A challenging lesson we learned during the pandemic was in pest control. We all know that pest control is essential for food safety on site. This message was misunderstood at the beginning of the pandemic which led to some pest control contact contractors not been allowed access to sites initially. However, in the UK after some lobbying by the pest control association they were granted essential worker status and then they were allowed into the sites. Of course, pest control is considered a very hands-on industry and it’s considered that you must be on site to do it. This was challenged during the pandemic and now there are alternatives to some physical visits.

 

Pest contractors have said that remote pest audits can be done in the interim if a site visit isn’t feasible and things like trend analysis review meetings can certainly be done remotely. This is better than not happening at all, but we have heard of occasions where pest contractors have not been given remote access to on-site pest control management systems and that’s mainly due to security reasons or hurdles. This can be very easily addressed by NDA’s or confidentiality policies. What we do know is that monthly pest control visits have been maintained and we haven’t really heard of many issues with that.

What we have heard is that field biologists weren’t always allowed on site, or their visits were being postponed. We heard some sites could end up not having a field biologist visit for nearly two years by the time the pandemic is over. This does contravene clause 4.14.10 of the food standard. We are not clear why field biologists weren’t being allowed on site, is it cost cutting or is it that sites don’t fully appreciate what the field biologist contributes or was it because the staff were being furloughed and they weren’t there to action the report? We don’t know but certainly what we heard was there was a 35% reduction in food and field biologist visits from one contractor. This of course raises some concerns, not only from a food safety point of view, but also because of all those delayed visits we’re going to have that inevitable backlog of scheduled visits and that now must be managed. So, this begs the question do sites fully appreciate the importance of your field biologist?

Just to add to the concerns from pest control companies, we know that some food sectors saw a huge increase in production demand at the early stages of the pandemic and if this is not managed correctly this can lead to less time to clean and less downtime for maintenance and deep clean. If you add in problems with stockpiling of raw materials and finished products and warehousing this could result in more places for a pest to harbour. If that’s not managed correctly, you’re going to end up with these sudden emergency callouts which are more costly for the site at the end of the day and that’s what we want to avoid.

The other thing that’s important to remember is when the lockdown happened it happened very quickly, and some sites just didn’t have a formal shutdown process. They didn’t have time to implement a thorough shutdown process and that could have led to some food safety prerequisites, such as pest control, not being managed correctly. It’s imperative that everybody has a reopening procedure implemented for when sites or parts of the site are reopened.

 

Information on pest sightings during the pandemic and whether they increased or decreased. This was a survey conducted by the British pest control association (BPCA) and they found that during the pandemic there was a 78% increase in rat activity and a 63% increase in mice activity. This emphasizes the importance of rigorous compliance especially around proofing and monitoring. It also emphasizes the fact that compliance isn’t just for the audit. Sites must operate in accordance with the BRCGS food standard 365 days of the year if they expect to maintain a rigorous food safety management system. If you have some parts of your site have been closed during the pandemic it might benefit from a field biologist visit to help you out with your reopening. ‘Becoming pest ready’ is another document by the BPCA with some guidance on how to reopen your site. That can be found on the BPCA website.

 

 

Moving on to non-conformities, the question is, did the pandemic create new non-conformities or have a notable impact on their prevalence? You can see in this image the percentage of audits that contained certain non-conformances. We just want to put this into context. To understand whether non-conformances differed during the pandemic was quite tricky because there was the added complication of comparing two untypical years. For most sites, 2019 was their first Issue 8 audit which was published in August 2018. Which means their first audit was 2019 and that always affects the pattern of non-conformances at sites because sites have got to get used to the new clauses and take some time to understand how to apply them to their facility. Then of course in 2020 we have had the pandemic, so we have had two consecutive years of potentially untypical data to try and trend.

If you look at the right-hand side of the image, clause 1.1.2 food safety culture was new in 2018 and that immediately was the top of the non-conformances. It’s relatively new for our industry and similarly with clause 2.7.1, the radiological hazard bullet point was new to sites, and this caused some non-conformances. If you look on the right-hand side for the following year those non-conformances moved down to position three and five. What we do see over the years is that the non-conformances have only changed slightly, and the top non-conformances have not had a huge amount of change. Not all the statistics on the remote audits have been done yet because we don’t really have a significant number of audits completed to make the statistics meaningful but what we will do is continue to monitor that as the pandemic progresses.

What we can see is that the overall number of minor non-conformances allocated were slightly down year on year but mostly consistent which suggests that, despite all the challenges, sites are maintaining their food standard clauses reasonably well. Sites must maintain their food safety standards during the pandemic, and they have had to make an awful lot of changes to their sites and operationally to comply to the new Covid rules. We know sites had to focus on these four specific clauses: 2.14.1, 2.2.1, 5.1.2 and clause 4.11.3.

What’s useful here is that the standard gives them flexibility to change systems in a controlled way and therefore maintain food safety and risks. This reinforces how standards are designed to help sites to manage changes such as the pandemic.
Finally, just a word about training. One of the key lessons was that remote working thrust virtual learning into the limelight. This has had a huge impact in breaking down the geographical boundaries that have been traditionally associated with classroom learning. If we look at the importance of having contingencies for training when face-to-face training is not possible. BRCGS has training locations all over the globe. They really took an early commitment that they were going to find ways of adapting to support their certificated sites to continue to develop their teams and to maintain this technical level of competence.

Sites that are more agile and more people-centric will be much better positioned to bounce back stronger once this pandemic is over so by adapting our content and our approach, we have redeveloped our packages to make sure that they’re providing an even better online experience. BRCGS had to reconsider how they did training, they had to adapt and to change. They have reframed the content to make it more online friendly, adapted the training methods so learners are getting a much better experience out of the virtual classroom environment. It’s all now delivered through virtual platforms they have even looked at mobile micro learning. That’s where they’re developing these mobile friendly learning options made as easy as possible for people to learn. There are platforms to allow learners to target specific skill areas that really meet their requirements and their business and professional schedules. Virtual events at BRCGS have switched from traditional learning conferences to virtual conferences and they have been a huge success they are going to continue to support their global network with virtual in-person and hybrids events in 2021 and 2022.

This is a continuation of our series of articles on maintaining food safety standards during a pandemic. You can read Part 1 Here. and Part 2 Here.We have compiled the top five remote audit tips for sites and certification bodies. This is direct feedback from some of the auditors.

Auditor Feedback

1. Preparation is key. With the remote audit approach, preparation by the auditor is much more intensive around the pre-order to review of documentation. It’s important for everyone to understand the pre-audit submissions review, and understand the process so as an auditor you can request the right information beforehand.Although there’s lots of similarities between the on-site and the off-site audit, remote document review generally requires information specified by the auditor to be uploaded onto a document portal. Scanning rather than photographing and uploading documents can take some time so auditors need to make sure that the company is aware before the order date of exactly what information will be required. During the audit itself they’re going to need lots more documentation so to enable that it’s important to have a scanner available if possible.
2. Test that your site it is compatible with the certification body systems. Compatibility can be an issue so the company needs to make sure the IT team is on hand on the day. It’s very important that we’ve got the right people available on the day to help with any technology troubleshooting. We all know video streaming can be poor when internet bandwidth isn’t at its best and of course with these audits taking place all over the world, some in very remote locations where wi-fi and bandwidth is a problem. If you think this could be a problem, it is probably a good idea to request a wired connection to a LAN or some sort of router ahead of time to ensure there aren’t delays on the day. You also need to check in case the company firewall has any internal controls or restrictions. On-screen sharing may need to be resolved in advance.
3. Test the technology in advance. It is a good idea to arrange a dry run in advance if it’s at all possible. The audit day time constraints on the auditor are tough enough already without the pressure of IT problems. It also allows the site and the auditor to have a chance to get to know each other before the actual audit day. Another consideration is that many sites experience live streaming problems due to a faraday cage effect that steel framed factories present and just to get around this the company can possibly upload a pre-recorded video requested by the auditor or present them via a shared screen. If live streaming is possible just be aware of the noise in the plant and how this can impact the auditor and of course the auditor doesn’t have control over the camera and where it’s pointing. A solution for this can be a team approach to the filming maybe involving two or more people with a camera operator and a quality manager using separate devices.Another point is with a typical on-site audit day, the team will all sit around a table during the audit which works well, however when you’re doing it remotely placing the laptop in the middle of a large table to allow everyone to join in doesn’t work so well particularly if the microphone isn’t picking up the sound or if the meeting rooms are a bit echoey. Moving the auditors closer to the microphone may cause social distancing issues so it’s probably better to have everyone logged into an audit platform with headphones and individual microphones.
4. Get familiar with video conferencing. Throughout the pandemic, the use of video conferencing has developed immensely and everyone is now much more familiar with these systems. Certification bodies may have their own platforms whether it’s Microsoft teams or Google, Skype or Zoom. The auditors can be trained in these and get familiar with them. Then they don’t have to deal with resolving any IT issues concerning these platforms, on the day. They’re familiar with the system, they’re not using some alien system on the day. Not knowing how an unfamiliar platform works it’s just extra hassle and extra stress for your auditor and you don’t want to have a stressed auditor!
5. Put a plan in place for poor wi-fi. We’ve mentioned this already but if you were intending to be live streaming during the factory visit but it’s not possible due to wi-fi you could try pre-recording a video of the production facility. However, before you do this you just also need to consider national privacy laws and you must make sure that the video gives a good representation of the site. It doesn’t have to be cinema quality but try to avoid things like nausea inducing rapid panning from one side of the factory to the other. Just think about what it is exactly that your auditor wants to see and focus on those details. Following up on the HACCP process flow diagram might be a good place to start the video. Try experimenting with different recording technology and avoid using the portrait style videos if possible. A digital camera can sometimes be better than a phone camera as it’s easier to transfer the videos onto a computer and so on.

The pandemic has certainly led to a dramatic increase in the use of some digital tools, information communication technology, or ICT, has been essential to the food industry. We know that remote audits could not have been possible without it and it’s been used to demonstrate food safety compliance to auditors. It has helped maintain certification for hundreds of sites across the globe however as we have said that hasn’t been without its challenges.

To recap, we’ve talked about additional steps such as having confidentiality agreements or NDAs to be signed and just to consider documents such as the IAF ID3 or AFMD4 docs need to be understood and agreed with your certification body and if you’re not sure about these just have a chat with your certification body about it. Sites had to learn where their wi-fi hotspots and black spots were in advance of the audit and that’s not something your typical technical manager knows anything about. We’ve heard of some extremely remote sites having no wi-fi at all and making it impossible to conduct a live remote audit. We do know that sites and auditors have used a huge variety of hardware and software. Everything from smartphones, ipads, laptops, even CCTV. They’ve used Go-Pros, they’ve used Whatsapp, they’ve used Microsoft teams. Some have been more effective than others.

ICT however doesn’t in any way constitute digitalization and this is usually an enterprise-wide project requiring investment and lots of detailed projects. The pandemic has not necessarily accelerated digitalization in that respect and it may in fact have slowed down the process in certain businesses. Companies who had started the roll out of a digitalization product may have delayed it because the pandemic took priority but having said that companies that already had digitalization food safety platforms in place had a three-fold increase in their use because those customers realized they could effectively manage their compliance systems remotely using a full set of features that their digital platforms already offered. In other words the pandemic encouraged digital users to exploit a digital based compliance solution that they already had. This is supported by feedback from those using remote technologies to perform internal audits. They enhanced their control to mitigate food safety risks during the pandemic and reiterate the importance of strong internal audits especially when third party audits weren’t possible.

So those who had digital systems in place were very grateful and it really made it a lot easier for them to share their documents with external auditors, it made the entire audit and remote audit experience much more effective.

An example of a rapidly evolving digital tool used in the food industry is digital pest monitors. These integrated pest management tools are a critical component of any food safety program and tools such as rodent monitoring service sensors can protect operations from pest infestations and the related risks of disease, product loss and recalls. They can help ensure your site is audit ready and compliant with lots of the complex regulations associated with food safety standards

We will talk more about pest management and control in the next article.