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Food Safety Third-Party Audit Corrective Actions

Monday, October 18, 2021

Bottle inspection during audit.

 

After a food safety audit is completed, there’s more work to do.  Chances are the auditor has left you with corrective actions to complete with a deadline. Not only are these corrective actions required to complete the certification process, but they also will be part of the records review during the next audit.  It is vital to be dedicated to seeing the corrective action process work and remain in effect to avoid the unwanted repeat nonconformance.

 

Consider the bird’s eye view of the company as a business and lean manufacturing. Nonconformances are defects that can be described as a type of waste in lean manufacturing. It is in an organization’s best interest to investigate, correct and prevent defects to optimize efficiency.

 

There are four parts to corrective action: root cause, corrective action, preventive action and objective evidence.

 

The root cause is defined by SQF as the core issue that caused the nonconformity. This investigation needs to be documented for record-keeping purposes and there are several methods to conduct this task. Interviews are a method that can uncover surprising details regarding the events leading to the nonconformance. Employees and contractors may be interviewed. Begin with an explanation of the reason for the interview, have questions prepared ahead of time and record relevant information.

 

The five whys technique is a common method to arrive at the heart of the matter. The essential point of the five whys technique is to begin by asking your team why a nonconformance occurred, and with that answer, again ask why. The process is ideally repeated three more times, but as many times as necessary to reach a conclusion. The investigation can include reviewing records or data from sources such as customer complaints, pest control service reports, process data, previous nonconformances and maintenance records.

 

The corrective action is defined as the immediate correction to eliminate a nonconforming situation.  Examples of corrective actions are conducting repairs to the facility or equipment and revising a documented procedure. If the corrective action is completed during the audit, be sure to inform the auditor. It will not undo the initial nonconformance, but quick action is evidence of management commitment.

 

The preventive action is defined as an action taken to prevent the reoccurrence of a nonconformance.  Training is a method to implement preventive actions, and the training can be scheduled for initial hire and annually thereafter. Posting a sign with the intention to inform and remind employees about a specific policy is an example of a preventive action. Adding a task to a schedule, existing checklist or other established procedure can prevent repeated nonconformance issues.

 

The objective evidence is defined as records, interviews and observations. Examples of this evidence include photos, documents and records. Before and after photos are beneficial to support a correction completed in the facility. Documents such as forms and procedures that have been revised to address a nonconformance are evidence of implementation.

 

Records of interviews, training or other data can be submitted to support the root cause, corrective action and preventive action. If a meeting is held to discuss a nonconformance, the minutes from the meeting can serve as objective evidence.

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