Tips on Preparing for a Food Safety Audit
With third-party food safety certification becoming more a necessity than a luxury in food production, the Oregon Blueberry Commission this past fall hosted a webinar featuring a presentation by a GLOBALG.A.P. Licensed Farm Assurer aimed at helping growers prepare for an audit.
Food Safety Specialist, Wilbur-Ellis
Mallory Lucas, a food safety specialist for Wilbur-Ellis, walked webinar participants through what to expect from a GLOBALG.A.P. audit and provided tips on preparing for and hosting auditors.
In starting her presentation, Lucas addressed differences between third-party food safety certifications that many retailers and other buyers now require of berry producers and the federally mandated requirements under the Food Safety Modernization Act, or FSMA.
FSMA, she said, focuses strictly on food safety. “But when you move into GAP (or good agricultural practices) certifications, a lot of times, they will choose to add categories like worker health and safety, or sustainability, to try to make (the certification) more appealing to buyers.”
She added that GAP certification does not exempt growers from FSMA requirements.
She also advised first-time users of GAP certifications to consider contracting with a consultant. “A consultant can help you with everything from coordinating the audit to getting your food safety plan in line,” she said.
Food Safety Plan
To start with, Lucas advised growers to start recordkeeping at least three months before a scheduled audit. “For your first year, you are expected to have at least three months of records,” Lucas said. “After that, you are expected to have continuous records.”
About two weeks before the scheduled audit, she advised growers to conduct an internal assessment. “That will give you time to get your corrections done,” she said.
After an audit, a grower has 28 days to conduct a corrective action. (In the first year, that is extended to 90 days.) No matter which audit program a grower chooses to go with, there are some basic building blocks that will apply, Lucas said. “Basically, the bulk of your food safety plan is going to be policies, so things that you are telling your visitors, your employees that they need to be in compliance with.”
Standard operating procedures (SOPs), which are a detailed set of instructions designed to help a grower meet the food safety plan policies, are required in any plan. These detailed sets of instructions should include what actions need to be done and how often.
“When writing your SOP, make sure you include your personal protective equipment,” Lucas said, noting that that is one area of SOP that is often missed.
The final component of a food safety plan is a risk assessment, a part of the plan that essentially determines a grower’s SOP and his or her policies. “Risk assessments help you figure out the rest of the plan, and I recommend doing that first,” Lucas said.
Auditors expect three types of risks to be covered, Lucas said: chemical, biological and physical. Examples of chemical contamination might be pesticide drift. Physical risks could include contamination from trash that people throw out along a roadside. Biological risk could be anything that has pathogens, such as contamination of surface waters or domestic or wild animal intrusions.
Many berry buyers expected growers to be certified through GLOBALG.A.P.’s IFA, or integrated farm assurance, Lucas said. An IFA audit covers worker health and safety, hygiene, traceability and food fraud. Harvest and preharvest activities are covered in an IFA audit, including documentation of preharvest inspections and cleaning and sanitation of harvest tools.
Lucas pointed out several activities people often overlook with preparing for an IFA audit, including not listing qualifications for consultants. “If you are working with an agronomist, ask for a copy of their consultant’s license,” she said. “If you are making fertilizer and pesticide decisions on your farm, you need to show your education. So, if you have a college degree in crop and soil science, or if you do continuing education credits as a part of your applicator's license, all of those are things that you can factor in.”
An IFA audit also looks at all pesticide application records, including documentation that growers adhered to preharvest intervals.
“The vast majority of people are keeping their application records, but the things they have a tendency to miss are the preharvest interval and the target pests, and some people forget to put down the weather,” she said.
When documenting training programs employed on a farm, Lucas said it is important to include everyone who participates, including management and office staff.
Another common misstep in documentation is to forget to document equipment calibration. “Calibration was a minor offense,” she said. “Now it is a major, so make sure you are keeping those records.”
Treat Auditors Well
Lucas also shared some tips to help audits go smoothly, including ensuring you have a clean, temperate workspace with plug-ins for auditors and a work surface.
“And give them water or a snack or lunch,” she said. “You do not want an angry auditor. They are more likely to let you explain things or work through things if they aren’t feeling like they need to get out of there to get something to eat.”
And, she said, when talking to auditors, “be informative, not argumentative,” and have documents organized and ready. “The more you look like you have your stuff together, the more the auditor is going to trust you, and it is going to make things go quicker.
“A quick audit makes for a happy auditor and it saves them time, so that saves you money on their hourly rate,” she said.