PET Food Processing - March 2021 - 22

FOOD SAFETY

" Good recordkeeping starts by
documenting what you do and
doing what you document. "
Wendy Yap, AIB International

Once an audit is on the calendar, Yap said, that communication and emphasis on organization should flow in
both directions, from management to line and back again.
" It is important that everyone is involved throughout the process, " she advised. " You can prepare your
staff through the internal audit process and then build
awareness and understanding toward the audit criteria
and implemented standard by participating in the actual
audit. Results of the audit should then be communicated
promptly, so everyone in the organization will do their
best to evaluate the root cause of any nonconformities
and rectify those issues. "

Next steps

" An FDA inspection can be stressful, " Barham said, perhaps understating things a bit. But the anxiety bound to
ripple through any organization notified of a pending
audit can be planned for, allowing you to avoid its undesirable byproducts.
That includes procrastination, which Marshall called " a
common issue " and which, he said, can cause friction when
it comes into contact with the flip side of auditing's human
element: an inspector trained to see what you've missed.
" The auditor is expecting the worst and looking for
high-risk situations that are poorly managed, " Marshall
said. " Don't challenge a finding without facts supporting
your claim. A minor citation can generate a rebuttal that
makes things worse. Having situations well-controlled

ahead of time will save the auditor time and will likely
influence whether the outcome is a nitpick affair or one
of thoughtful collaboration. "
Barham echoed this concern, noting that this is where
the recordkeeping comes in.
" Respond to the FDA with evidential solutions and
not vague answers, " he suggested. " Be ready to provide
supporting documentation - records of repairs, pictures, revised HACCP plans - to verify that corrective
action has been completed. "
In the live-audit setting as well as ahead of it, Barham
emphasized that a company's communication culture is
again paramount.
" Expect the FDA to interview some of your employees, " he said. " They should be trained to never be argumentative with an FDA investigator or speak on areas outside of their general duties or knowledge. They
should be able to implement a company's operating procedures and they should show a commitment to comply
fully with the laws and regulations. "
To reach that high ground, Barham advised conducting regular internal audits, calling it the surest way to
monitor " the effectiveness of your food safety system,
whether it's effectively implemented and updated, and
whether it meets regulatory requirements. "
Whether performed entirely in-house or via an outside consultant, gap assessments - scrutiny of any process component that may have fallen out of regulatory
compliance - also can tamp down apprehension.
" Companies that invest in a gap assessment, and well
in advance of an audit, can identify oversights and weaknesses in their programs and documents, " Marshall said.
An observation noted during food safety inspections in 2020 by
the FDA and of concern to the agency is animal food facilities
that have not identified or implemented a preventive control for
hazards that do require a preventive control.
©Vitalii Vodolazskyi - stock.adobe.com

22

PET FOOD PROCESSING | March 2021 | www.petfoodprocessing.net


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PET Food Processing - March 2021

Table of Contents for the Digital Edition of PET Food Processing - March 2021

PET Food Processing - March 2021 - Intro
PET Food Processing - March 2021 - 1
PET Food Processing - March 2021 - 2
PET Food Processing - March 2021 - 3
PET Food Processing - March 2021 - 4
PET Food Processing - March 2021 - 5
PET Food Processing - March 2021 - 6
PET Food Processing - March 2021 - 7
PET Food Processing - March 2021 - 8
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