FSSC 22000 unannounced audit: how to stay audit ready on any day

The security guard phones the QA office at 07:40: there is an auditor at the gate, and nobody knew they were coming. For an FSSC 22000 certified site, that call is certain to come at least once in every certification cycle, and the FSSC 22000 unannounced audit is designed to show the site as it really runs, not as it looks after a week of preparation. The answer is not a faster clean-up. It is a system that is ready on any ordinary day.

How the FSSC 22000 unannounced audit works

Under the current scheme (Version 7), the certification body must carry out at least one surveillance audit unannounced after the initial certification audit, and at least one in every three year period after that. The certification body decides which surveillance audit it will be. The initial certification audit (stage 1 and stage 2) cannot be unannounced. A certified organisation can also choose to have all of its surveillance and recertification audits unannounced, which some sites prefer because it removes the “audit season” mindset altogether.

The key features, as the scheme sets them out:

• No notice of the date. The site is not told in advance when the auditor will arrive, and the audit plan is only shared at the opening meeting.
• Normal operating hours. The audit takes place while the site is producing, with consideration of all shifts. If you run a night shift, the auditor may want to see it.
• The factory comes first. The audit starts with an inspection of the production facilities and premises, which must begin within one hour of the auditor arriving on site.
• Off-site activities are included. Secondary sites, off-site storage, warehouses and distribution facilities that fall under the certificate are also audited during the unannounced audit.
• The site must be operating. If it is not operating when the auditor arrives, the unannounced audit is rescheduled. If parts of the process cannot be audited on the day, an announced follow-up audit is scheduled within 28 calendar days.

Where visa or security restrictions apply the certification body may give a time window instead of a date. Check your certification agreement and confirm the detail with your certification body.

Blackout days and the access rules to agree in advance

Blackout days are days when an unannounced audit would not be possible or meaningful: a planned annual shutdown, a stocktake, a major maintenance week. The scheme requires blackout days to be agreed in advance between the certification body and the certified organisation. The scheme itself does not set a number of days, so ask your certification body for its rule on how many you may request and how far in advance, in writing, rather than relying on what another site told you.

The consequence of getting this wrong is serious. If a site refuses to let the auditor in for an unannounced audit, the scheme requires the certificate to be suspended within three working days of the refusal. If the unannounced audit is then not conducted within six months, the certificate is withdrawn. “The QA manager is on leave” is not a reason to turn an auditor away.

Agree these points with your certification body before the window opens:

• Your blackout days for the year, with the reason for each.
• Your production days and shift times, so the auditor arrives when you are producing.
• Any site safety or security induction the auditor must complete at the gate, and how long it takes.
• The contact names and phone numbers security must call.

The first hour: who meets the auditor and where they go

The first hour is where unprepared sites lose ground. The auditor waits at reception while people search for the QA manager, the induction video will not play and nobody can find visitor PPE. Write a one page “auditor at the gate” procedure and train security and reception on it.

1. Security checks the auditor’s identity document and certification body credentials, signs the auditor in and calls the first contact on the list.
2. The first available contact (QA manager, then food safety team leader, then production manager) comes to reception immediately. Every one of them must be able to host the audit alone.
3. The host issues PPE, completes the visitor health questionnaire and the hygiene induction, and informs the site manager.
4. A short opening meeting, where the auditor shares the audit plan, and then the facility inspection, which must start within the hour the scheme allows.

Keep a ready pack at reception: visitor PPE in a range of sizes, the induction material, the site plan and a list of what is running today. While the host is on the floor, a second person (a scribe or document runner) should know where every record lives.

Daily habits that keep records audit ready

An announced audit tempts sites to catch up on paperwork the week before. An unannounced audit exposes exactly that. Records must be complete on the day they are made. The habits that work:

• Same day verification. Supervisors check and sign monitoring records (CCP and OPRP records, cleaning, temperatures) before the end of each shift, not at the end of the month.
• A weekly records walk by the food safety team leader, sampling a few records from each area and following up gaps immediately.
• Open actions tracked in one place, with owners and dates, so you can show the auditor the status of last year’s nonconformities and internal audit findings in a minute.
• Current documents only at points of use. Old versions of work instructions on the factory floor are an easy finding.
• Training records filed as training happens, including new starters and temporary staff.
• Monthly checks of the things that expire: calibration certificates, pest control reports, supplier approvals and certificates, and water test results.

A regular internal audit programme run in the same unannounced style is the best rehearsal you can give your team.

The factory floor walk auditors start with

Because the scheme requires the audit to start with a facility inspection, the auditor sees your site as it is at that moment. Think about what an auditor notices in the first 30 minutes:

• Hand wash stations stocked and used, and staff following the hygiene rules at entry points.
• Product, packaging and ingredients properly labelled, covered and stored off the floor.
• Allergen controls visible: segregation, colour coding and line changeover records.
• Equipment condition: temporary repairs with tape or cable ties, flaking paint, condensation over open product.
• Glass and hard plastic, knives and loose items under control.
• Pest control devices in place, numbered and matching the site plan.
• Operators who can explain the CCP or OPRP at their step, what the limit is and what they do when it is not met.

Here is an example from our work. A meat processor in the Western Cape passed announced audits for years. On its first unannounced audit the auditor walked in during the morning changeover and found that the metal detector check had been signed for 06:00 but the test pieces were locked in the QA office, which only opened at 07:30. The records were not dishonest in intent; the night shift had signed in advance out of habit. That one observation turned into a major nonconformity on record integrity. The fix was simple: test pieces in a locked box at the line, with the key held by the shift supervisor. The lesson was not.

What not to do when the auditor is at the gate

The morning an auditor arrives is not the time to rebuild the site. It is reasonable to make sure the auditor’s route is safe and that obvious, everyday housekeeping is done, the same as any normal shift. What must be left alone:

• Do not complete or backdate records. Missing entries are a finding. Records filled in after the fact are a much bigger one.
• Do not hide product, stop lines or send staff home to make the site look quieter. The point of the audit is to see normal operation.
• Do not delay the start with long meetings or waiting for a particular person.
• Do not coach operators on what to say. Auditors ask open questions and can tell when answers are rehearsed.
• Do not argue findings on the floor. Note them, ask for clarity and deal with them at the closing meeting or in your corrective action response.

What to do this week

• Confirm with your certification body when your unannounced audit window opens, your blackout days and how they want them requested.
• Write and train the “auditor at the gate” procedure, with at least three named hosts.
• Prepare the reception pack: PPE, induction, site plan.
• Do an unannounced floor walk yourself tomorrow at 06:00 and record what you find.
• Check one week of CCP and OPRP records for same day verification.

If your team needs to understand the scheme requirements properly, our FSSC 22000 Version 7 implementation course for food manufacturers explains what the scheme requires and how to put it in place on a real site. Sites that need the paperwork in shape can start from the FSSC 22000 Version 7 document templates toolkit, and our FSSC 22000 consulting team can run a mock unannounced audit for you.