Food service audit standards and best practices

Food service audit standards and best practices

Written by Jonathan S Youngleson & Johann Leitner

Although the terms for food service audit standards and food inspections are sometimes used interchangeably, there are important differences between them. While audits and inspections may address some of the same standards, such as the rules in the Food Safety Modernization Act (FSMA), their purpose, significance and scope vary.

Food Safety Audits: are conducted by a facility’s own personnel (internal audit) or an outside third-party external audit to determine if a facility is adhering to an agreed set of food safety standards. External audits may be conducted by independent consultants, customers of auditors from one of the recognized food safety certification schemes such as BRC or SQF. The results of these audits include identification of areas where process improvement is needed (corrective actions), attainment, maintenance or loss of third-party certification or loss of business opportunities.

Food Safety Inspections: are conducted by a regulatory body such as USDA, FDA or State agency. These inspections can occur “for cause” as a follow up to consumer complaints or as part of an outbreak investigation, or “routine” random inspections to ensure compliance with applicable regulations. Consequences of failure may include loss of licensure, fines, or criminal penalties.

[Related content: Food service regulations]

The FDA and USDA are the regulatory parties that conduct inspections to find out if food processing facilities are following rules outlined by the federal government. These agencies typically do not conduct audits.

Audits are usually conducted by third parties, and the reason for the audit depends on who is carrying it out. Food processors can pay third parties to conduct audits of their facilities to gain certain safety and quality certifications. These third-party certifications are frequently a customer requirement. Respected organizations that conduct such audits are the Safe Quality Food Institute (SQF), global standards from the British Retail Consortium (BRC), Global Food Safety Initiative (GFSI), and NSF International as well as ISO Certification.

There are also supplier audits in which your customers suppliers assess the food safety programs and other factors at your hospital. For example, a food chain may conduct an audit at a facility where its fresh-cut salads are being made to find out if the plant is following the chain’s supplier food safety standards.

Audits identify areas for improvement around food safety and sanitation in order to determine the best ways to serve the customer. Food processors can, and should, conduct their own internal food safety audits on a regular basis as well.

What are the Consequences of Failing Inspections and Audits?

There can be serious consequences for unacceptable results of both inspections and audits, but failing an inspection can have more substantial penalties. Failing an FDA inspection can require your campus or hospital to correct defects and become compliant with regulations within a set time period. However, if the issues found are a major concern, the inspector may shut down production immediately. It’s also possible that the FDA will require a product recall based on inspection results.

With a third-party audit, it’s more likely that certifications would be revoked, or not awarded. In the case of a supplier audit, unfavorable results could lead to a decision to stop doing business with your organization. These consequences can certainly have a negative financial impact, but are less likely to force a facility to halt operations. Serious failures, however, may be reason enough for a voluntary recall, or even temporary closure.

How Produce Processors Can Prepare for a Food Safety Audit

Facilities should always be audit or inspection ready. Generally, audits are pre-planned and a facility has advanced notice of when an audit will take place and the scope of the audit predefined. Inspections can be announced or un-announced, and “cause” inspections are almost always unannounced.

Because you’re aware of an audit ahead of time, food processors have time to prepare. An audit only gives you a snapshot of what the situation was on the day it was conducted, or it may not uncover defects that are outside the scope of the audit. Effective food safety requires constant vigilance and inspection readiness. It is wrong, but it is possible, to alter documents and recordkeeping to make it look as if proper food safety and sanitation steps are being followed. Using an electronic data capture system will help to avoid this undesirable situation.

Be and Stay Prepared for FDA Inspections

Being prepared for an FDA inspection under FSMA rules necessitates that you must have a well-documented food safety plan for your organization, that has been prepared and overseen by a designated Preventive Controls Qualified Individual (PCQI) who has been trained in FSMA rules. It is very likely that inspectors will ask to review this food safety plan as well as your records that prove your food safety steps are being followed on a regular basis. Without proper documentation or preventive controls and records, it’s as if none of it is happening at all. So be sure to document in detail!

FSMA rules explain what needs to be done, but it is up to your organization to come up with a plan which complies with regulations (visit FDA.gov). Complying with regulations may seem overwhelming, and you may wish to work with food safety experts for guidance and food safety solutions you need as you take on the challenge of FSMA compliance.

The focus of your food safety plan must be on processes that are aligned with written internal SoP’s for safety and quality care, staff training and retraining to ensure competency, and collaboration with operational and clinical stakeholders such as Providers, Nursing, Rehabilitation, Social Work, Facilities, Infection Control, Environmental Care Services, and Environmental Health and Safety departments. Leaders should collaborate with their accreditation department, quality department, and/or other departments to audit scope of service/s provided and ensure that practice and policy match. An electronic audit tool is highly recommended, where results can be reviewed, and Performance Improvement (PI) plans developed on a regular basis to track and report deficiencies and ensure that standards are consistently being met.

How to Prepare for a Survey Inspection

Ensure that you are informed of the Regulatory Standards that govern Dietary Services by completing a Regulatory Crosswalk of these standards. Nutrition Services/Kitchens are often the most inspected areas, whether this is from local or State health departments; operators should know and understand the local regulations as these apply to their operations and ensure staff training is up to date. Regular inspections and audits can help prepare for a successful outcome. CMS utilizes the FDA Food Code when conducting surveys, and are followed by all accreditation organizations as listed below:

**HFAP is now known as ACHC (Accreditation Commission for Health Care, Inc).

Review your required written policies and procedures

1. The hospital has the necessary staff to support the care, treatment, and services it provides.

• The hospital has a qualified dietitian on a full time, part time, or consultative basis.

2. The hospital assesses and reassesses its patients

• The hospital defines, in writing, the scope and content of screening, assessment, and reassessment.
• The hospital defines, in writing, criteria that identify when additional, specialized, or more in-depth assessments are performed 
• The hospital has defined criteria that identify when nutritional plans are developed.
• A current therapeutic diet manual approved by the dietitian and medical staff is available to all medical, nursing, and food service staff.

3. The hospital provides education to patients and families specific to the anticoagulant medication prescribed, including the following:

• Potential food and drug food interactions

4. The hospital makes food and nutrition products available to its patients 

• The hospital prepares food and nutrition products using proper sanitation, temperature, light, moisture, ventilation, and security.
• Food and nutrition products are consistent with each patient’s care, treatment, and services such as therapeutic diets and the evaluation of diets for nutritional adequacy
• The hospital accommodates the patient’s cultural, religious, or ethnic food and nutrition preferences, unless contraindicated.
• Frequency of meals served process for ordering and delivering food to patient areas
• Accommodation of non-routine occurrences such as total parenteral nutrition, tube feeding, change in diet orders, early/late trays, nutritional supplements, and special diets
• The hospital procures and stores food and nutrition products, including those brought in by patients or their families, using proper sanitation, temperature, light, moisture, ventilation, and security.
• Ventilation system provides required pressure relationships, temperature, and humidity 

5. Sanitary Environment to include cleaning schedules, waste disposal, pest management, and personal hygiene protocols

6. Emergency Preparedness 

• The Emergency Operations Plan describes the following:
  • How the hospital will obtain and replenish food supplies throughout the response and recovery phases of an emergency
  • Downtime procedures to follow
  • Maintaining business continuity

Knowing what your peers are doing about Food Safety Audits and Inspections?

Practical experience and expert advice are often the best way to learn. Be sure to expand your network and build relationships to share experiences and best practices for successful and organized Dietary Services. The Association for Healthcare Foodservice (AHF), Association for Food and Nutritional Professionals (AFNP), Academy for Nutrition and Dietetics (AND), and (HFM) are a few professional organizations that offer resources, professional conferences, community listservs, and opportunities to build relationships and network with experts and experienced professionals in the food and hospitality industry. Some questions you can ask about survey experiences are:

• Was your survey within the last 36-month time limit?
• What did your surveyors ask/look for during the department walk-through?
• Did you have a diet tracer? If so, tell us about it.
• Did your surveyors meet with your dietitian team, if so, what was asked and/or discussed?

Regulatory standards often change, so be sure you are keeping up to date on the various code and policy changes especially before your survey window opens. Ensure you have all records and policies available and up to date to ensure accountability.

In its 2021 Healthcare Foodservice Industry study the Association of Healthcare Foodservice (AHF) self-operated food management, healthcare, senior living and long-term care professionals reported that over 85% provide on-demand food service, with most operators providing continuous meal ordering through most of the day with a service standard of delivery of under 45 mins or less (78%). Of those operators not currently offering on-demand room service, a majority (74%), plan to switch to this service in the next 3 years. For non-patient food-service options most operators offer retail food services such as cafés (80%), catering (76%), and vending (56%). Fewer operators (<40%) reported having coffee shops, gift shops, micro-markets, or kiosks in their diverse food operations. These integrated operational decisions are typically driven in response to perceived customer needs, which obviously means you need to know what your customers need.

Incidentally, a top concern identified by 83% of AHF member operators was the scarcity of qualified candidates to fill positions due to the covid pandemic, thus compromising their ability to serve patients and customers in the usual manner.

The AHF Survey revealed that the majority (70%) of patient food trays are delivered by food services staff, with nursing staff also sharing in this task. Telephone and paper remain a significant means by which food orders are placed, although technology-based ordering means are gaining in importance. Menus are typically communicated on paper, with technology accounting for only 3.80%

Consistent “wish-lists” for self-operated food service providers to change patient dining programs emphasize:

• Increased technology use for ordering
• A move away from cook-chill programs
• Increased sustainability options/a la carte
• Offering better tray delivery and setup options
• Adding “on demand” room service

Covid note: most organizations made covid related operational adjustments including regulatory guidelines including reduced seating capacity, enhanced cleaning protocols, increasing packaged food offerings, and making changes to self-service areas, and the use of touchless solutions. It’s not certain how many of these strategies will be retained as covid emergency measures subside in time.

Regular Monitoring and Hardwiring

You need to measure what you wish to manage in the dietary operations. To achieve this, you need to 

• Establish regular unannounced auditing of your operations
• Leverage the expertise within your organization such as Infection Control and the Regulatory departments to implement frequent rounding and auditing to check staff knowledge, compliance with policies and procedures, and environmental safety
• Focus on clean and dirty separation, buildup of grease and dust, temperature logs, labeling and dating, proper storage of food and chemicals to include the 6 inches from the floor and 18 inches from the sprinkler heads guidance, floors, surfaces, and equipment cleaning schedules. 
• Be sure to circulate/post audit results and explain how they relate to inspections and potential deficiencies.
• Meet with your Human Resources Business Partner to conduct employee file Audits to ensure employee files are up to date to include orientation paperwork, current licenses, and certifications as per Job Description and/or regulatory requirements.

What Touchwork can do for you?

Touchwork provides a range of solutions to streamline the capture and reporting of  food safety (and other) audits and inspections. 

Touchwork’s solutions are built on the powerful and flexible cloud-based Kinetica CX platform and can be used individually or in any combination. They provide results in real-time with advanced drill down reporting and analysis capabilities. They are quick to deploy, require no on-site IT support and are optimized for use with mobile devices. Touchwork’s Kinetica platform is an automated survey and data collection platform that provides maximum flexibility to craft and implement data driven workflows, integration with third party systems and logic to manage complex survey and audit implementations.

Further reading: Food safety regulations