Passing a Third Party Food Safety Audit

by Shari L. Plimpton, Ph.D.
June 2006

Food ManufacturingPassing a third party food safety audit can be simplified to one basic concept: develop a food safety program and demonstrate that you are implementing that program. Remember as you approach a food safety audit that the ultimate goal is to demonstrate your emphasis on growing food safely and willingness to learn new methods for improving the safety of your operation. It’s easy to get caught up in trying to understand what the auditor is looking for and achieving a passing score, while losing sight of the real goal for these audits. If you keep your eye on the food safety ball, you will achieve your goal of passing.

Food Safety Programs have been developed to include all of the possible tools that growers could use to assure the safety of their produce. When a grower who is new to GAPs is confronted with all of these tools it is easy to see why they might throw their hands up and declare that what they are being asked to do is impossible. Common sense plays a large role in determining what elements of a food safety program apply in your situation.

Take advantage of the free consulting services we offer through the Ohio and Indiana Specialty Crop Food Safety Initiative (Initiative). Also, working with your third party auditing company, to understand their perspective and expectations prior to the audit will only make things go more smoothly. This is your food safety program, so think it through and focus on those parts that apply to your operation.

Fortunately, not all of the possible documentation is necessary in order to demonstrate that you are following Good Agricultural Practices, Good Handling Practices and Good Manufacturing Practices. For this reason I have compiled a list of issues/documentation that would be considered necessary (although not a guarantee) to passing a third party audit.

Food Safety Program
Any grower who has participated in the GAPs consults with our program has received support in developing a Food Safety Program. These programs are complete and exhaustive; however, they are not meant to imply that all of the documentation available in the program must be filled out to comply.

Water Quality
Have documentation available demonstrating the potability of your water. If you’re using wells then have annual tests available for review that demonstrate Fecal Coliform and E. coli levels. Reservoirs/ponds/rivers should be tested quarterly. Water used for washing purposes should be treated to assure sanitation of the surface of the produce. Methods differ based on the type of produce and handling methods. Maintain a log for testing the treated water for sanitizer levels at least at the beginning of the day, in the middle and at the end.

Employee Training
Employee hygiene is extremely important. Training is essential. Maintain a training log signed or marked by the employees, on an annual basis. If you can’t capture all workers in your pre-season training session, encourage trusted, trained workers to pass on their training to others. Also, put up the handwashing and related posters available through Mid American Ag and Hort Services in as many places as possible.

Pest Control
Rodents, insects and animals are still capable of infecting humans with disease. Effective pest control includes minimizing the opportunity for pests to enter packing and storage facilities, as well as, being set up to quickly trap and remove any rodents that do get into your buildings. Outside: keep the perimeter of the buildings free of debris which could harbor rodents and insects and set up rodent stations (preferably poison free) on either side of doorways and along the perimeter. Inside: also set up rodent stains on either side of doorways and along the perimeter (definitely poison free). Make a map of the location of all of the rodent stations and keep a log for weekly checks of the rodent stations.

Traceback/Recall
Having a printed lot code on each bag, or sale unit (i.e. bin) should be enough to get a passing score as long as you maintain a record (via the shipping log, invoice or similar documentation) that will identify to who you shipped that lot code of product.

Storage Temperatures
Maintaining cool storage temperatures is critical for reducing the potential of microbial growth on or in produce. If you aren’t set up with automatic recorders that can provide you with a record of storage cooler performance, then it will be necessary to maintain a written log of cooler temperatures. Begin with a once a morning check and increase if you can.

Audit Yourself
For most buyers a passing score of 70% or greater is needed to qualify as an approved supplier. Good housekeeping and particularly maintaining clean equipment will go a long way toward achieving that passing score. Also remember that the goal is to achieve 70% or higher in each section, not just on an overall basis. In order to have a better feeling for how you would do in an audit. Download a copy of the USDA audit matrix http://www.ams.usda.gov/fv/fpbgapghp.htm and use it to audit your operation. That will give you an idea how you would do in a real audit and some direction regarding what you could improve to reach a passing score.



Consultation for GAPs, developing food safety programs, and passing third party audits is available through CIFT. You can reach us by calling Shari L. Plimpton at 614-314-4627 or emailing us at foodsafety@eisc.org.



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