"Unannounced audits quickly reveal if compliance is embedded as an essential part of daily operations or just a last-minute scramble!"
Having been a GFSI auditor for 10+ years, I’ve visited and audited a lot of manufacturing facilities. During announced audits I always knew that the site had up to 6 months’ notice of my impending visit, so if the premises weren’t tidy, you knew there were real problems under the surface.
On rare occasions, where I’ve had the chance to revisit former GFSI audit clients for other non-audit work, I was often disappointed to see that the facility was not maintained to the same standard I’d observed during previous planned audits. Though not unexpected, it did reveal the underlying food safety culture of the business.
As more and more businesses adopted GFSI standards and their compliance improved over the years, it was only a matter of time before mandatory unannounced audits would be introduced to capture the everyday state of a facility’s operations and their food safety culture.
The new norm...
All GFSI schemes now require unannounced audits to occur at least once every three years. Unlike scheduled audits, these unannounced audits aim to capture your day-to-day reality.
You can approach these audits as either:
- An opportunity to showcase your consistent compliance and commitment to best practice across your operations; or,
- As a risk to the business by revealing gaps in your hygiene, housekeeping or maintenance, or your food safety system compliance, or worse still, a poor food safety culture.
In my experience, sites that routinely relied on quick fixes and had only a few key staff to maintain food safety compliance struggled to perform in unannounced audits.
Rising to the challenge...
Unannounced audits reveal a great deal about your organisation’s food safety culture – how employees behave when no one’s watching. If compliance is seen as “Quality’s” job, you’ll struggle to maintain consistent compliance.
The goal is to make food safety a shared responsibility, embedded in your entire team’s daily operations. Most unannounced audit non-conformances stem from behaviours & attitudes, not the systems.
Reviewing audit findings from unannounced audits, I found that most of the non-conformances were around the following issues:
This isn’t an exhaustive list but it does shows that food safety needs to be a shared responsibility to maintain a consistent, high standard of operations and compliance.
Building an audit-ready culture...
To turn unannounced audits into a chance to shine, consider implementing these 8 practical steps:
1. Tackle repeat issues:
Review past external and internal audit findings to address any recurring problems to prevent them appearing in an unannounced audit.
2. Dig deep with root cause analysis:
Investigate all the contributing factors to food safety compliance issues so that you can implement risk based solutions to prevent recurrence.
Expert Tip: Being able to demonstrate that the business understands the causes and is in the process of implementing solutions can reduce the likelihood or severity of a non-conformance.
3. Assign clear responsibilities & ownership:
It’s critical to clearly define key food safety roles and their deputies to ensure seamless compliance coverage when key personnel are absent. Use a site map to ensure that every area, regardless of the production zoning, has a person or team responsible for the hygiene and housekeeping of the area.
Expert Tip: Identify shared spaces, such as corridors, raw material staging areas and product return zones where the responsibility for cleaning may be unclear. These areas are often not upheld to the same hygiene and housekeeping standards as other areas.
4. Standardise compliance:
Check for inconsistencies in cleaning standards, records completion or correct use of PPE across different shifts, product runs, or production volumes. Focus your efforts on the widest compliance gaps.
Expert Tip: Collaborate with cross-functional teams to identify and address issues, fostering ownership and embedding compliance as a core expectation. For instance, if new hygiene and housekeeping issues arise, rather than adding additional GMP checklist prompts, engage the employees in those areas to uncover the root causes and to develop effective solutions to prevent recurrence.
5. Set clear visual standards:
Use photos to provide a visual guide on “what good looks like” versus marginal and unacceptable conditions.
Expert Tip: Using photos is a highly effective technique to align expectations and overcome literacy & language barriers.
6. Reward positive behaviours & actions:
Launch a regular recognition program to celebrate employees who uphold food safety standards. This will boost engagement & maintain a constant focus on your food safety culture.
7. Challenge proposed fixes:
Ask yourself: “Will this solution solve one problem without creating a new one?” For example, relocating equipment storage to ease congestion in one area, may restrict cleaning access in the area.
Expert Tip: Get the opinion from other team members before deciding on the particular solution to check it’s suitability.
8. Gain leverage from your internal audit program:
Internal audits are the most effective tool for verifying that you do what you say you do and for driving continuous improvement.
Expert Tip: Conduct some of your internal audits as unannounced practice audits to challenge compliance, address findings and build your team’s confidence without the pressure of an external audit.
Transform your approach...
• Be Proactive...
Make food safety a priority and compliance an everyday expectation, not a pre-audit sprint.
• Engage Everyone...
Build a culture where all employees own & value food safety
• Learn from Data...
Use audit findings to drive meaningful improvements that can be sustained.
• Be audit-ready. Every day...
This builds trust and confidence, ensuring your team is always prepared for a surprise visit from an auditor – whenever that may be.
"By prioritising a strong food safety culture, you’ll not only improve the result of your unannounced audit, but also elevate your operations from basic compliance to best practice."
As always, if you need help to build an audit-ready culture, don’t hesitate to get in touch!
