7 replies to this topic

[EEMR]

Hello,

We would like to confirm whether it is permissible for the sanitization supervisor to perform the verification sampling. Due to recent changes in our department, we are considering this option since this individual is highly trusted. If allowed, we plan to provide them with training in basic microbiology and best sampling practices.

Our main concern is whether this arrangement could raise questions during an audit, given that the same person responsible for supervising the sanitization of a production line would also be conducting the swab sampling.

As part of our standard process, the supervisor not only oversees the sanitization but also performs ATP testing to ensure cleanliness. If any ATP readings indicate contamination, they conduct additional cleaning until achieving a result of zero.

For consideration, our facility is audited by both the FDA and NSF, so we want to ensure compliance with their standards.

We would appreciate your feedback on this matter.

 

Thank you!

Edited by EEMR, 17 March 2025 - 07:06 PM.

[nwilson]

At a prior plant we had our program set up very similar with a Sanitation Supervisor performing the verification of all cleaning activities.  The only thing that was added on was a random monthly check by QC.  As long as there is training to back the supervisor up this shouldn't be an issue and the trust factor is there.  Generally someone outside the scope of work performs these types if verifications to keep everyone honest, however with limited staff alternative methods can be achieved.  

[GMO]

I can't confirm FDA and NSF but I would consider the whole section of that HACCP control of sanitation.

 

Your control for x pathogen, let's say Listeria monocytogenes, is effective cleaning.

 

Your monitoring is your cleaning records.

 

1. One method of verification is supervision and supervisor review of cleaning records.  
2. Another method is reviewing you have got sufficient manning and hours for sanitation.
3. Another is environmental swabbing and product testing.
4. Sanitation auditing

 

The first and second will probably be reported by your hygiene supervisor.  The third, while it might be ok to the standard to have the same person testing, I'd encourage you to use a different and independent person if you can find a way of doing so.  Why?  If you have three verification methods performed by one dodgy person, you will not have effective verification of your HACCP plan.  Of course s/he might not be dodgy at all!  And this is not throwing shade on my cleaning brothers and sisters... But you have to plan for the worst.  And personally, I'd prefer a bit of segregation of duties. 

 

But what about auditing GMO?  Why are you ignoring that?  Because it's infrequent and people are changing behaviours because you're there.  You know they are... yet you find stuff anyway don't you?  Doesn't that speak volumes?

 

I wouldn't.  But it's probably ok standard wise.

Edited by GMO, 17 March 2025 - 07:29 PM.

[G M]

It may not be "best practice" to audit your own work by performing the verification, but there is nothing technically forbidden about it, so long as they are qualified to properly perform the testing through training, certification etc.

[Scampi]

We have a very similar situation here

 

Sanitation Manager performs swabs etc and does not perform any of the actual sanitation activities, no issues in my mind

[AZuzack]

I'm in line with Scampi and GM.  This happens all the time in Small and Very Small companies.  I am a quality department of 1 person.  I cannot possibly be on site 10 hours a day 5 days a week to follow behind and verify everybody's tasks.  We're going to have a problem with BRC internal audits since I cannot own the documents and be the internal auditor.  

Back to your Sanitation Supervisor doing the swabs, you can write into your plan/SOP that this task will be verified/audited/observed by a QA person monthly or Quarterly.  So at some frequency, a QA person goes with the Sanitation Supervisor and observes them performing the task and compares it back to the SOP for compliance.  This ensures the oversight that the training was effective and that the Supervisor is continuing to follow the SOP as trained and intended.  Most people can put on a show but if they truly aren't following the SOP everyday then their "bad habits" have a way of slipping out during observation.  

[GMO]

I'm in line with Scampi and GM.  This happens all the time in Small and Very Small companies.  I am a quality department of 1 person.  I cannot possibly be on site 10 hours a day 5 days a week to follow behind and verify everybody's tasks.  We're going to have a problem with BRC internal audits since I cannot own the documents and be the internal auditor.  

Back to your Sanitation Supervisor doing the swabs, you can write into your plan/SOP that this task will be verified/audited/observed by a QA person monthly or Quarterly.  So at some frequency, a QA person goes with the Sanitation Supervisor and observes them performing the task and compares it back to the SOP for compliance.  This ensures the oversight that the training was effective and that the Supervisor is continuing to follow the SOP as trained and intended.  Most people can put on a show but if they truly aren't following the SOP everyday then their "bad habits" have a way of slipping out during observation.  

 

All good points and much as you're alluding to, it's down to the business size as for if this is acceptable.  In UK Health and Safety law there is a principle of doing things which are "reasonably practicable" so you don't have to do absolute perfect best practice but if it's practicable for your business size and resources, you should.  If it's not, that's also acceptable.  

 

I do think as a principle though that if you can segregate duties, you really should.  It's not of course as bad as the person doing the cleaning taking their own swabs but it's not far off.  But it all depends on risk.  If this is a meat slicer we're talking about in a high risk facility, I'd not take the risk.  If it's a mincer for raw meat, yeah that'd be fine.

 

I find it surprising how little attention is given to verification in HACCP, not just in peoples plans but in guidelines for it.  It might be half an hour of a week long course or a page or two of things like Guideline 42.  Ultimately though, verification is your early warning that things have gone badly wrong, or, even worse, a too late warning depending on what kind of verification activity you've chosen.  If you look at FMEA, which HACCP was based on, detectability of failure of the system is baked into the hazard analysis type step.  Somehow it's become an afterthought.  You would not believe how many sites I've been in to where I'd identify the HACCP plan has essentially already failed because they are receiving significant numbers of consumer complaints relating to something the HACCP plan is meant to control.  How many food business operators think about it that way?  Zero...

 

So I'm going to champion putting more effort into verification and, as previously this swabbing was done by the Technical department (so they presumably had the resource which they're now losing), if the reason for this change is saving money, I'm unconvinced it's money I want to save...

 

But I accept there are situations, businesses etc where this might not be reasonably practicable and proportionate.  Only the Op can make a call on that...

[jfrey123]

I'm fine with the sanitation supervisor taking swabs to verify their team's performance.  There should still be some swabbing done by QA at some frequency as an additional verification, just so the QA department is reviewing more than the sanitation department's paperwork that the jobs were done properly.