Food Plant GMP Internal Audit Checklist Based on 21 CFR 117 Subpart B
Current Good Manufacturing Practice is the base layer under every food safety plan. This checklist follows the structure of 21 CFR Part 117 Subpart B so an internal auditor can walk the plant and mark findings area by area.
0 of 38 items complete
17 critical items still open - these are the highest-risk gaps.
Personnel and hygiene
Plant, grounds and facility
Equipment and utensils
Sanitation and allergen control
Processes, controls and warehousing
Mark each item. Any critical item that is not met needs a documented corrective action before the next production run. Track the percent of items met per area and trend it by audit.
Track findings to closure
Optional review of how audit findings and CAPA can flow into your ERP or quality system.
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How to run the audit
Print the checklist or work through it on a tablet while walking the plant in the order product moves, from receiving to dispatch. For each item mark met, not met or not applicable, and take a photo of every finding. Critical items are those where a failure can lead directly to contamination of food, so any miss should get a documented corrective action and an owner. Export the completed list to PDF or Excel for the audit file.
- Audit all shifts over time, not only day shift
- Interview operators as well as checking documents
- Trend findings by area to see where controls decay
Structure behind the checklist
Subpart B of Part 117 covers personnel, plant and grounds, sanitary operations, sanitary facilities and controls, equipment and utensils, processes and controls, and warehousing and distribution. This checklist groups the same ideas into five audit areas. It is a practical aid, not a copy of the regulation, so always read the current rule and any state or customer requirements that apply to you.
Reading the results
A 95 percent score can still hide a critical failure, so look at critical items first. Then rank open findings by risk: likelihood of hazard reaching food times severity. Closing three drain and handwash issues usually reduces more risk than closing ten housekeeping items. Repeat findings across two audits point to a system problem rather than a one-off lapse.
Common mistakes
Auditing only when the plant is clean, accepting a signed log without checking the actual condition, ignoring contractor and visitor practices, and failing to verify that corrective actions actually closed the gap. A finding that is closed on paper but reappears in the next audit is still open.
Frequently Asked Questions
Which rule covers GMP for food plants in the US?
21 CFR Part 117 Subpart B contains the current good manufacturing practice requirements for human food. Some operations are subject to modified requirements or exemptions, so confirm what applies to your facility.
How often should GMP audits be done?
Many plants do a full internal audit at least quarterly with weekly or daily walk-throughs of key areas. Your food safety plan and your certification scheme may set the minimum frequency.
Is this enough for a GFSI audit?
No. GFSI-benchmarked schemes such as SQF, BRCGS and FSSC 22000 have their own requirements. Use this as a GMP baseline and map findings to the scheme you certify against.
What is a critical item?
An item where non-conformance can lead directly to food contamination or loss of control of a hazard, such as handwash facilities, allergen changeover and calibrated monitoring devices.
Netray can help move audit findings and corrective actions into your ERP or quality system. The checklist is free to use as is.
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