An article in the lawyer-sponsored report was reprinted throughout the mass media - Ukraine – Audit finds fruit contamination may go undetected in Ukraine – Microbial Contamination. Having spent time there, I was curious about this report as I knew that Ukrainian berries were doing quite well in international trade. In reviewing this report from the EU, I found that it was a virtual audit. So product from a whole country was getting slammed by people who did not actually visit any farms, but evaluated State controls. As it is here for exporting or importing commodities, the quality and safety standards are between the purchaser and the supplier. For those companies that export, they have to meet their purchaser's requirements through enacting required policies and procedures. In the US, we require that companies, not the countries, follow FDA (FSMA) or USDA regulations.
So is this audit accurate, or is it perhaps a knock against some exporting country's product? Not able to speculate on that, but the thing for us to note is the shortcomings of the virtual audit. We recently heard from a number of agencies and associations that they are in favor of the virtual audit. Easy to do for both the auditor and the auditee, what is not to be liked?
While the virtual audit can be better than no audit at all, and can be adequate when travel is limited, such as the case during the COVID pandemic. It may be completely adequate when there is only paperwork to check, such as the case with a FSVP audit. However, a virtual audit can never provide the same information that an actual onsite audit does.
For one, an onsite audit forces that face-to-face communication where it harder to mislead the other. People are more apt to be honest regarding the findings (not always of course) and recommendations and conversely, the proposed course of corrective action. Sure there have been rare occasions of when a company is blindsided by the outcome of an audit, but hopefully that comes in the close-out when the auditors are sitting right in front of you.
An onsite audit gets to appraise the conditions as they are (on that day). And for the auditor, they can get a better understanding of those conditions in context of the product being manufactured. A seafood plant is much different than a diary.
They can read the procedures and then go see those procedures in practice. They can see the process beyond what is written in a flow diagram. Auditors get to speak to others beyond those on the other side of the screen, including the real people actually operating the equipment or taking the measurements.
Few of us enjoy the onside audit, but it is a more honest way of doing business. In today's world where the media can spin audit findings far and wide, we want to have the best shot at making the right impression.
