Jun 16, 2011Five ways to automatically fail an audit
There are some situations that stop an audit in its tracks. These situations force the auditor to assess a farm as automatically unsatisfactory, and can spell disaster for a grower. It’s important for growers to understand these situations so as not to be caught off guard.
The five situations that can cause an automatic unsatisfactory are the presence of an immediate food safety risk, presence or evidence of rodents or excessive insects during packing or storing, observations of employee practices that may jeopardize food safety, falsification of records, not having a designated food safety person on staff and not having a GAP (Good Agricultural Practices) manual.
In order to be kept in a sanitary manner, produce must be grown, harvested and packed in a way that minimizes the opportunity for contamination. Anything that significantly puts the produce at risk of contamination qualifies as an automatic unsatisfactory. If an adjacent field has had a recent application of manure, that can represent an automatic unsatisfactory.
It is critical that growers do everything they can leading up to an audit to minimize evidence of rodents or excessive insects. In this case, how your farm and packing area looks counts. The cleaner and more orderly, the greater chance you have of passing the audit. Litter around field edges can encourage auditors to look a little more carefully than they may otherwise look.
When processing high sugar-content produce, manage cull disposal to keep rotten fruit to a minimum in the packing area and row middles. Sweeping the packing area in the morning prior to the audit is a good idea, to remove any potential food safety hazards.
Farm workers come from many places around the world that may or may not have the same amenities we are accustomed to here. These differences of amenities can have implications on food safety.
In many countries, plumbing is unable to handle toilet paper, leading to disposal of used toilet paper in small baskets next to the toilet. From a GAP perspective, if this took place on a farm or in a packing house, it would be an imminent food safety risk. Auditors have reported that they have seen instances of farm workers leaving toilet paper in a pile next to the toilet, and had to give farms an automatic unsatisfactory for it. It is important to remind all farm workers of the proper method of disposal for toilet paper.
Falsifying records with regards to record-keeping is never advised. If the auditor suspects that records have been falsified, he or she may also assess an automatic unsatisfactory. Some auditors begin to suspect records have been falsified if they are in the same hand and pen color.
It is critical that someone on the farm has been designated as the food safety coordinator. This should be documented in the GAP manual. In addition, there must be an actual GAP manual for the auditor to review. Ideally, this should be organized to minimize shuffling around for the necessary documents. In both cases, if the grower does not have either of these in place, the auditor will assess an automatic unsatisfactory.
By making sure these major components to food safety are in place, you can avoid a very short, unsuccessful audit. Avoiding these major hurdles will not guarantee that you will pass an audit, but they do get you one step closer.
If you have specific questions or have difficulty tailoring GAPs to your farm, email the Agrifood Safety Work Group, or call 517-788-4292.
By Phil Tocco, Michigan State University