Food processing inspections

Follow-Up Review Report No. 14-17

December 2014

Georgia Department of Audits and Accounts
Performance Audit Division
Greg S. Griffin, State Auditor Leslie McGuire, Director

Why we did this review
This follow-up review was conducted to determine the extent to which recommendations in our June 2012 performance audit (11-31) have been addressed.
The purpose of the original audit was to review the Department of Agriculture's efforts to ensure a safe food supply by confirming food processing facilities are adhering to standards. The objectives of the audit were to assess the effectiveness and efficiency with which the food processing inspection program inspected licensed facilities and took appropriate action when it identified problems.
About the Manufactured
Food Program
In September 2012, the Food Processing Program and the Dairy Program were merged into the Manufactured Food Program. This Program is responsible for the inspection of food processing plants, wholesale bakeries, bottled water and drink processors, and sanitation in establishments where food is handled and manufactured. Inspectors collect water and food samples from these facilities to ensure food safety and compliance with regulations.

Follow-Up Review
Food Processing Inspections
Action has been taken to improve
monitoring and oversight
What we found The Georgia Department of Agriculture's Manufactured Food Program has taken steps to address issues identified in our June 2012 performance audit.
Specifically, the program implemented a risk-based inspection model that takes into consideration the product type, distribution volume, and previous compliance with regulations. Prior to this model, the program was attempting to inspect every facility every six months. Our 2012 report found that this goal was not being met. The new frequency is based on the assigned risk category: low risk facilities are inspected every 18 months, moderate risk facilities are inspected every 12 months, and high risk facilities are inspected every six months.
The program has also established procedures to help ensure food processors are implementing the state's testing regulations. It incorporated the testing requirement into its inspection form and developed a process for addressing non-compliance. Management is also collecting information on the types of products tested by facility and on statewide trends in positive testing, which can be used to establish baseline metrics.
The program addressed issues related to inspection quality and consistency by increasing training hours for inspectors, establishing an online training course, and creating a new Field Training Coordinator position to work directly with inspectors in the field. The program has also continued development of a comprehensive audit program to ensure that inspectors are applying standards and regulations correctly and consistently.

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www.audits.ga.gov

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The program has taken steps to increase and monitor individual inspector productivity as well. For example, management noted that it is has the ability, using the system's GPS data from each inspector's cell phone, to monitor their daily activities, such as time spent on site, traveling to and from facilities, and route taken to ensure efficient use of resources. The program also used inspection data to set baseline inspection time frames based on the type of business, size of facility, and product produced.
Finally, the program refined its Manufactured Food Inspection Report for documenting inspection activities. It also continues to explore adding additional components to the form to collect information on specialized food products and processes. The form has also been incorporated into the program's electronic database.
Additional action could be taken to establish policies to help increase the amount of time available for conducting inspections. For example, the program could provide guidance on when inspectors should visit facilities for administrative tasks instead of making a phone call. The program could also establish guidance on when inspectors can notify facility management of an impending inspection. In some cases, prior notification could be beneficial to ensure facilities, especially the smaller ones, will be open if an inspector is traveling a long distance.
The following table summarizes the findings and recommendations in our 2012 report and actions taken to address them. A copy of the 2012 performance audit report 11-31 may be accessed at http://www.audits.ga.gov/rsaAudits.

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Food Processing Inspections Follow-Up Review, December 2014
The Department of Agriculture should implement a risk-based approach for scheduling routine inspections.
Fully Addressed In the original audit, we found that the program was not using a risk-based approach to conducting inspections and that it was not meeting its own goal of inspecting each facility every six months. The program has implemented a risk-based system and is using it to guide inspection frequency.

RECOMMENDATIONS

Original Recommendations
DOA should adopt a risk-based approach, which includes baseline frequencies for inspections. By incorporating a risk analysis into the inspection process, DOA can focus its inspection activities on the facilities that pose the greatest risk to health.

Current Status
The program implemented a risk-based inspection system for the Manufactured Food Program in 2012. The approach includes the determination of risk category based on the following factors: type of products produced; method of processing; facility square footage; distribution volume; and previous compliance with regulations. The procedure has been updated and revised, and is now incorporated into the Food Safety Division's electronic database, known as Digital Health Department (DHD). According to management, the risk category directly affects the frequency of inspection, as well as required frequency for conducting finished product testing.
In addition, inspectors assess the risk classification of each facility during the routine inspections to determine if they should request a change to the risk category classification. Management noted that the Food Safety Division is currently working with the Department's Information Technology Department to classify each risk factor in DHD to facilitate a standardized assignment of risk classification within the next year.

The Department of Agriculture should continue efforts to improve its inspection form and related processes.
Fully Addressed In the original audit, we found that the program's inspection form was designed for more general food safety requirements and did not reflect the specific risks associated with the food manufacturing operations in the processing facilities. The program has implemented a new form that is specific to manufactured food inspections. It is also considering adding new forms that would be even more specific to certain food manufacturing processes.

Original Recommendations
The department should continue implementation of the new inspection form and processes to more specifically address processing environments.

Current Status
The program implemented the Manufactured Food Inspection Report in 2012. The report documents inspection-related activities at all food processing facilities. The program also incorporated the report into DHD to provide consistency with the information collected regarding the condition of facilities inspected. In addition, the program is in the process of adding citations into DHD to increase efficiency.

RECOMMENDATIONS

Management should evaluate opportunities to develop addendums to the base form for application in different types of processing environments.

Program management stated that they continue to explore the addition of new inspection forms for specialized processes such as low acid, acidified, seafood, and warehouse inspections.

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Food Processing Inspections
Follow-Up Review, December 2014
Management does not have a systematic process for ensuring that inspectors are consistent in their interpretation and application of the food safety regulations.
Fully Addressed In the original audit, we found variability between inspectors in the number of violations written and the length of time it took to complete inspections. Absent a process for monitoring the inspector's activities and determining whether they were being accurate and complete in their inspections, it was not possible to determine whether inspectors were operating effectively and efficiently. To ensure consistency in the application of the regulations, the program has increased the training provided to inspectors; established standards and protocols for inspections; and, improved the evaluation of inspectors' work in the field.

Original Recommendations

Current Status

RECOMMENDATIONS

The program has taken steps to improve overall inspection quality by increasing training hours, developing policies and procedures for the Food Inspection Regulatory Standards Training Program, and creating an online training course curriculum for inspectors. Additionally, the program developed new protocols to better guide decision making regarding compliance with standards and identification of violations.

Due to the inherent subjective nature of the food safety inspections, it is necessary that management develop a comprehensive process for evaluating the quality of inspections completed by its employees.

Additionally, Field Supervisors are now required to conduct quarterly reviews of inspectors and to work with them in the field, thereby increasing oversight and monitoring. The program also created a Field Training Coordinator position. The Coordinator will train inspectors, develop baselines for inspections, assist with policy development, and assist with food safety initiatives.
Management reports that it has continued developing its comprehensive audit program to include performance reviews of inspection reports and product sample collections. It also utilizes DHD to review inspection reports and the time inspectors spend in conducting each inspection. Any time or travel discrepancies are discussed with the individual inspectors.

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Food Processing Inspections Follow-Up Review, December 2014

The Department of Agriculture should establish productivity standards for inspectors and monitor inspectors to ensure inspections are conducted as expected.
Fully Addressed In the original audit, we found that management could not determine if employees were operating at an acceptable level, were under-productive or thorough in their inspections because they lacked standards for what constituted acceptable performance. We found that, depending on the individual, inspectors spent from less than a quarter to a little over half of their day conducting inspections; additionally, the average number of inspections conducted per day ranged from 1.43 to 3.58. The program has made improvements, such as using the Field Force Management program to facilitate monitoring of inspectors activities; and has begun the process of establishing benchmarks for individual inspectors.

Original Recommendations

Current Status

RECOMMENDATIONS

We recommended the program develop a comprehensive program for monitoring inspector productivity to include goals based on an analysis of historical data. We also recommended management monitor performance against the established goals and re-evaluate and update them as necessary.

The program is using the Field Force Manager (FFM) system to monitor inspectors' activities. Management noted that it has the ability, using the system's GPS data from each inspector's cell phone, to monitor their daily activities, such as time spent on site, traveling to and from facilities, and route taken to ensure efficient use of resources. Management also noted that it reviews each inspector's weekly timesheets and daily inspection logs to evaluate how inspectors are spending their time. On October 1, 2014, the program implemented a Monthly Productivity Report that will help establish a baseline for the number of inspections performed and violations documented and in November, it held training sessions with program managers and supervisors to further define and measure performance goals.

The program has developed inspection times based on type of facility, facility size, and type of product(s). It is also collecting information through its risk-based inspection system that facilitates measuring inspector productivity.

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Food Processing Inspections
Follow-Up Review, December 2014
Opportunities exist for the Department of Agriculture to increase the amount of time available for conducting inspections.
Partially Addressed In the original audit, we identified areas in which changes could be made to improve efficiency. The program has made some changes to improve efficiencies and increase the amount of time for inspectors to conduct inspections; however there were additional actions that the program could take to maximize the amount of time available for inspections.

Original Recommendations

Current Status

RECOMMENDATIONS

We identified six areas in which action could be taken to improve efficiencies, allowing more time for additional inspections. The areas were travel, inspection report write-up, enforcement, sample collection, and non-inspection activities.

The program has taken steps to improve efficiencies in several of the recommended areas as discussed below.
Inspectors have access to Department staff at the central office that can assist them in using geospatial data to allow them to group their inspections in the same area and reduce travel time. Management noted that, regarding inspection reports, some paperwork can now be completed offsite. It also indicated it is working with IT to develop additional strategies for increasing productivity. The program addressed sample collection by establishing a north and south component for its courier service that provides for sample shipment twice a week at 12 strategic locations across the state. It noted that this change allows inspectors more time for conducting inspections.
Additional actions could be taken to address when it is appropriate for inspectors to contact a facility prior to a visit, to ensure the facility is open, as well as when inspectors must go onsite to conduct non-inspection activities such as delivering correspondence or discussing processes.
Agency Response: In its response to the report, the agency noted that "...unannounced inspections are performed to ensure the conditions observed during the inspection are truly indicative of the normal facility operations conducted." It also noted that it will "...explore the possibility of drafting policies and procedures to establish when contacting an establishment would be acceptable, and the limits for utilizing this advanced notice."

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Food Processing Inspections
Follow-Up Review, December 2014
Additional action should be taken to ensure the state's testing regulations are being implemented.
Fully Addressed In the original report, we found 6 of 11 facilities we visited reported that they were not conducting required tests because they were unaware of the law, misunderstood the regulations, or were waiting for the program to review their food safety plans. The testing requirements had been in place since 2009. The program has added process steps to ensure it identifies non-compliant businesses and has established procedures for handling such non-compliance.

Original Recommendations

Current Status

RECOMMENDATIONS

To ensure food processors are compliant with state testing laws, management should establish oversight and enforcement procedures. Management should consider collecting information on the products selected for testing by each facility, and the types of tests each facility conducts. Management should periodically review the incidence rates of reported positive tests...to approximate the effectiveness of the law.

The Manufactured Food Inspection Report now includes a category for product testing to identify facilities that are not complying with regulations. Inspectors must file a Reportable Conditions Form if a firm is not testing as required, or cannot provide lab analysis. The Compliance and Enforcement section then takes further action. There are also specific enforcement actions for firms not complying with state testing requirements.
Additionally, the product testing requirements, directions for reporting, and links to online testing regulations, are now included on each inspection report provided to the businesses.
Management also noted that it is collecting information on the types of products produced and tested at each facility to be recorded in its data system and collecting information on statewide trends in positive testing.

The department could improve its guidance to inspectors regarding escalation of violations for corrective action.
Fully Addressed In the original report, we found problems in the processes for determining if a follow-up inspection should be conducted, the escalation of enforcement efforts, and the timeliness of enforcement actions. The program has since developed new procedures, and revised existing ones, to provide additional guidance. It also established a new section to ensure uniform escalation of enforcement actions.

Original Recommendations

Current Status

The department should develop specific criteria that would trigger a follow-up inspection; management should then conduct a regular desk review of a crosssection of inspection reports to ensure consistency among the inspectors in their decisions to conduct follow-ups.

The program developed new procedures, and revised existing ones, to guide inspectors through the inspection process and increase consistency among inspectors on issues that require judgment calls. These protocols provide inspectors with guidance in determining the need for re-inspections and follow-up inspections.

RECOMMENDATIONS

The department should review its process for escalating enforcement action to ensure that it is adequate, update its processes as necessary, and institute internal controls to ensure processes are followed. Enforcement actions should be prioritized to ensure that violative conditions are addressed as quickly as possible.

The program established a Compliance and Enforcement section to facilitate uniform escalation of enforcement actions. In addition, it developed policies that limit the number of follow-up inspections that should be conducted without effective action being taken by the business.

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Food Processing Inspections Follow-Up Review, December 2014

Management should develop procedures that will address the delays in initiating such actions.

The program's Manufactured Food Inspection Protocol document prioritizes enforcement actions. It has also revised and developed other policies and procedures that have improved the tracking and expediting of enforcement actions.

Consideration should be given to making inspection reports available to the public.
Not Addressed In the original audit, unless an Open Records Request was submitted, the public remained largely unaware of the violations and inspection results of processing facilities manufacturing food in the state. The report suggested making the reports available through the website.

Original Recommendations

Current Status

RECOMMENDATIONS

The program has not made inspection reports available on its website.

Consider making inspection reports public documents.

Agency Response: In its response to the report, the program noted that the Open Records law provides the public with broad access to departmental records and documents and that requests are processed within three business days of receipt of the request.

The department's process for identifying unknown firms appears adequate.
Fully Addressed In the original audit, we noted that the program's processes for identifying unknown firms was adequate. Facilities had to obtain a license from the Department prior to beginning operations and counties require proof of licensure before granting a local occupational tax permit or local business license. However, because not all counties are enforcing this requirement, we noted that the program could identify those counties and monitor businesses in these areas for non-compliance. The program reported it is working with county governments.

RECOMMENDATIONS

Our research identified six firms that were operating as unlicensed food processors, which demonstrated negligible adverse effects associated with this potential gap in controls. DOA could consider identifying counties where a license or permit is not required and monitoring the businesses in that area that may require licensure.

The program noted that it continues to inform county governments that food processing facilities must produce a state license prior to granting a local business license or local tax permit.

9 Findings

7 Fully Addressed 1 Partially Addressed 1 Not Addressed 0 Not Applicable

The Performance Audit Division was established in 1971 to conduct in-depth reviews of state-funded programs. Our rviews determine if programs are meeting goals and objectives; measure program results and effectiveness; identify alternate methods to meet goals; evaluate efficiency of resource allocation; assess compliance with laws and regulations; and provide credible management information to decision-makers. For more information, contact
us at (404)657-5220 or visit our website at www.audits.ga.gov.