The Heart of the Program: Self-Inspection

So you’ve reviewed AIB’s Consolidated Standards for Food Safety and have documented all the required information. You’ve set up a Pest Control Program. Personnel have received GMP training and maintenance employees are trained on the programs and policies. You have documented programs and scheduled all the required tasks for your cleaning program. So, your Food Safety Program is complete, right? Wrong!

Once you have all the paperwork in order and training is completed, there’s one thing left to do. You must verify that the programs are functioning as you want them to. Qualified personnel should evaluate all programs. AIB recommends that you use a multi-disciplinary team approach. Representatives from all plant departments should be involved in the self-inspection process. Typically this includes at least the following personnel:

Plant Manager: The Plant Manager ensures that self-inspections and evaluations are conducted on schedule, that the inspections are in depth, and that corrective or preventive actions are implemented to eliminate the condition.

Plant Sanitarian: The sanitarian or lead employee should be responsible for verifying through inspection that the Cleaning Program and Pest Control Program function properly.

Production Superintendent: This person should ensure through constant inspection that personnel are following plant procedures and are in compliance with the GMPs.

Chief Engineer: (S)he should ensure that the building, equipment design, and maintenance functions are provided with the tools needed to maintain a sanitary plant and produce wholesome products.
Personnel involved in ongoing facility inspections should be aware of the past audit/inspection history. Ask them to review any third party or regulatory inspections conducted at the facility so that they are aware of what kinds of issues to look for. In addition, it may be beneficial for members of the Food Safety Committee to accompany outside auditors to learn inspection techniques.

The plant manager should control the inspection process to ensure that the self-inspection and assessment is being done. In some cases, you may need to require each attending member to only report issues under their control. The meeting and inspections shouldn’t take longer than an hour. The team should be assembled. All members should have the necessary inspection tools. The area to be inspected should be identified. After the inspection, team members should submit their findings so they can be consolidated into one inspection list. In addition, follow-up corrections to the previous inspection should be submitted so that they can be removed from the ongoing inspection list. If necessary, target completion dates should be assigned to carry over items noted on the inspection reports. In some instances, if the correction noted is not necessary, the plant manager may delete it for financial considerations.  

When an issue is found during a third-party audit, it needs to be corrected and the program responsible for the issue needs to be questioned so that it doesn’t reoccur. There are many approaches to a Self-Inspection Program. If regulatory and third-party inspection results are at a high level of compliance, then you can assume that your self-inspection is adequate. If they are not, you may want to meet with the Self-Inspection Team to gain the information needed to find the issues and make necessary corrections.

Many plants use a scoring system to measure the effectiveness of Food Safety Programs. Plant Managers always ask me, “What is the best scoring system?” I tell them that it really doesn’t matter what kind of ruler you use, as long as it’s always the same one. Ultimately, you are trying to measure compliance and progress (or lack of). Pick a system that everyone understands and stick with it. If you are not regularly inspecting your entire facility and providing the necessary follow-up to ensure that issues are corrected, third-party auditors and regulatory inspectors will do it for you!

Mike Perry is a Food Safety Auditor at AIB International.