January 24, 2017
The word “audit” strikes fear into most everyone, since it usually is preceded by “IRS” and followed up with the anxiety of combing through piles of receipts and tax papers.
One kind of audit that shouldn’t cause people to wince is the Common Swine Industry Audit, which has evolved out of consumers’ desire for assurance that the meat they are eating has been raised under established standards for swine care and preharvest pork safety.
As of yet, a farm audit is not mandatory within the swine industry, although some retailers and packers are requiring an audit of their suppliers — hog producers. A number of auditors who recently completed CSIA training offered through the Professional Animal Auditor Certification Organization Inc. offer up the areas where producers fall short in getting credit during an audit.
It has long been said that farmers need to treat their farm as if it’s a business, rather than a lifestyle. As with any business, keeping detailed records helps paint the picture of a successful farm. CSIA auditors will be asking to see detailed records, but not the types of records that a tax auditor may be requesting.
Producers should have on hand records such as daily observation of the pigs and compliant medication and treatment records, as well as a written record of the periodic testing of emergency backup equipment. Daily observation records need to be kept for 12 months and aren’t considered complete if they are not initialed by the caregiver.
Compliant medication and treatment records also need to be kept for 12 months, but these records go deeper into detail than the observation records. In addition to initials of the person administering the medication, other information required under the CSIA includes date, animal or group ID, drug dose, route and withdrawal time.
Producers know how to raise hogs, and they know the procedures that they follow to get the job done. However, under the guidelines of the CSIA, producers need to have written standard operating procedures that are readily accessible.
The main objective of proper pig care is for animals to be handled appropriately for their age as recommended in PQA Plus, and this needs to be spelled out in a site’s SOP. Pigs should be moved at their normal walking pace, aggressive handling must be avoided as it can lead to injured or stressed pigs. Examples of aggressive handling include improper use of electric prods; excessive loud noises and yelling; moving pigs too fast; moving too many pigs in a group; overcrowding pigs in chutes, ramps and alleyways; and rough physical contact.
Pig caretakers handle pigs every day, but an auditor will request to see a written SOP to substantiate that they know how to handle the animals under their care. There should not be discrepancies between what is written in records or SOPs and what the caretakers are able to demonstrate or articulate.
In that same vein, each hog facility is required by the audit to have a written zero tolerance policy for willful acts of abuse toward the pigs, as well as documentation of how an employee can report animal abuse.
Another SOP producers will need to show an auditor is an Euthanasia Action Plan, which should be consistent with current guidelines established by the American Association of Swine Veterinarians for each phase of production.
Within the EAP, the primary and secondary choices for euthanasia need to be defined, and euthanasia must be performed in a timely manner, defined as:
■ pigs that have no prospect for improvement or that are not responding to care and treatment after two days of intensive care unless otherwise recommended by a veterinarian. The caretaker’s past experiences with similar conditions should be used to make informed decisions about the likelihood of recovery.
■ severely injured or non-ambulatory pigs with the inability to recover. An animal is considered non-ambulatory if it cannot get up or if it can stand with support but is unable to bear weight on two of its legs.
■ any pig that is non-ambulatory with a body condition score of 1 (on a 4-point scale).
■ pigs with hernias that are perforated or with large hernias that touch the ground while standing and cause difficulty walking and are ulcerated.
■ any pig with an untreated prolapse that has become necrotic or any pig with a uterine prolapse.
Written SOPs are required for certain practices being performed on the hog farm, but maybe more importantly, the caretaker accompanying the auditor on the barn walkthrough should be able to articulate what is in the SOP, beyond simply reading it.
Not all producers are fluent in writing SOPs, but the National Pork Board offers help with examples of SOPs on its website under the Common Swine Industry Audit. Producers cannot simply print out an NPB sample SOP and adopt it as their own; producers can use the SOP templates, with personalization and specifics to the individual farms.
3. Improper storage and records of medications
Medication records provide documentation of the proper use of the drug, and medication and treatment records should be kept for 12 months after the animal has been treated, or as long as the farm has been operating if less than one year.
Most animal health products require storage in a clean, dry and dark location. Caretakers should follow the medication label for proper storage, or be able to produce documentation if a veterinarian has prescribed off-label storage. An example is if a medication label does not call for refrigeration, but a veterinarian suggests such storage. Medications should be stored in the original container, and must not be past the expiration date.
In connection with medications, auditors will also check to see that the proper size and length of needles are being used. Needles that are 16 gauge or larger in size (lower number) must be highly detectable. This does not apply to sites using needle-free technologies.
Proper disposal of sharps needs to be followed according to state medical waste regulations to prevent environmental contamination and injury to humans who may come in contact with the spent sharps. Sharps should be placed in a rigid puncture-resistant container immediately after use. Glass containers are not acceptable, and the container should prevent the penetration of the needle both on the farm and throughout transport to final disposal. Sharp disposal containers must be clearly labeled as containing sharps, and according to each state’s regulations. When the container is full of sharps, the cap or lid must be securely tightened and may be sealed with heavy tape.
Making the audit go smoothly
Of course, the goal is for a farm site to pass the audit, and though it has no bearing on the outcome of an audit, auditors offer tips for producers to make the process go as smoothly as possible.
1. Be available to meet with auditor upon arrival
Auditors should schedule an audit in advance to ensure availability of the farm manager or main caretaker. An opening interview should take place, probably in the office, and a plan for the day will be established. It is suggested that producers know their animal inventory as closely as possible. For example, on a sow farm that includes every barn and room. If you will have newly weaned pigs held in a group waiting to be loaded out, the auditor will need to know those details as well.
It is also recommended that producers have all SOPs, daily health logs, staff training records and other pertinent records compiled in one location (i.e., break room/conference room) if possible, or clustered in two or three locations. If such records are normally stored at an alternate location, say the main office, it would be beneficial to have copies at the site being audited, making sure to adhere to biosecurity protocol.
2. Know what to expect
Read the audit tool available on the National Pork Board website well ahead of time. None of the questions asked by auditors should be a surprise. Preparation should begin as soon as the audit appointment has been scheduled, and it is recommended that all caretakers working on the site also read the audit tool.
3. Ask your own questions
Yes, during the audit, the auditors will be asking most of the questions. But beforehand, confirm with the auditor that all items on the auditor’s checklist are ready for the on-site assessment. This checklist should be provided ahead of time by the auditor. Don’t hesitate to ask any questions ahead of time.
Anything that can be done to make the process and on-site assessment go as smoothly as possible is beneficial to both the producer and the auditor.
Producers should not look at the auditor as an enemy. Auditors should be seen as someone who can provide benchmarking that producers can use for the continual improvement of their farm and the entire swine industry.
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