Developing Effective Internal Audits

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What is an internal audit?. An audit conducted by you (or your employees) on your company/facility;

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Developing Effective Internal Audits

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1. Developing Effective Internal Audits Richard H. Dougherty Washington State University Pullman, WA 99164-6376 509-335-0972 103007

2. What is an internal audit? An audit conducted by you (or your employees) on your company/facility; “us on us” Vs a third party audit (independent audit on us) Vs a secondary audit (audit on us by a customer)

3. Purpose Continuous improvement Corrective actions Assessment of effectiveness of overall (or portion of) programs Identification of problems before they get out of control Program requirement (SQF, BRC, GlobalGAP)

4. How do we do internal audits? Frequency Ag operations – 1-2 times /year Processing/packing facilities – quarterly or monthly

5. How do we do internal audits? Mechanism – depends on company size and objectives Could be corporate internal audit or individual facility internal audit or both Who? One person does all audits More than one person splitting audits Alternating people Group of people alternating portion of the audits

6. Characteristics of a good auditor Integrity Observant Inquisitive Non-confrontational Persistent Ability to deal with conflict Understanding of principles involved Familiarity with general operation Not directly responsible for audited area Trained

7. Reporting/Documentation Observations Verbal during and at conclusion of audit Written within 1-2 days after audit Corrective actions Written – what and timing Written - completion

8. Developing the Check List Consider Food safety/HACCP programs Support programs Pre-requisites/GMPs/GAPs Food quality programs

9. Check List Considerations At CCPs Monitoring methods Monitoring frequency Records Corrective actions Records review Calibrations Other verifications Record security

10. Check List Considerations Flow diagram correct (?) Quality Monitoring methods Monitoring frequencies Records Corrective actions Records review Calibrations Records security

11. Check List Considerations Personnel Hygiene and cleanliness Smoking, eating, drinking, chewing, toothpicks Hand washing and sanitizing Jewelry Gloves Protective clothing (aprons, smocks, uniforms, etc.) Hair restraints, hair nets, beard nets, etc.

12. Check List Considerations Personnel (cont’d) Personal items Personal food Employee health Wounds, cuts, abrasions coverage Items removed from pockets above waist

13. Check List Considerations Employee Assistance Drinking water available Designated area or hooks/hangers for protective clothing Lockers and surrounding areas clean Break rooms and contents clean (including refrigerators, microwave ovens, etc.) SOP’s posted and current

14. Check List Considerations Visitor Requirements Sign in/out Policies/guidelines for visitors Accompanied? Badges or identification

15. Check List Considerations Potentially Hazardous Chemicals Storage secure and lockable Signage Handling instructions MSDS Transfer vessels Tracking Inventory/usage logs

16. Check List Considerations Food Grade Lubricants/Chemicals Use Storage Separated from non-food grade Grease guns, lube cans marked Hand Dips, Foot Dips, Hand Sanitizers Monitored (records) Used Maintained (records)

17. Check List Considerations Toilets and Hand Washing Facilities Clean and working Serviced and maintained (records) Warm water Soap Single use towels

18. Check List Considerations Cleaning and Sanitation Program Master Sanitation Schedule current, maintained, and followed Procedures readily available and followed Cleaning equipment and materials properly stored Items used for cleaning and sanitizing appropriate for their use (no steel wool, wire brushes, etc.) Protective clothing appropriate, worn, cleaned and properly stored Verification (records)

19. Check List Considerations Pest Control Free of evidence of pests Schematics/maps current and complied with Traps located properly and securely Traps numbered and functional Traps serviced (records) Service reports available Corrective actions completed

20. Check List Considerations Pest Control (cont’d) Insect lights properly located Insect lights serviced Bird control No dogs, cats, etc.

21. Check List Considerations Processing/Packing Areas Doors closed when not in immediate use Clean Free of flaking paint and corrosion that could contaminate products Food contact utensils off floor Walls, floors, ceilings clean and in good repair Overhead equipment and areas clean

22. Check List Considerations Processing/packing areas (cont’d) Plastic strip curtains in good repair and working 18-inch internal walls perimeter maintained Lighting adequate Food contact surfaces free of cross contamination Food containers clean and sanitized (as appropriate)

23. Check List Considerations Processing/Packing Areas Products, ingredients, raw materials, packaging free of and protected from contamination Floor drains clean; free of off odors Free of standing water No product accumulation Waste and garbage addressed promptly and properly Free of cross contamination/product adulteration potential

24. Check List Considerations Storage Areas Clean Floors, walls, and ceilings in good repair Utensils stored clean Doors closed when not in immediate use Pest proofed Temperature controlled and monitored (records) Atmospheres controlled and monitored when appropriate (records) Free of potential cross contamination and product adulteration

25. Check List Considerations Maintenance and repairs Shop reasonably organized and clean Daily pre-op evaluations (records) Preventive maintenance program (records) Maintenance logs maintained and current (records) Cleaning after repairs/maintenance (records) Tools appropriate (clean, cleanable, etc.) Free of unapproved temporary repairs

26. Check List Considerations Maintenance (cont’d) Free of excess grease/lubes on equipment Drip pans properly used when needed Spills addressed promptly Contractor policies and protocols being followed Compliance with hygiene and personnel practices Protocols being followed

27. Check List Considerations Receiving Approved supplier program being followed Records and documentation Tracking incoming goods Integrity of vehicles and goods documented Seals/ locks (records) Product requirements met Procedures followed to storage

28. Check List Considerations Shipping Records and documentation Tracking system (records) Seals/locks (records) Outgoing vehicles checked for cleanliness, good repair, etc. (records) Vehicle temperatures and other requirements met (records) Procedures followed from storage to loading

29. Check List Considerations Exterior and Surrounds Free of litter, weeds, standing water, etc. Dust controlled Outside dumpsters, garbage bins, etc. covered Waste and garbage addressed promptly and properly Free of potential pest harborages

30. Check List Considerations Foreign material Glass and hard plastics policy and protocol followed (documented) Glass and hard plastic inventory (records) Lights protected Metal detection and removal

31. Check List Considerations Records Legible and permanent Free of white-out, erasures, pencil entries, ink-outs Secure Current and compliant with policies Free of falsification or appearance thereof

32. Check List Considerations Employee information GMP signs Evacuation protocol Emergency information SOPs

33. Check List Considerations Allergen Program Receiving Ingredient identification and storage Scheduling Utensils Cross contamination potential Cleaning procedures followed Labeling Right labels on right products Finished goods storage

34. Check List Considerations Food Defense/Security Locked doors and gates Employee badges Records of key holders Outside lighting effective Cameras in place and functioning Security services

35. Check List Considerations Other Water testing records Other calibrations (scales, penetrometers, refractometers, pH meters, etc.) Hold policy compliance Rework/repack handled properly Containers marked for their use Training logs current

36. Check List Considerations Specific program requirements Marks, logos in compliance Verification of corrective actions from earlier audits


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