Audit preparation

The 80% rule: how a compulsory audit becomes a two-year inspection holiday

Since 2019, FSSAI has required an annual third-party food safety audit from food businesses meeting all three of the following: a Central licence, a kind of business of manufacturing, and a product in a notified high-risk category. Miss any one of the three and the mandate does not apply to you. Meet all three and it applies every financial year, whether or not anyone reminds you.

What most plants do not price in is the incentive attached. A business that scores 80% or above in its third-party audit is not required to go through an FSSAI inspection for two years. That turns a recurring compliance cost into something with a measurable return — two years of not rearranging production around an inspector's visit, and two years of not discovering a documentation gap in front of one.

Where plants usually lose the marks

In our experience the shortfall is rarely in the physical plant. It is in evidence: records that exist but are not signed, monitoring logs with gaps nobody reconciled, corrective actions raised and never closed out, supervisors trained but with no certificate on file, and an FSMS manual describing a process the floor stopped following two years ago.

None of that requires capital expenditure to fix. All of it requires somebody to systematically look.

What to do if your audit is this financial year

Work backwards from the audit date. Anything requiring a full cycle of records — an internal audit programme, a mock recall, a management review — needs to have started at least a quarter before, because an auditor is looking for evidence the system has been running, not evidence that it exists on paper.

Source: FSSAI mandatory audit for FBOs, citing the 2019 FSSAI notification and subsequent clarifications.

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