Preparing for Your First Food Production Inspection

Preparing for Your First Inspection

Your first food-production inspection can feel intimidating.

It becomes much less intimidating when you understand what an inspection is really testing.

An inspector is not simply looking to see whether your kitchen appears clean on inspection day.

The bigger question is:

Does this business have a reliable system for producing food safely?

If your everyday practices are organized, documented and repeatable, preparing for an inspection becomes much easier.

First, Know Who Regulates You

Not every food business is inspected by the same agency.

Depending on your food, process, facility and sales channels, oversight might involve a state agriculture department, local health authority, FDA, USDA, or another regulatory body.

Before preparing for an inspection, know which agency has jurisdiction and what rules apply to your operation.

Do not assume that an inspection checklist found online for another business applies exactly to yours.

Don’t Prepare Only the Night Before

A deep cleaning the night before an inspection does not create a food-safety system.

Good inspection preparation starts weeks or months earlier by establishing procedures employees follow every production day.

The goal should be:

Operate every day as though someone could inspect the facility.

That does not mean maintaining showroom perfection. It means making food-safety practices routine.

Walk Through Your Facility Like an Inspector

Start at receiving and follow the product through the operation.

FDA describes its food-facility inspections similarly: investigators typically gather administrative information and then walk through the establishment from receipt of ingredients through distribution while observing processes, manufacturing procedures and employee practices.

Look at your facility with fresh eyes.

Are ingredients stored properly?

Are containers identified?

Are allergens controlled?

Are chemicals stored appropriately?

Are refrigerators maintaining required temperatures?

Is equipment clean and in good condition?

Are food-contact surfaces protected?

Are employees following hygiene procedures?

Are there signs of pest activity?

Are finished products stored appropriately?

If you have stopped noticing a problem because you see it every day, an inspector may still notice it immediately.

Get Your Records Organized

One of the worst times to discover that your records are disorganized is while an inspector is waiting for them.

Know where important documentation lives.

Depending on your operation, that could include licenses, registrations, food-safety plans, process documentation, sanitation records, temperature logs, supplier records, training records, production records, allergen procedures, pest-control records, calibration records, corrective actions and traceability information.

FDA investigators may review records as part of an inspection.

A good test is simple:

If someone asked for last Tuesday’s production record right now, how long would it take you to find it?

If the answer is 30 minutes, your record system needs improvement.

Review Employee Practices

Employees are part of the food-safety system.

Make sure employees understand appropriate handwashing, illness reporting, clothing and hair-restraint requirements, glove use where applicable, allergen procedures, cleaning responsibilities and safe food-handling practices.

Don’t teach employees to put on a performance when an inspector arrives.

Teach them the correct process and expect it every day.

Review Your Sanitation Program

Look beyond visible cleanliness.

Verify that employees know which cleaners and sanitizers are used, how they are prepared, where chemicals are stored, which equipment must be disassembled, and how cleaning is documented.

Check difficult areas.

Under equipment.

Around floor drains.

Inside refrigerators.

Behind storage racks.

Around door seals.

At handwashing stations.

Inspection problems often hide in places that aren’t part of the casual end-of-day wipe-down.

Review Allergen Controls and Labels

Verify that employees understand which products contain major allergens and how allergen ingredients are handled.

Then review your labels against your current recipes.

A perfectly printed label can still be wrong if the recipe changed and the label did not.

FDA’s current allergen guidance emphasizes accurate declaration of major food allergens on labels of covered foods.

Make label verification part of production, not just label design.

Test Your Traceability

Pick one package of finished product.

Find its lot code.

Now work backward.

Can you determine when it was produced?

Which batch record applies?

Which ingredients were used?

Which ingredient lots were used?

Who supplied them?

Now go forward.

Can you determine where other product from that finished lot was sold?

That exercise is essentially a miniature mock recall.

If the process takes hours and requires searching through several unrelated spreadsheets, invoices and notebooks, fix the system before you actually need it.

Prepare One Person to Work With the Inspector

Know who will meet the inspector and who understands the operation well enough to answer questions.

For an FDA inspection, the investigator presents credentials and a Notice of Inspection, and FDA recommends that a knowledgeable company representative accompany the investigator.

Your designated person should understand production, sanitation, records and the basic organization of your food-safety system.

If you don’t know the answer to a question, don’t invent one.

Find the correct record or person.

If the Inspector Finds Something

Do not treat every observation as an argument to win.

Understand the concern.

Ask questions if you do not understand what the inspector is telling you.

Take notes.

Correct simple problems immediately when appropriate.

For FDA inspections, significant findings and concerns are generally discussed with management at the conclusion of the inspection; objectionable conditions or practices may be documented in writing.

What matters after an inspection is not only what was found, but how effectively the business responds.

First Inspection Checklist

Before the inspection, review:

• Licenses and registrations
• Food-safety plan or required process documentation
• Employee hygiene and training
• Handwashing facilities
• Ingredient receiving procedures
• Dry-storage organization
• Refrigeration/freezer temperatures
• Allergen storage and handling
• Chemical storage
• Cleaning and sanitation
• Pest control
• Equipment condition
• Facility condition
• Production records
• Batch and lot records
• Ingredient traceability
• Finished-product traceability
• Labels
• Temperature/process records
• Calibration records
• Corrective-action records
• Supplier documentation
• Recall procedures
• Employee understanding of procedures

Run Your Own Inspection First

A week or two before an expected inspection, perform your own.

Don’t have the person who normally manages sanitation conduct the sanitation review.

Have someone else look.

Ask them to identify anything that appears unclear, dirty, undocumented, uncontrolled or inconsistent.

Then fix the system rather than merely fixing the appearance.

Where Production Software Helps

Inspections expose a weakness common among growing food businesses: the information exists, but nobody can find it quickly.

A batch number might be on paper. Ingredient purchases might be in accounting software. Sales might be in a POS system. Recipes might be in spreadsheets.

DoBetter helps connect production, recipes, lots, inventory and sales so a producer can retrieve important operational information without reconstructing the history from multiple disconnected systems.

Frequently Asked Questions

Will I know in advance when an inspection is coming?
That depends on the agency and type of inspection. Build your operation so that food-safety procedures and records are maintained continuously rather than only before a scheduled visit.

What happens during an FDA inspection?
FDA says investigators generally present credentials and a Notice of Inspection, interview management, review the operation, walk through production, examine records where authorized, and may collect samples. Significant findings are generally discussed with management at the end.

What should I do if I don’t understand something the inspector says?
Ask for clarification. FDA itself advises firms to ask questions when they are unsure about actions taken during an FDA inspection