How to Prepare for an MPI Audit: Guide for NZ Food Manufacturers and Processors

If you run a food manufacturing operation in New Zealand under a Risk Management Programme, you already know the MPI verification visit is coming. The question is whether your site is genuinely ready for it, or whether you’re going to spend the week before scrambling through filing cabinets.

This guide covers what MPI verifiers actually focus on during a manufacturing audit, how to prepare systematically, and how to handle findings if they come up. It’s written from the perspective of someone who has been on the receiving end of these visits and learned the hard way what matters.

What MPI Actually Looks For

Forget the generic compliance checklist for a moment. Here’s what happens in practice when a verifier walks through your plant.

Record completeness is the number one issue. Not whether your HACCP plan exists (it does, or you wouldn’t have an RMP), but whether your daily records actually prove you’re following it. Verifiers look for gaps. A temperature log that’s filled in for Monday through Wednesday, then picks up again the following Monday, tells them nobody was monitoring for four days. Or that someone was monitoring but not recording. Either way, it’s a finding.

Corrective action follow-through matters more than the initial log. Every site logs corrective actions. Not every site closes them out properly. The verifier wants to see that when something went wrong, you identified what happened, fixed it, and then verified it was actually resolved. A corrective action that says “fridge temp high - adjusted thermostat” with no follow-up temperature reading to confirm the fix worked is incomplete.

CCP monitoring consistency gets checked carefully. If your RMP says you check metal detector performance every two hours, they’ll look for two-hourly entries. If your CCP log shows checks at 6am, 8am, 10am, and then nothing until 3pm, that’s a gap. They’re not looking for perfect numbers every time. They’re looking for evidence that monitoring is happening at the frequency you committed to.

Traceability is tested, not just reviewed. Expect the verifier to pick a finished product and ask you to trace it back through your records: raw materials, batch records, CCP logs, supplier approvals. They may also go the other direction, starting with an incoming raw material and asking you to show which finished products it ended up in. If this takes you 45 minutes of digging through binders, that tells them something about your system.

Staff competency comes through in conversations. The verifier will talk to operators on the floor. They’re not expecting everyone to recite the HACCP plan, but they expect your CCP operators to explain what they’re monitoring, what the critical limits are, and what they’d do if a reading fell outside those limits. If an operator doesn’t know, that points to a training gap.

Verification activities need to be current. Your RMP requires you to conduct internal audits and verification checks. If your last internal audit was 14 months ago, or you can’t produce any evidence of verification activities, that’s a finding before the verifier has even looked at anything else.

The 30-Day Prep Checklist

If you know your verification visit is roughly four weeks out, here’s how to use that time well. Don’t try to do everything in the last three days.

Week 4 (30 days out)

Start with records. Pull your CCP monitoring logs, temperature records, cleaning schedules, and corrective action logs from the last 12 months. Look for gaps. Any day without a record needs to be accounted for. If you find missing entries, you can’t fabricate them now, but you can document that a gap was identified and what you’ve done to prevent it happening again.

Run a mock traceability exercise. Pick a random product from your dispatch records and trace it backwards through production. Time yourself. If it takes more than an hour, your system needs work.

Check calibration records for all monitoring equipment: thermometers, metal detectors, scales, pH meters. If anything is overdue for calibration, get it sorted now.

Week 3 (21 days out)

Review every open corrective action. If something was raised six months ago and never closed out, either close it properly or document why it’s still open with a realistic timeline. Verifiers understand that some fixes take time, but they need to see progress and documentation.

Pull training records for every staff member. Check for expired certifications or new employees who haven’t completed their food safety training. If anyone’s training is out of date, schedule it this week, not next.

Week 2 (14 days out)

Conduct a full internal audit against your RMP. Walk through every section: prerequisite programmes, CCP monitoring, corrective actions, supplier approval, recall procedures. Document your findings honestly. If you find issues, that’s actually a good thing. It shows the verifier that your internal audit process works and catches problems.

Write up any findings from the internal audit with corrective actions and timelines. Start closing out anything you can.

Week 1 (7 days out)

Organise your records so they’re accessible. If your monitoring logs are in one binder, corrective actions in another, and training records in a desk drawer, pull them together. The verifier shouldn’t have to wait while you locate things.

Prepare a brief compliance summary: when your last internal audit was conducted, the status of any outstanding corrective actions, recent calibration dates, and your latest traceability test result. Having this ready shows you’re on top of your programme.

Brief your team. Let everyone know the visit is coming. Remind CCP operators what they’re monitoring and why. Make sure the person who manages records is available on the day, not on leave.

Day of the Audit

Have all records accessible and organised. If your QC manager is the only person who knows where records are kept, make sure they’re on site. Unlock filing cabinets. Log into any digital systems in advance.

Know where everything is before the verifier asks. The worst impression you can make is spending 20 minutes searching for a document while the verifier waits.

Stay calm. A verification visit is a normal part of operating under an RMP. It’s not adversarial.

The 5 Most Common Audit Findings (and How to Avoid Them)

1. Gaps in Temperature Monitoring Logs

What it looks like: Missing entries on specific days. Logs that show readings for weekdays but nothing on weekends. Entries that say “OK” or have a tick mark instead of an actual temperature value.

Why it happens: Staff forget, or they check the temperature but don’t write it down until later (and then forget). Weekend and night shifts are the biggest gaps. Sometimes the log book is in an inconvenient location, so people skip it when they’re busy.

How to prevent it: Make the recording process as easy as possible. Place log sheets right next to the equipment being monitored. Build temperature checks into shift handover routines so the gap between shifts is covered. Review logs weekly, not monthly, so you catch gaps while they’re fresh enough to address.

2. Corrective Actions Not Properly Closed Out

What it looks like: A corrective action log that says “fridge running at 7C - adjusted thermostat” with no follow-up entry confirming the fridge returned to the correct range. Or a corrective action raised three months ago that’s still marked as “in progress” with no updates.

Why it happens: The immediate fix gets done, but nobody circles back to document that it worked. In busy plants, the person who raises the corrective action isn’t always the person responsible for closing it out, and things fall through the cracks.

How to prevent it: Every corrective action needs three things documented: the problem, the fix, and the verification that the fix worked. Assign a specific person responsible for closing out each action. Review open corrective actions weekly.

3. Training Records Not Current

What it looks like: A new employee started two months ago but has no documented food safety training. Or a long-term employee’s training records are five years old with no evidence of refresher training. Training records exist but don’t specify what was actually covered.

Why it happens: Training happens informally (“go shadow Dave for a day”) but never gets documented. High staff turnover means training documentation falls behind. Refresher training gets deprioritised because everyone is focused on production.

How to prevent it: Build training documentation into your induction process. No one starts on a CCP without signed-off training records. Schedule annual refresher training and put it in the calendar so it doesn’t get bumped. Keep a training matrix showing who is trained on what and when it’s due for renewal.

4. Supplier Approval Documentation Missing or Expired

What it looks like: You’re using a new ingredient supplier, but there’s no approved supplier assessment on file. Or your supplier approval records are from 2021 and haven’t been reviewed since.

Why it happens: Purchasing decisions happen fast. Production needs a raw material, someone sources it, and the supplier approval process gets skipped or deferred. Existing supplier reviews get pushed back because “they’ve been fine for years.”

How to prevent it: Make supplier approval a prerequisite for any new raw material entering the plant. No approved supplier record, no purchase order. Review your approved supplier list annually and document the review even if nothing changes. Keep copies of supplier food safety certificates and track their expiry dates.

5. Internal Audit Not Conducted Within the Required Timeframe

What it looks like: Your RMP says you’ll conduct an internal audit annually, but the last one was 16 months ago. Or the internal audit was done but the report is a single page that says “all satisfactory” with no detail.

Why it happens: Internal audits take time, and production always feels more urgent. Sometimes the person responsible for internal audits leaves and no one picks it up. Other times the audit gets done superficially because nobody wants to create more work for themselves by finding issues.

How to prevent it: Schedule the internal audit in advance and treat it like any other mandatory activity. Use a proper checklist based on your RMP sections. Document findings honestly. A thorough internal audit that finds three minor issues looks far better to a verifier than a superficial one that claims perfection.

What to Do During the Audit

Assign one person to accompany the verifier. Usually this is the QC manager or site manager. This person should know where records are, understand the RMP, and be able to answer questions clearly. Don’t have five people trailing behind the verifier.

Answer questions directly. If the verifier asks when the metal detector was last calibrated, tell them the date and show them the record. Don’t launch into a detailed explanation of your entire calibration programme unless they ask.

Don’t volunteer extra information. This is not the time to mention that side project you’ve been meaning to get around to, or the procedure you know needs updating. Answer what’s asked. Be helpful and cooperative, but stay focused.

If you can’t find a record, say so honestly. “I can’t locate that right now, but I’ll find it and provide it to you” is much better than making excuses or pretending the record exists somewhere. Verifiers can tell the difference between a genuine filing issue and a record that was never created.

Take notes on everything the verifier flags. Even informal comments or suggestions. These notes will be valuable when you’re reviewing the visit afterwards and planning any follow-up actions.

Ask for clarification on any findings you don’t understand. If the verifier raises a non-conformance and you’re not clear on what specifically they expect, ask. It’s much easier to get clarity in the moment than to guess at what they meant after they’ve left.

What to Do After a Finding

Getting a Corrective Action Request (CAR) is not the end of the world. It means something needs fixing, and you have a defined timeline to fix it. Here’s how to handle it properly.

Don’t panic, but don’t ignore it either. You have a deadline. Mark it in the calendar and work backwards from there.

Identify the root cause, not just the symptom. If the finding is “gaps in temperature monitoring,” the root cause isn’t “staff forgot.” The root cause might be that your monitoring schedule doesn’t account for shift changes, or that log sheets run out and nobody is responsible for replacing them. Dig into why the gap exists.

Implement the corrective action and document it thoroughly. What did you change? When? Who is responsible? Include evidence: photos of new log sheet locations, updated procedures, signed training records, whatever demonstrates the fix.

Consider what systemic change prevents the issue from recurring. A corrective action that only fixes the specific instance will get flagged again next time. If temperature logs had gaps because staff weren’t trained on the requirement, training one person doesn’t fix it. Updating your induction programme so every new starter learns the requirement does.

Prepare for the follow-up visit. If you’ve received a CAR, your next verification visit will likely come sooner. The verifier will specifically check that the corrective action was implemented and is working. Have your evidence ready and organised before they arrive.

Remember that your audit frequency increases after a finding. A business on a 12-month cycle can drop to 9, 6, or even 3 months. Each additional visit costs $230.50 per hour. Getting it right the first time is significantly cheaper than repeated follow-ups.

Digital vs Paper for Audit Readiness

The difference between digital and paper record-keeping becomes most obvious in the weeks before an audit.

With paper, preparation means physically locating every binder, folder, and log sheet. It means flipping through hundreds of pages to check for gaps. It means hoping that the corrective action from last June is actually in the right folder and not sitting on someone’s desk. Many QC managers spend two to three full days just organising records before a verification visit.

With a digital system, the records are already organised. You can pull up any date range, filter by record type, and identify gaps in seconds rather than hours. When the verifier asks for your last six months of CCP monitoring data, you’re not searching through binders. You’re running a report.

Traceability exercises are where the gap is biggest. Paper-based traceability means manually cross-referencing batch records, supplier invoices, CCP logs, and dispatch records. It’s doable, but it’s slow and error-prone. A digital system links those records automatically.

If you’re spending days preparing records for every audit, it’s worth considering whether a digital approach would save you time and reduce risk. The Custom FCP / RMP App is built specifically for manufacturing QC teams who need their records organised, searchable, and audit-ready without the filing cabinet archaeology. But whatever system you use, the principle is the same: your records should work for you, not against you, when the verifier walks through the door.