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Josh ClauserJan 12, 2024 8:50:58 AM5 min read

Avoiding Internal Audit and Corrective Action Pitfalls: Non-Conformance Case Studies

GFSI Non Conformances For:

Internal Audits and Corrective Actions Scenarios


Organic Farm Facing GFSI Non-Conformances

Setting: A small, family-run organic farm prides itself on sustainable practices and fresh produce. However, during their first GFSI audit, several issues arise:



Internal Audit Gaps:

  • The farm lacks a documented internal audit program, relying solely on informal checks by the owner.
  • No risk assessment has been conducted, leaving critical areas like soil testing and irrigation unmonitored.

Ineffective Audit Scope:

  • The owner primarily focuses on visible farm features like crop health and animal welfare, neglecting document control and recordkeeping for food safety procedures.

Insufficient Corrective Actions:

  • Previous non-conformances related to improper composting practices resulted in superficial actions like relocating the compost pile, failing to address pest attractant issues.

Limited Management Involvement:

  • Hiring decisions for farmhands are based on experience rather than training in organic food safety best practices.
  • Management doesn't actively participate in corrective action planning or follow-up.


Implement a comprehensive internal audit program:

  • Develop a documented program aligned with the GFSI standard and the farm's specific risks and operations.
  • Conduct regular audits (e.g., quarterly) based on risk assessments, covering all food safety elements.

Expand the audit scope:

  • Include document control and recordkeeping of food safety procedures, maintenance logs, and training records.
  • Assess soil testing results, irrigation water quality, and pest control procedures.

Implement effective corrective actions:

  • Conduct root cause analysis for non-conformances to identify underlying issues like compost composition or lack of pest management barriers.
  • Develop actionable corrective actions focused on addressing the root cause and preventing recurrence (e.g., installing pest exclusion netting, adjusting compost recipe).

Enhance management involvement:

  • Ensure all farmhands receive training on organic food safety best practices and relevant GFSI standards.
  • Appoint a dedicated food safety officer or involve management in reviewing audit findings and approving corrective actions.



Ignoring these non-conformances could lead to:

  • GFSI certification denial or suspension.
  • Loss of market access or consumer trust.
  • Food safety incidents and financial repercussions.

By actively addressing these potential pitfalls, the farm can:

  • Strengthen its internal audit and corrective action processes.
  • Build a more robust food safety culture.
  • Enhance its preparedness for future GFSI audits and maintain certification.

Remember: Continuous improvement and proactive attention to internal audits and corrective actions are key to maintaining compliance, mitigating risks, and ensuring the sustainability of any farm's food safety program.

This is just one scenario, and the specific challenges and solutions will vary depending on your individual farm and GFSI standard.


Seafood Processor Facing HACCP Challenges

Setting: A seafood processing facility produces frozen fish dishes for supermarket chains. During their internal audit, several issues emerge related to HACCP implementation and corrective actions:



Ineffective HACCP Plan:

  • Critical control points (CCPs) for temperature control during cold storage and cooking haven't been clearly defined or monitored effectively.
  • Hazard analysis lacks sufficient consideration of potential cross-contamination risks between different fish species.

Inadequate Corrective Actions:

  • Previous non-conformances regarding product recalls due to spoilage were addressed by tightening temperature control procedures without identifying the root cause (inaccurate calibration of thermometers).
  • Follow-up audits for corrective actions weren't conducted, leaving room for repeated issues.

Limited Communication and Collaboration:

  • The HACCP team lacks involvement from production staff, leading to knowledge gaps and potential implementation errors.
  • Communication of corrective actions to relevant personnel is limited, resulting in confusion and potential non-compliance.


Revise and strengthen the HACCP plan:

  • Define clear CCPs with measurable critical limits, monitoring procedures, and corrective actions for each hazard.
  • Conduct thorough hazard analysis considering all potential sources of contamination, including handling practices and equipment.

Implement effective corrective actions:

  • Conduct root cause analysis for non-conformances to identify underlying issues beyond immediate symptoms (e.g., faulty equipment, inadequate training).
  • Develop actionable corrective actions addressing the root cause and preventing recurrence, including equipment maintenance schedules and staff training programs.
  • Conduct follow-up audits to verify the effectiveness of implemented actions and make any necessary adjustments.

Enhance communication and collaboration:

  • Include production staff in HACCP team meetings and training sessions to foster ownership and understanding.
  • Communicate corrective actions clearly and transparently to all relevant personnel through various channels (e.g., meetings, signage, online training modules).



Ignoring these non-conformances could lead to:

  • Product recalls and potential food safety incidents.
  • Financial losses due to damaged reputation and product waste.
  • Regulatory sanctions and license suspensions.

By proactively addressing these issues, the seafood processor can:

  • Strengthen its HACCP implementation and food safety culture.
  • Improve traceability and control over critical processes.
  • Enhance communication and collaboration among staff for overall effectiveness.

Remember: a continuously revised HACCP plan, effective corrective actions, and strong communication are crucial for building a robust food safety program in any seafood processing facility.

Scenario 3:


Food Truck Navigating Hygiene Challenges

Setting: A popular food truck known for its innovative street food faces challenges during their internal audit related to hygiene and sanitation practices:



Inadequate Handwashing Practices:

  • Handwashing sinks are inconveniently located and lack readily available soap and sanitizers.
  • Observation reveals inconsistent handwashing by food handlers between tasks and after potential contamination.

Improper Temperature Control:

  • Limited storage space necessitates storing cooked food at unsafe temperatures in the passenger compartment.
  • Lack of accurate thermometers or proper cooling procedures for potentially hazardous foods.

Poor Allergen Management:

  • Ingredients aren't clearly labeled or separated, increasing the risk of cross-contamination with common allergens.
  • Staff training on allergen awareness and handling procedures is insufficient.


Improve handwashing facilities and practices:

  • Relocate handwashing sinks to accessible locations and ensure continuous supply of soap, sanitizers, and paper towels.
  • Implement handwashing reminders and implement an observation system to monitor compliance.

Enhance temperature control practices:

  • Invest in portable temperature-controlled storage containers or insulated bags for safe food storage during service.
  • Calibrate thermometers regularly and develop standardized cooling procedures for cooked food.

Strengthen allergen management:

  • Implement clear labeling and separation systems for ingredients containing common allergens.
  • Provide comprehensive training to staff on allergen awareness, safe handling practices, and customer communication.



Ignoring these non-conformances could lead to:

  • Foodborne illness outbreaks and potential lawsuits.
  • Damaged reputation and loss of customer trust.
  • Regulatory fines and license suspensions.

By addressing these issues proactively, the food truck can:

  • Establish a more hygienic and safe food preparation environment.
  • Ensure proper temperature control and allergen management procedures.
  • Improve staff training and awareness for a stronger food safety culture.

Remember: constant vigilance over hygiene, temperature control, and allergen management are essential for any food truck to thrive in a competitive and safety-conscious environment.