During the past year, AIB implemented the Food Safety Evaluation (FS•360) inspection, expanded the scope of its BRC audits to include storage and distribution and packaging, and received approval to conduct gluten-free certification audits on behalf of the Canadian Celiac Association. The AIB’s audit department also remained laser-focused on the Food Safety Modernization Act (F.S.M.A.) and its potential impact on the food industry.
Put in place in the summer of 2012, the FS•360 program was developed to fill the void when a facility opts to go strictly with program-focused audits and cursory on-the-floor inspections, explained Betsy Blair, head of GMP audit services at AIB.
“In this activity, the auditor is meant to get dirty; the inspection cannot be rushed,” Ms. Blair said. “It is truly meant to be a deep dive into the facility GMPs.
“The FS•360 is intended to be educational in nature. AIB’s history and a foundational core competency is the ability of its audit staff who are trained to carry out a deep physical inspection of a processing area: open the equipment, climb the silos, go on the roof, and dig, dig, dig to identify areas where contamination could occur.
“As many facilities move to GFSI (Global Food Safety Initiative) benchmarked audits, the documentation is
thoroughly reviewed, but the physical audit doesn’t allow for much time to be spent really looking at equipment. The FS•360 does that. It is complementary to the GFSI audits in that it allows the inspector and the facility personnel to spend time opening equipment to look for areas that may have been missed, and to encourage open discussion on root cause and corrective action.
“It is our belief that the ‘sweet spot’ in the development and implementation of a robust food safety program is at the intersection of food safety and food defense training, program audits and deep inspection. This 3-circle approach provides the necessary educational approach and review processes that will help design and implement programs as well as provide continuous oversight both in the office and on the floor. The FS•360 assessment is a critical component of a fully balanced food safety system.”
Ms. Blair said the baking industry has been the most enthusiastic about the FS•360 program, but she expects other companies to continue to sign up for the program because of the unique view of the facility and process that the evaluation provides. She noted that the FS•360 program fits in well with the other activities in AIB’s audit services department, and encourages facility personnel to open up and discuss issues with the equipment and facility so that the inspector can help find the source of the issue.
“The FS•360 allows facilities that do well on certification audits or GMP inspections to look at areas that could be overlooked during normal daily activities,” she said. “The evaluation is a great training tool for old and new employees alike. The FS•360 teaches techniques for self-inspection that facility personnel can use after the inspector leaves. We have found that every facility where we have conducted the evaluation has been conducting self-inspections while running and therefore have missed cleaning issues in equipment that was not being opened.”
Since being approved for the Gluten-Free Certification Audit program for the Canadian Celiac Association, AIB has trained several auditors to conduct the audits, Ms. Blair said. She said the audit program looks at facilities that produce gluten-free products and how they manage those products and ingredients. The audit reviews ingredient and product testing, documentation of pre-requisite programs, HACCP with regards to gluten, training and awareness of personnel with regards to gluten in the facility and products among others. It includes a GMP inspection as well as documentation review, she said.
AIB also has expanded its GFSI capabilities. Ms. Blair said the BRC Storage and Distribution Standards and BRC-IOP Packaging Standards have been benchmarked, and AIBI-CB has expanded the scope of its accreditation to include these certification audits.
Whether it is about the Consolidated Standards or how to apply the standards or rate items, the F.S.M.A. is constantly in the minds of audit services personnel, Ms. Blair said.
“As new rules come out, we sit down as a multi-disciplinary team and discuss how the new rule should be included in our standards and how the auditors should be trained on the interpretation,” she said. “F.S.M.A. requirements are also applied during the certification audits as needed.”
Looking ahead, Ms. Blair said AIB will continue to update and train auditors on the F.S.M.A. rules as they become available, and will continue to expand the number of auditors that conduct certification audits as AIB expands the scope of the AIBI-CB accreditation. Work will be done to update the second round of standards to be published in January 2014, she said.