Interpretation
3.4.1 Internal audit programme
Internal audit programme The primary role of an internal audit programme is to provide an ongoing assessment to ensure that the site is following the wrien procedures and methods of working dened in its quality system. The scope of internal audits needs to be established and must ensure that all aspects of the food safety and quality system, including the
HACCP programme, prerequisite programmes, policies, documentation, hygiene and production, are audited at least annually.
All the internal audits should not be conducted on a single day, nor should they cover all aspects of the Standard. The Standard states that at least four dierent audit dates should occur each year. Each date can be used to audit dierent aspects of the site’s systems that have been implemented to comply with the Standard. A once-a-year check against all the requirements may be of value as a gap analysis when preparing for an audit, but is insucient to cover the full requirements of an internal audit programme as it will not provide the depth of assessment or level of condence required.
The site must evaluate the risk inherent in each section and determine the frequency of the audits for that specic section or activity accordingly. For example, the site should be aware of the consequences of not complying with its own systems, which could lead to hazards not being identied in a timely manner. Frequency may also be inuenced by known issues within the company, best practice or customer requirements. The site must therefore have a schedule or programme of internal audits to ensure that individual sections of the process, documentation or production are scheduled for dierent, predened audit dates throughout the year.
Where a site is part of a multi-site company, and the company conducts annual corporate food safety audits, it is acceptable for this annual audit to be incorporated into the internal audit schedule. However, additional internal audits that look at specic parts of the food safety and quality system, and compliance with the Standard, should be scheduled throughout the rest of the year. The frequency of these audits will still be based on risk.
For seasonal production, particularly when the season is very short (e.g. 4 weeks or less), the site must have in place a system for the management of start-up processes. Therefore, internal audits should start before the season commences. For example, the
HACCP programme should be reviewed to ensure that it is up to date and appropriate for the forthcoming production; that hygiene and fabrication are correct; and that sta are appropriately trained. The remaining areas of the internal audit programme should be covered throughout the season. Care should be taken to ensure that the requirements that pertain to those seasonal activities are audited appropriately (e.g. that systems are checked when in operation).
The most common way of completing an internal audit is by taking documented procedures and work instructions and comparing them with the actual working practices and records.
The use of an external consultant (e.g. by small sites) is acceptable, providing the internal audit programme is scheduled throughout the year and not in a single block of activity.
