Episode 6: Management and Auditing of the CAPA Program

Corrective & Preventive Actions (CAPA)

In the sixth installment of the Kellerman Consulting Corrective and Preventive Action video series, we discuss management and auditing of the CAPA program. Internal audits and management reviews of programs and policies are a nonnegotiable part of a culture of food safety, but it is particularly important for the success of the CAPA program. In this video, we discuss the differences between an internal audit and a management review of the CAPA program, and why each of these are important for a facility’s success.

An internal audit of a program focuses on the review of documentation for availability, accuracy, and completeness. In an internal audit, we are looking for evidence that that program is fully implemented by reviewing associated documentation such as CAPA reports, changes to policies and procedures as part of a CAPA response, or training records associated with corrective actions and preventive measures. All associated records should be available during the internal audit with all aspects of the document completed. Records should also be reviewed and signed by the appropriate management personnel. Internal audits should be conducted by an internal audit team or individual trained in auditing techniques.

In contrast, management review of a program focuses on the effectiveness of the program in finding nonconformances, and that the corrective actions and preventive actions implemented in response to identified nonconformances are effective in reducing the total number of deviations or preventing recurrence of repeat deviations. Management review of the CAPA program should include tracking and trending of both the number and type of deviations that have occurred over a period of time, and at least since the last management review was conducted. This assists the facility in evaluating whether the total number of nonconformances have increased or decreased following the implemented corrective and preventive actions, or if a specific type of nonconformance (i.e. facility issues, employee errors) is more prevalent than others. Management review must include key site leadership and management personnel in order to achieve its intended impact.

In our final video in the CAPA series, we discuss CAPA programs as part of a GFSI scheme. Subscribe to our YouTube channel or follow us on LinkedIn to be notified of new educational food safety resources.

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