An internal audit for the FSSC 22000 standard entails a structured and systematic evaluation of a food company’s food safety management system based on FSSC 22000 scheme requirements, ISO 22000, and any related technical specification. It is an obligatory requirement according to the FSSC 22000 V 6 scheme, and it serves as the primary instrument for the detection of non-conformities before the certification body. This article provides you with information about how to conduct an FSSC 22000 internal audit, what an FSSC 22000 internal audit checklist must include, and what the auditors are looking for during the inspection of your facility.
For Indian food manufacturing and exporting firms, whose products are integrated into the global food and beverages value chain, an internal audit becomes a difference between the smooth surveillance audit process and placing your certificate under suspension. The customers more and more often ask for the internal audit reports as part of their due diligence efforts concerning their suppliers.
What Is an FSSC 22000 Internal Audit
FSSC 22000 internal audit involves carrying out an internal audit of the food safety management system by trained individuals within the company or a competent individual outside the company performing the work on behalf of the company. This internal audit involves auditing of the HACCP plan, the pre-requisite programs, food defense, food fraud prevention, and management commitment. This differs from third-party audits of the same process in the sense that the internal audit should uncover the areas of concern early before the arrival of the external auditor.
According to FSSC 22000 standard, internal audits should be planned, documented and risk based. The auditors should not be connected in any way with the process that is undergoing the audit. Finally, the results of the audit should feed directly into the management review.
FSSC 22000 internal audit should cover a wide range of areas. Not only should it include the production processes but also warehouse, dispatch, incoming goods, laboratories where used, and even maintenance and procurement functions.
Why an FSSC 22000 Internal Audit Matters for Your Food Safety Management System
The auditing of the food safety management system cannot be considered an exercise in bureaucracy. It is the process that ensures that day-to-day activities within the factory are in line with the information presented in the manual. Manufacturers who regard their FSSC 22000 internal audit as a true diagnostic tool perform better during surveillance and recertification audits.
- Highlights any non-conformances before these evolve into findings that threaten the certificate
- Verifies that non-conformities identified in the last audit have been closed
- Creates audit-readiness throughout shifts rather than on the day of the certification visit
- Enhances traceability, recalls, and supplier control records
- Generates objective data for management review as per ISO 22000 Clause 9.3
Facilities that either skip or rush through their internal audit process usually follow a predictable trend during external audits due to the fact that the nonconformities that were missed during the internal audit process kept reoccurring without being linked back to its root cause. A scheduled FSSC 22000 compliance audit prevents that from happening.
How to Conduct an FSSC 22000 Internal Audit Step by Step
The most common question by manufacturers is how to perform an internal FSSC 22000 audit that is not only compliant but also relevant. The process described below demonstrates how the internal audit process of food safety professionals in India is organized.
Step 1: Build the Annual Internal Audit Schedule
All the clauses of the FSSC 22000 scope, and all the prerequisite programs must be assessed once during the entire certification cycle. High risk programs like allergen management, sanitation, and pest control are usually assessed more often than other non-administrative clauses.
Step 2: Assign Independent, Trained Auditors
An auditor should never audit his own department. The production supervisor should not audit the production line under his control. Internal auditors require documented training in ISO 22000, HACCP, and auditing methods like ISO 19011.
Step 3: Prepare the FSSC 22000 Audit Checklist
FSSC 22000 audit checklist can be formulated from the relevant ISO 22000 clauses, FSSC 22000 specific requirements, the sector-relevant prerequisite program (e.g., ISO/TS 22002-1 for food processing) and the particular site HACCP plan and SOPs.
Step 4: Conduct the Opening Meeting
State the parameters of the audit, the criteria that need to be met and the time frame for conducting the audit. Determine who will be interviewed and which areas need to be physically inspected. A short preliminary meeting will also set the proper tone for the audit; this is an investigation, not a reprimand.
Step 5: Gather Objective Evidence
This is the essence of the FSSC 22000 compliance audit. Auditors gather their evidence by examining documents, sampling records, interviewing personnel, and observing the process on the factory floor itself, as opposed to simply taking people’s word for it.
Step 6: Record Findings and Classify Nonconformities
The findings may be categorized into major non-conformance, minor non-conformance, or observations. Each finding will have to have objective evidence, the clause referred to, and a proper description, but not just a general one.
Step 7: Hold the Closing Meeting
Submit findings to site management prior to exiting the floor. This will avoid any surprises and kick off the process for correction.
Step 8: Issue the Report and Track Corrective Actions
Assign owners and timelines for correcting each nonconformity in the report. A root cause analysis is mandatory for significant findings, not merely fixing the immediate issue.
Step 9: Verify Closure Before the Next Audit Cycle
The closure of an internal audit finding is never dependent on the submission of a proposed corrective action. The auditor, or the designated verifier, must prove that the correct action was actually implemented using new evidence, which in turn must be recorded using the date and signature for the accreditation body to follow up.
FSSC 22000 Internal Audit Checklist: What to Prepare Before the Audit
This FSSC 22000 audit checklist and auditor requirements summary provides Indian manufacturers and exporters with a quick guide to the documents that an internal auditor would usually require.
What Auditors Look For During an FSSC 22000 Internal Audit
What are the FSSC 22000 auditor criteria when auditing a food facility? Apart from ticking off items on a checklist, experienced auditors want to know whether the written system really matches reality. This is presented in the table below.
The ability of a location to retrieve a record upon demand is also an important factor that auditors consider. The time required to retrieve a calibration certificate within five minutes is considered by many to indicate that the record management system is not actually being used on a day-to-day basis.
Technique is also an important factor during interviews. Rather than having a line worker regurgitate the policy, a professional internal auditor will ask the worker how they would respond in the event they saw glass near the packing line or if there was a spill involving an allergen.
Common Mistakes to Avoid During an FSSC 22000 Internal Audit
- Auditing your own department, thus violating the independence rule
- Making internal audits an annual ritual rather than a continuous process
- Preparing general conclusions without including a clause or supporting facts
- Closing out corrective action plans without confirming the completion
- Overlooking root cause analysis before coming up with a solution
And each of them usually comes up at the most inconvenient moment, which is the moment of the external audit or re-certification audit, where there is less chance to do something about it. To build a routine practice of performing an honest internal audit for FSSC 22000 within the ordinary routine of the plant would be the best solution to that problem.
FSSC 22000 Internal Audit: Key Takeaways
- An internal audit for an FSSC 22000 scheme is a mandatory risk-based audit of your food safety management system, rather than just a formality.
- The key components of an effective FSSC 22000 checklist are HACCP, prerequisites, food defense, and suppliers.
- Auditor independence and competent auditing are absolute necessities.
- The auditor assesses the accuracy of the documentation and floor practices.
- The corrective action must be based on the root cause and re-assessed.
FAQs
How do you conduct an FSSC 22000 internal audit?
It is scheduled based on the certification cycle, assigned to an independent and trained auditor, evidence collected on the basis of a checklist, and corrective actions are monitored until their resolution is achieved.
What do FSSC 22000 auditors look for during an audit?
He/she checks if the documented procedure matches the floor practice, if records are true and if there are any previously open corrective actions.
How to conduct an FSSC 22000 internal audit step by step for a small facility?
It can be performed using the same nine steps of the process: scheduling, assigning an independent auditor, performing a checklist, collecting evidence, reporting and verifying closure.
What is included in an FSSC 22000 internal audit checklist and auditor requirements?
These include HACCP records, logs from the prerequisite program, documentation from suppliers, training records and the auditor should be trained and independent from the audited area.
How often should an internal food safety audit be conducted under FSSC 22000?
Each clause and prerequisite program should be audited at least once during each certification period, with high-risk programs audited more often.
Who can perform an FSSC 22000 compliance audit internally?
Any trained person who is independent from the audited area and understands ISO 22000 and HACCP.
What happens if a food safety management system audit finds a major nonconformity?
There will be root cause analysis, correction and time bound, and then verification of resolution with new evidence prior to the next audit.