Auditing

Audit Checklist For Food Industry Part 1

Page 1 of 3 Page 2 of 3 Page 3 of 3

Disclaimer

This checklist is intended to aid in the systematic GMP audit of a facility that manufactures or processes food.

The adequacy of any procedures is subject to the interpretation of the auditor. Therefore, the GMP Institute accepts no liability for any subsequent regulatory observations or actions stemming from the use of this audit checklist.

Instructions for Using GMP Institute Audit Checklist

Before starting an on-site audit, plan the audit. Review past audits, note indications of possible problem areas, and items, if any, that were identified for corrective action in a previous audit. If you are not already familiar with this facility, learn the type of product produced here and how it is organized by personnel and function. What does your "customer", i.e., your superior or senior facility management, expect to learn from this audit?

  1. The checklist is to be used with a notebook into which detailed entries can be made during the audit.
  2. While the checklist is to guide the auditor, is not intended to be a substitute for knowledge of the GMP regulations.
  3. Although a single question may be included about any requirement, the answer will usually be a multi-part one since the auditor should determine the audit trail for several products that may use many different components. Enter details in your notebook and cross reference your comments with the questions.
  4. At least three production batches should be selected for thorough analysis to include: (a) traceability of all components or materials used in the subject batches, (b) documentation of raw material or component, in-process, and finished goods testing for the subject product batches, (c) warehousing and distribution records as they would relate to a possible recall.
  5. Responses entered on the checklist should be consistent. "X" is recommended for "NO"; a checkmark for "YES"; "n/a" for not applicable to questions that do not apply. An asterisk and notebook page number should be entered on the checklist to identify where relevant comments or questions are recorded in your notebook.
  6. The notebook used should be a laboratory-type notebook with bound pages. The notebook should be clearly labeled as to the audit type, date, and auditor(s). Many auditors prefer to use a notebook for a single audit so it may be filed with the checklist and the final report.
  7. The references to sections in the GMP regulation are for your convenience should a question arise. In some instances, two or more sections within the GMP regulation may have bearing on a specific subject. The headings in the GMP regulation will usually offer some guidance on the areas covered in each section.
  8. A general suggestion for a successful audit is to spend most of your time on major issues and a smaller portion of your time on small issues. There may be observations that you may wish to point out to supervisory personnel that deserve attention, but do not belong in an audit report because they are relatively insignificant. By the same token, too many small items suggests a trend of non-compliance and deserve attention as such. When citing these, be specific.

Sections 1 and 2

Section Question Yes, No, or NA

1.0

General Controls

 
1.001 Does the facility and its many departments or organizational units operate in a state of control?  

 

1.1 Organization and Management Responsibilities  
1.101 §110.80 Is there an appropriate quality control operation employed to ensure that food is suitable for human consumption and that food packaging material is safe and suitable?  
1.102 §110.3(i)  Is there a planned and systematic procedure for taking all actions necessary to prevent food from being adulterated within the meaning of the FD&C Act?  
1.103 §110.80  Is there one or more competent individual(s) assigned responsibility for the supervision of the plant sanitation program?  
1.104 §110.10(d)  Is the responsibility for assuring compliance by all personnel with the requirements of the GMP regulation clearly assigned to competent supervisory personnel?  
1.105 Is there a formal, multidisciplinary plant food safety committee performing complete inspections of the entire facility at least monthly?  
1.106 Is a functional organizational chart maintained?  
1.107 Do all departments involved in implementing food product safety have adequate budgets established for the timely acquisition and maintenance of tools, materials, and equipment?  

 

1.2 Document Control
1.201 Is there an adequate procedure for writing, approving, and distributing written procedures to the appropriate personnel?
1.202 Is there a system for insuring the timely review of procedures and for the prompt removal of obsolete procedures from the system?
1.203 Are there written procedures to delineate responsibilities of departments for implementing quality control/quality assurance?
1.204 Are there written procedures to delineate responsibilities of departments for implementing the plant sanitation program?
1.205 Are there specific procedures for the inspection of incoming raw materials?
1.206 Are there written procedures for laboratory analysis and sampling, whether conducted in-house or by an outside laboratory?
1.207 Are there written procedures or a written program for evaluating complaints of adulteration or misbranding?
1.208 Are there written procedures to prevent adulteration of food or raw materials from pests or from the application of pesticides, rodenticides, insecticides, etc.?
1.209 Are there written procedures, including schedules, for cleaning?
1.210 Are there written procedures for handling regulatory inspections?
12.11 §113.100(a)  Is processing and production information for low acid can foods (LACF) entered when it is observed by the processing system operator?
1.212 Are adequate records maintained for LACF's per §113.100(a) for:
    (a) Still retorts?
    (b) Agitating retorts?
    (c)  Hydrostatic retorts?
    (d)  Aseptic processing & packaging systems?
    (e)  Flame sterilizers?
    (f)  Food preservation methods?
    (g)  Critical factors specified in the formulation of the product or scheduled process?
1.213 Are recording thermometer charts for LACF's identified by date, retort number, and other data per §113.100(b)
1.214 §113.100(b)  Are all processing and production records for LACF's reviewed and signed or initialed by a qualified representative of plant management no later than 1 day after the actual process and before shipment or release for distribution?
1.215 Do written records for LACF container/closure examinations specify: product code, date & time of inspection, measurement obtained, and corrective action taken per §113.100(c)
1.216 §§113.100(d) and 114.100(d)  Are records maintained for LACF and acidified foods to identify distribution of finished product?
1.217 §114.100(a)  Are records maintained of examinations of raw materials, packaging materials, finished product and supplier's guarantees  for acidified foods?
1.218 §114.100(b) Are production and processing records showing adherence to scheduled processes maintained for acidified foods?

 

1.3 Employee Orientation, Quality Assurance, and Job Training Program
1.301 §110.10(c) Do personnel responsible for identifying plant sanitation failures or food contamination have the combination of education and experience to produce clean, safe food?
1.302 §110.10(c)  Do food handlers and supervisors have appropriate training in proper food handling techniques and food protection principles?
1.303 §§113.10 and 114.10 respectively.  Have those who supervise operators of retorts, processing systems, aseptic processing and packaging systems and product formulation systems for LACF's and acidified food attended a school approved by the Commissioner? 
1.304 Is there an orientation for new employees on food safety, employee safety and quality?
1.305 Do temporary employees, contractors, and outside service personnel receive basic food safety training?
1.306 Is there initial and periodic training for all who apply pesticides?
1.307 §110.10(a)  Are employees instructed to report health conditions that might contaminate food, food product surfaces or food packaging materials to their supervisor?
1.308 §110.10(b)  Are employees trained to protect against contamination of food by properly wearing suitable outer garments, hair nets, beard coverings, etc.?
1.309 §110.10(b)   Are employees trained to wash hands thoroughly before work and after each absence from their work station?
1.310 §110.10(b)  Are employees trained to remove unsecured jewelry and other objects that might fall into food?
1.311 §110.10(b)  Are employees trained to confine eating, drinking, gum chewing, and use of tobacco to areas where food is not exposed or equipment and utensils are not washed?

 

1.4 Plant Safety and Security  
1.401 Does the facility have a plant safety program?
1.402 Are Material Safety Data Sheets readily available for all chemicals used in the facility?
1.403 Are there written safety procedures?
1.404 Is there adequate safety equipment in each area of the facility?
1.405 Have employees and contractors received adequate safety training?
1.406 Is access to the facility restricted?
1.407 Is proprietary information identified and adequately secured?
1.408 Are all computer systems regularly backed up and is the backup data stored in separate facility?

 

1.5 Internal Quality System and Audit Program
1.501 Does the facility have a Quality Policy?
1.502 Is the Quality Policy distributed to all employees?
1.503 Does the facility have a formal internal audit program?
1.504 Is there a written procedure for internal audits that describes: who shall conduct the audits, the frequency of audits, how audits are documented, and the distribution of audit reports?
1.505 Is there a written procedure that describes how to handle an FDA audit?

 

1.6 Quality Cost Program
1.601 Does the facility have a formal, periodic review of the cost of quality?
1.602 Does the facility have the capability through trained personnel, adequate accounting records and computer software to identify and capture quality costs?
1.603 Is there a conscious effort to communicate quality cost savings to the workforce?
 

2.0

Design Control

 
  Does not apply to the Food Industry  
 

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