Audit process
It is generally recognised that programs encompassing GHP can successfully support the development and implementation of HACCP based food safety programs. If GHP programs, such as cleaning and sanitation programs, have been properly implemented then the team developing a food safety program can concentrate on the application of the HACCP principles directly to the product and process in question, having some confidence that hygiene matters pertaining to personnel and the surrounding environment are being controlled. Consequently GHP programs should be audited in conjunction with HACCP based food safety programs.
The difficulty in assessing compliance with hygiene requirements is to determine what aspect of GHP and HACCP an authorised officer can assess through the audit process. Successful auditing will depend on the presence of appropriate documentation of GHP programs. A food business should document their GHP programs and ensure that the program is being followed. Records detailing the checks carried out and the action taken must be kept to demonstrate compliance. The compliance auditor will ensure that the GHP program is adequate, the program is being followed and any non-compliance is detected and corrective action taken. If appropriate records are not provided, an auditor would have to rely on traditional inspection to confirm compliance with hygiene regulations, which could incur greater inconvenience and cost to the business.
An auditor will essentially be seeking to verify the effectiveness of a food safety program as it is being followed. A business will be expected to make available to the auditor appropriate records which particularly pertain to critical control points, deviations from critical limits and corrective actions. The scale and frequency of the audit must be related to the nature, size and the risk the businesses poses to public health.
An auditor will seek answers to questions about issues such as:
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the implementation of GHP programs;
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product description and specifications;
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production flow diagram;
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the hazard analysis process;
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the identification of critical control points for significant hazards;
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the establishment of critical limits and monitoring procedures;
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the development and implementation of corrective actions; and
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validation and verification activities.
This question and answer approach to auditing could encourage a check-list approach for auditing which may be appropriate, especially for less complex food businesses. It is important though that this approach does not evolve into a simple ‘tick the box’ approach where there is no critical evaluation of the food safety management system.
The ‘approval’ of a food safety program by a government agency is an issue yet to be resolved in Australia. There is concern that in approving a food safety program a food business may pass responsibility for the production of safe food back to government. This could be avoided by the first audit being used to assess or verify the appropriateness of the food safety program, but not approve the program.