection Team, Registrar Corp., Hampton, Va., that
offers compliance services across a spectrum of FDAregulated corporations.
" Failure to develop an FSVP was the most frequently
cited violation during FDA inspections in both 2019
and 2020, " he added. " Food safety plan and hazard analysis violations have steadily increased as well. Now, even
if you are following good manufacturing practices, you
are still likely to be cited if you have not properly documented those practices as required under FSMA. "
Bulletproof documentation is crucial, then. But
Barham and other industry veterans said that achieving
broader audit readiness yields more benefit than burden.

Where to start

A nontechnical first principle for turning " when " into
" anytime " is reliable year-round communication, advised Douglas Marshall, PhD, certified food scientist
and chief scientific officer for Eurofins Microbiology
Laboratories, Fort Collins, Colo.
" The food safety team should have representatives
from all functional departments, " he said, " and such
team members should communicate preaudit expectations and use audit findings to support continual improvement projects. "
Inside communication also means knowing how your
own systems and procedures work - and where they demand improvement.
" Being prepared by understanding the audit's criteria
versus the implemented system in place is a good place
to begin, " said Wendy Yap, consulting partner with foodintegrity organization AIB International, Manhattan, Kan.
" Knowing specifically how your system meets the audit criteria can show knowledge and confidence in the
audit, while also reducing stress in the audit, " Yap added.

" Sometimes it is as simple as having the audit criteria
with your personal notes of which documents and departments have that information. In a remote auditing
world, which is happening more frequently now, this is
even more important because you will need to have the
documents easily accessible electronically. "
Marshall agreed and recommended a decidedly analog but effective tool.
" A well-organized document binder - whether hardcopy or electronic - is essential, " he said. " Too many
keep multiple folders hidden in file folders so finding
information leads to an unnecessary hunting project.
Scattered monitoring records also is an annoying reality
at many operations. "
" You want to make sure the documentation is organized,
reviewed, and kept up to date, " Barham said. " Proper safeguards should be in place to ensure that the records are accurate and protected from unauthorized changes. "
Yap added, " Good recordkeeping starts by documenting what you do and doing what you document. Keep it
simple. The document should be easy to read and understand and be user-friendly. A good structure of documentation and recordkeeping will support the organization during any audit. "

Effective two-way
communications
from management
to the production
line and back helps
prepare a team
for what may be
asked during an
inspection.
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PET Food Processing - March 2021

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