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10 Things to Know Before Arguing with Your Inspector
By Frank Guray, Consultant & Trainer, Professional Food Safety Ltd.
Picture this…you and your team is having a record day and is producing your products. Everything seems to be working well: materials arrived on time, equipment is working well, and your workers are productive and happy. And then suddenly, your inspector walks into the room, finds condensation in the back area of the room, nowhere near product, and then shuts you down. Or how about a label print error? Or not starting up because of pre-operational sanitation issues?
Though these can be food safety issues, and we are not in the business to hurt or injure our customers, we feel sometimes that our inspector takes it too far. But before you start an argument with your inspector, here are 10 things that you need to keep in mind:
- You will get nowhere by arguing with your inspector. Arguing with an inspector is like telling a police officer that you were not speeding and that they are not doing your job properly. Not a good idea. Inspectors are not robots; they are human beings that enforce the law. Keep in mind that you need to
work with this person(s) for 6 months, even more. A partnership will get you farther.
- Don't get violent. You may create a hostile environment for a federal employee, which may be worse than you start.
- An inspector wants to know that you are taking a proactive approach to food safety. Repairing small items on a weekly basis, additional training, a higher sense of awareness for food safety are ways to create trust. Inspectors want to know that companies do not follow the saying, "When the cat's away…the mice will play."
- Negative findings or Non-Compliance Records (NRs) are a part of doing business in the food industry. Appealing all NRs is not the way to maintain a partnership with your inspector. Discuss the concerns and weigh the options. By successfully appealing small NRs, you may win the fight, but you may lose the war. One more note, if you are the local District, or Washington, DC, and you see a facility that has not had any NRs in 3 or 6 months, what would you think about the facility? Maybe the facility is that good or maybe the inspector does not show up or do his or her job? Probably the later…
- Simply keeping an open line of communication does wonders for working with your inspector. If he knows that you are being proactive and that you notify him of findings and deviations, this may help in easing the constant inspection that an inspector would be required to do, if the company is not proactive. Though they might not be able to be part of your Food Safety Team, they can certainly contribute and thus, prevent an adversity between the inspector and the company.
- Though the inspector may not be responsible for their facility, periodic reviews are done to the facility by review officers. A poor result in a facility may reflect poorly on the inspector. They have just as much at stake as you do.
- Odds are your inspector has multiple assignments. A facility that performs well and is proactive may give the inspector an excuse to go and focus on other facilities.
- Keep in mind that this is food safety and that the inspector is simply doing his or her job. There have been instances where a supervisor would write up the inspector by not writing up a finding but only telling the company to take care of the issue.
- Understand the rules of the game. Know the regulations. Know your food safety programs. It is extremely difficult to deal with inspection services and not even know the rules. In the eyes of all auditors and inspectors, you present a front of weakness if you don't understand the rules.
- At the end of the day, you are ultimately responsible for any failures in your system. Treat all findings of inspectors as serious failures in your system. Better that it was found by your inspector, rather than found by a consumer, then reported to the authorities.
Frank Guray is a Consultant & Trainer at Professional Food Safety Ltd. He graduated from Purdue University at Lafayette with a Bachelor's of Science in Agricultural Engineering - Food Processing Option. An Indiana Professional Intern Licensed Engineer, he was with Tyson Foods, Inc. working at multiple plants and has served in various capacities. He instructs and audits at various capacities, including HACCP Introductory and HACCP Advanced, to Local Food Safety Sanitation Management classes. In addition, he assists plants with all aspects of regulatory compliance and processing issues, including inventory control, acting as a liaison with regulatory agencies, audit preparation and onsite training. For article feedback, contact Frank at fguray@professionalfoodsafety.com
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