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Author: Karl Kolb PhD

Navigating Food Safety through Internal Auditing in Controlled Environment Agriculture

Indoor Ag-Con will host a CEA Food Safety Pre-Event Workshop in conjunction with Ceres University on March 10, 2024, the day before the March 11-12, 2024 edition opens at Caesars Forum in Las Vegas. Leading up to this session, this column explores key issues and actionable improvements you can implement for your food safety and food quality processes. This month, Dr. Karl Kolb, President of Ceres University and Ceres Certifications, International, shares insights into the invaluable internal audit process.


“At its simplest, internal auditing involves identifying the risks that could keep an organization from achieving its goals, making sure the leaders know about these risks and proactively recommending improvements to reduce these risks.”1

This statement says it all.  The function of internal review, auditing,  inspection or assessment is to assess risks and ensure they are eliminated, controlled, or mitigated. In the food industry we may not be able to eliminate all risks but we can control them or mitigate the effects of a known hazard.

All GFSI audits desire qualification in three things, HACCP, PCQI and Internal Auditing. Every QA team needs at least one person qualified in one of these three subjects. Given the type of factory, other qualifications may be necessary but Internal Auditing will always be the top of the “need to have” list.

There are two questions that seem to rise to the top of the list when this topic is discussed. “What to inspect?” and “How to inspect?”

But before we dive into these two questions let’s discuss to whom the Internal Audit team reports to in the factory.

In all ISO systems and GFSI is another name for ISO, information such as the data and recommendations from audits must go directly to the highest level of management.  This way the decision makers have unfiltered information into those risks that have the potential to harm the organization.

So, what to inspect?

For any plant the HACCP program and its CCPs and supporting CPs are at the top of the inspection list. This is where major harm to the product is caught and hopefully eliminated or at least mitigated. This is the last step in the food safety process yet the most important one. From my analysis, HACCP is the least knowledgeable of all the things in a food safety program by auditors and practitioners alike.  The more time spent understanding how a HACCP functions and the science behind it the better. As HACCP is a capstone requirement in a food safety program built only after prerequisite programs are developed, the HACCP will point the way to deficiencies in the factory.
Other important high-risk items are GMPs, manufacturing controls such as calibrations, environmental testing, reporting and the ever-fabled corrective actions to external and internal audits. Don’t leave out training as we don’t do enough of that day to day.

So, how to inspect? 

There are lots of ways.  Most folks like myself dread the interview.  You ask probing questions of familiar associates (meaning friends) and find out information which may be damaging to their status within the plant.  That is hard, no two ways about it.  We all need to sharpen our interviewing skills and be strong.
But there are other techniques just as important as interviewing which will lead us to answers about the health of our factory. These include reviewing the HACCP program to ensure it is written and executed properly, observations of GMPs and SOPs to ensure they are being followed, review of reports to determine if they are correct, root cause, corrective and preventative actions and how well they are dealing with an audit issue. Internal auditing is not just reviewing pre-requisite programs. It’s the Clouseau of investigations, following your intuition.

See you at the Indoor Ag Con show!  Sign up for the course and become a Certified Internal Auditor.

Footnote: 1.


Dr. Karl Kolb


Karl Kolb, Ph.D., is the founder and President of the High Sierra Group companies, which services more than 10,000 customers with Ceres Certifications, International (ISO 17065 food safety certifying body), HSG/AME Certified Laboratories (17025 food testing laboratories), Ceres University (Accredited, degree granting), High Sierra Chemicals and Epicure Farms.



CEA Food Safety Spotlight: The Benefits Of An Internal Review Audit

Indoor Ag-Con will host a CEA Food Safety Pre-Event Workshop in conjunction with Ceres University on March 10, 2024. Looking ahead to this session, we’ve launched a monthly column to explore key issues and actionable improvements you can implement for your food safety and food quality processes.  This month, Dr. Karl Kolb, President, Ceres University and Ceres Certifications, International, shares how  the  value of an Internal Review audit is priceless to a food organization that works hard to ensure food safety, quality, authenticity, nutrition, food fraud and security programs enforce a rigorous GFSI program.


Virtually every GFSI food safety scheme from PGFS to SQF require the staff to be qualified in Internal Review skills.  Internal Review has become a required certification for those in quality assurance or compliance areas. All GFSI schemes require at least one certified individual in the company. And the internal review team is also trained in these same skills. The skill set of the qualified person is no more than what is required by a HACCP and PCQI qualification.

An internal review audit is a comprehensive evaluation conducted by qualified individuals to assess an organization’s adherence to food safety standards, regulatory requirements, and industry best practices.  It involves a systematic review of processes, procedures and documentation.

Internal review goes by many names.  Internal Audit, Internal Review, Self-Inspection or Audit or a title that indicates a review of internal programs to determine their effectiveness.

An Internal Review is comprised of the following major tenants:

  • In this step an internal auditor or audit team must identify a clear objective of the food safety audit process. For a GFSI scheme this can involve critical prerequisite programs, HACCP, GMP’s or other important processes in the company organization.  These internal audits are spread over the 12 months or 4 quarters of the audit year. Many times, the food safety scheme indicates preferred subjects like HACCP, GMPs or food fraud programs.
  • What is the plan for completing the audits?
  • How are corrective actions and preventative actions taking place?
  • Verification of results.
  • Audit evaluation.

There are many simple techniques to help make the process less arduous. Interviews, KPI analysis, review of written programs or records and observations.  While the audit does cover every part of the food safety program, the manner in which it is approached, conducted and evaluated does not need to be hard to perform.  There are many ways to conduct a meaningful audit.  Start slow and focus on only the critical items building each year to achieve a complete and meaningful program.

How ever the internal audit is approached it is vital to the company’s commitment to food safety.

Karl Kolb, Ph.D., is the founder and President of the High Sierra Group companies, which services more than 10,000 customers with Ceres Certifications, International (ISO 17065 food safety certifying body), HSG/AME Certified Laboratories (17025 food testing laboratories), Ceres University (Accredited, degree granting), High Sierra Chemicals and Epicure Farms.




Learn more about the Indoor Ag-Con 2024 CEA Food Safety Workshop!

What Type of Food Safety Audit Do You Need For Your CEA Operation?

Determining the type of food safety certification your operation needs, or if you even need one, can be confusing and overwhelming when you are new to the process. Where do you start? Begin with your customers!

If you sell directly to consumers, such as fresh-from-the-farm or at farmer’s markets, then your customers likely know you and feel that they have a sense of how you conduct your operation. You have probably already established a trust with your customers and do not need a third-party food safety audit unless you feel that its marketing value justifies the additional expense.

But if you sell to a wholesaler or retailer or other food distributor, they probably have specific requirements about the type of food safety certification they require suppliers to maintain. They may just have the basic requirement of any third-party audit and certification. They may require a specific “scheme” such as GLOBALG.A.P., Primus, SQF, etc.. They may not dictate the certification scheme but require that you hold a Global Food Safety Initiative (GFSI)-benchmarked third-party certification. This means that the type of audit and certification you choose must be GFSI-benchmarked and meet the internationally agreed upon GFSI requirements. There are several options that meet this requirement. This chart lists the most popular types of third-party audits, as well as indicating which types have a GFSI version.

Ceres Certification International Chart 1

In order to be able to sell your products to the major grocery retailers you would need to meet their specific requirements, listed below:

Now that you know what type of certification you need, you are probably wondering where to start the process to get this certification. Do an online search for CBs offering the type of certification you have decided upon. CBs are Certifying Bodies- these companies are licensed by the audit scheme to perform the audits and make the certification decisions. Make a list of a few that offer what you need (they don’t necessarily need to be local since most CBs have auditors for each section of the country, but you do want to choose one headquartered in your main country of operation) and reach out to them. You will quickly get a sense of which CBs will be easy to work with and have experience with your type of operation.

The CB you select should be able to answer your questions to the point where you are comfortable signing a contract for their services, which will be required before the process can proceed. The application you submit to a CB may seem a bit overwhelming the first time, but the CB can help you with any questions. They are trying to get as clear of picture of your operation as they can to ensure that the food safety certification is appropriate for your operation.

Once the application and paperwork is behind you, the CB will send an auditor to your operation to observe your primary agricultural activities. Don’t worry– a good CB will work with you to make sure this happens at a time that is both reasonable and convenient for you. If the auditor finds any issues, called non-conformances, you will have a chance to take measures to address/correct them immediately following the audit. Once that is done, the CB will review your entire file and issue certification or not. (Of course, there are appeal processes in place should you disagree with their decision.)

Your certification will be valid for up to one year, so you will need to go through the process again before that certification expires, but by then you’ll feel like an expert and won’t even break a sweat!


About Karl Kolb, Ph.D.

Karl is the founder and President of the High Sierra Group companies, which services more than 10,000 customers with Ceres Certifications, International (ISO 17065 food safety certifying body), HSG/AME Certified Laboratories (17025 food testing laboratories), Ceres University (Accredited, degree granting), High Sierra Chemicals and Epicure Farms.


About Kellie Worrell

Kellie Worrell has an extensive background in Agriculture and Food Safety. She has written several accurate ag children’s books, including the Virginia Ag In the Classroom Book of the Year. She has served as Food Safety Officer for farms with a wide variety of fresh vegetables, and is currently the GLOBALG.A.P. Scheme Administrator at Ceres Certifications, International.


About Ceres Certifications, International

Ceres Certifications, International (CCI) has been serving the produce industry since 2021.  CCI offers a wide variety of 3rd party food safety certifications, including both GFSI-benchmarked standards and more basic audits. Connect with its experienced Scheme Managers to discuss the extensive CCI offerings, including GLOBALG.A.P. IFA, HPSS, PHA, localg.a.p., a variety of GG add-ons, PrimusGFS, PrimusStandard, SQF, and more.  Learn more.