What the FDA Inspects at a Food Production Facility, and… | Kaloutas

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What the FDA Inspects at a Food Production Facility, and How to Keep Your Business Compliant

Industrial facility. What the FDA Inspects at a Food Production Facility, and How to Keep Your Business Compliant

As a busi­ness own­er or man­ag­er, you need to ensure that your food pro­duc­tion facil­i­ty is com­pli­ant with FDA reg­u­la­tions. After all, com­pli­ance pre­vents penal­ties and ensures that your facil­i­ty can con­tin­ue to operate. 

You can find the FDA guide­lines on its web­site, but that infor­ma­tion includes legalese and tech­ni­cal jar­gon. The fol­low­ing guide will ful­ly answer your ques­tion, What does the FDA inspect?” so you don’t have to search else­where. We will even give you the best advice for keep­ing your facil­i­ty FDA-compliant. 

FDA Guide­lines for Food Pro­duc­tion Facilities

The most impor­tant guide­lines for food pro­duc­tion facil­i­ties have to do with over­all clean­li­ness. The FDA ensures that your facil­i­ty has no cross-con­t­a­m­i­na­tion or oth­er poten­tial issues. Specif­i­cal­ly, you can expect an FDA facil­i­ty inspec­tion to include the following. 

Food Safe­ty Programs

Expect the FDA inspec­tor to ask about your food safe­ty pro­grams. Inspec­tors will ask to see the doc­u­men­ta­tion for these pro­grams and ver­i­fy the records, ensur­ing that your pro­gram meets the lat­est FSMA requirements. 

An Over­all Tour/​Inspection

The first part of an FDA facil­i­ty inspec­tion will typ­i­cal­ly be an over­all inspec­tion of the facil­i­ty. Plan on giv­ing the inspec­tor a tour of the pro­cess­ing areas, as well as every oth­er rel­e­vant area of your facil­i­ty.

Review­ing the Records

You can also expect the inspec­tor to scru­ti­nize your records. As men­tioned, your records should include food safe­ty pro­grams and records for mon­i­tor­ing and verification. 

The FDA is not enti­tled to review finan­cial, pric­ing, sales, research, or per­son­al data. For per­son­al data, they can only ask for proof of appro­pri­ate training. 

Micro­bi­o­log­i­cal Sampling

Dur­ing the inspec­tion, the FDA will col­lect a vast num­ber of sam­ples. Expect them to col­lect swabs from sev­er­al areas of your facil­i­ty, usu­al­ly total­ing about 100 to 200 swabs. These swabs will include sam­ples from Zone 1 through Zone 4 envi­ron­ments, out­go­ing prod­ucts, and incom­ing ingredients. 

The orga­ni­za­tion will then test every sam­ple for poten­tial con­t­a­m­i­na­tion, includ­ing pathogens. If the results show high lev­els of cer­tain pathogens, includ­ing sal­mo­nel­la or lis­te­ria mono­cy­to­genes, expect the FDA to require you to issue a recall. The results of the bio­log­i­cal sam­ples from your facil­i­ty will also be com­pared to the DNA fin­ger­prints of oth­er pathogens in the FDA’s system. 

The Impor­tance of FDA Compliance 

When it comes to food pro­cess­ing facil­i­ties, you can expect the FDA to do rou­tine inspec­tions due to health and safe­ty rea­sons. The con­se­quences of not pass­ing the inspec­tion can be cat­a­stroph­ic, poten­tial­ly even clos­ing down your busi­ness per­ma­nent­ly. Of course, if you take steps to remain com­pli­ant at all times, you need not be worried.

That said, you should rec­og­nize the risks that come with fail­ing the inspec­tion. To start, non-com­pli­ance can involve offi­cial penal­ties and fines that may hurt your busi­ness. Fines will have an obvi­ous finan­cial impact on your com­pa­ny. But oth­er penal­ties, such as recalls or tem­po­rary facil­i­ty clo­sures, can also become incred­i­bly costly. 

Fail­ing an inspec­tion can also dam­age your company’s rep­u­ta­tion sig­nif­i­cant­ly. Depend­ing on the extent of the dam­age to your rep­u­ta­tion, you may not be able to attract enough cus­tomers. At the very least, you will have to work much hard­er to attract clients, reas­sur­ing them that you have addressed the FDA’s concerns.

How to Pre­pare for an FDA Inspection

Once you know that the answer to Does the FDA inspect food pro­cess­ing facil­i­ties?” is yes, you may won­der how to pre­pare. The good news is that you should receive notice of an upcom­ing inspec­tion. This will give you time to gath­er doc­u­ments and make oth­er prepa­ra­tions. Don’t expect to have enough warn­ing to make any dras­tic changes, as that will defeat the pur­pose of the inspection. 

Start by get­ting in the habit of fol­low­ing the FDA guide­lines and best prac­tices. These are high­ly focused on san­i­ta­tion, so you must have a detailed clean­ing and main­te­nance plan in place. Con­sid­er out­sourc­ing facil­i­ty clean­ing to a com­pa­ny famil­iar with FDA require­ments. Remem­ber that in addi­tion to gen­er­al facil­i­ty clean­ing, you must have food dis­in­fec­tion pro­to­cols in place. 

Gath­er an Inspec­tion Response Team

Cre­at­ing an inspec­tion response team is one of the first things to put on your FDA facil­i­ty inspec­tion check­list. This team will con­sist of peo­ple who will be respon­si­ble for gath­er­ing rel­e­vant doc­u­ments. It will also include at least two peo­ple to accom­pa­ny the FDA inspec­tor. One of these indi­vid­u­als should act as a guide for the inspec­tor, while the oth­er should be a scribe and record every­thing that tran­spires. Doc­u­ment­ing the inspec­tion will be use­ful for your records and can even help you pre­pare for future inspections. 

Have Some­one Accom­pa­ny the Inspec­tor at All Times

As men­tioned, some­one should serve as a guide for the FDA inspec­tor. Impor­tant­ly, if that per­son has to leave the FDA inspec­tor for some rea­son, anoth­er per­son should take their place. Nev­er leave the FDA inspec­tor unat­tend­ed. This could reflect poor­ly on your facil­i­ty and present extra oppor­tu­ni­ties for them to find deficiencies. 

If the inspec­tor is alone, you also lose knowl­edge of their inspec­tion. You won’t know what areas of the facil­i­ty they see or be able to ask ques­tions about their pro­ce­dures. In fact, the FDA encour­ages you to ask ques­tions if you aren’t sure why the inspec­tor is tak­ing a cer­tain action. 

Set Up a Space for the Inspector

While you won’t have enough notice to deep clean your facil­i­ty before the inspec­tor arrives, you will have enough time to set up a space for them to work. Clear­ing out a con­fer­ence room or office will put the inspec­tor in a bet­ter mood, so make sure you include it on your FDA facil­i­ty inspec­tion check­list.

Gath­er Documents

One of the most impor­tant roles of your inspec­tion response team will be gath­er­ing all the doc­u­ments that the FDA inspec­tor will like­ly request. Make it a habit to orga­nize your doc­u­ments reg­u­lar­ly, so the nec­es­sary paper­work should be easy to find. It may help to orga­nize these doc­u­ments in chrono­log­i­cal order. You may even want to cre­ate charts or graphs. 

Cor­rect Defi­cien­cies as Soon as Possible

Even with the best prepa­ra­tion and poli­cies, FDA inspec­tors will still find areas for improve­ment with­in the facil­i­ties they inspect. These will be not­ed on Form 483, which you can see a copy of. You will also be able to dis­cuss the find­ings with the inspec­tor. Minor issues are unlike­ly to result in penal­ties or fines if you take care of them quickly. 

Start cor­rect­ing any not­ed defi­cien­cies as swift­ly as pos­si­ble. In some cas­es, you may even be able to start cor­rect­ing them while the inspec­tor is still present. Do so when­ev­er pos­si­ble, as this indi­cates your will­ing­ness to com­ply. Also, make sure to doc­u­ment all the cor­rec­tions you make. 

Get Inspec­tion Sup­port From Your Contractor 

The best way to pre­pare for an FDA facil­i­ty inspec­tion is to com­bine good reg­u­lar prac­tices with sup­port from a con­trac­tor. For exam­ple, Kaloutas pro­vides inspec­tion prepa­ra­tion and sup­port. These ser­vices help keep you FDA-com­pli­ant, safe, and productive.

Let Kaloutas help keep your facil­i­ty com­pli­ant with the most recent FDA guidelines.


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