Once again third party audits take heat for an outbreak, in this case, the Listeria outbreak in Jenson Farms Cantaloupes.. In the USA Today, two viewpoints are presented. Both present valid points, but there is more that can be said. Third party food safety audits provide a snapshot evaluation of the food safety system of an organization and give an assessment of whether that facility is following that food safety system. One important limitation is that audits, as currently completed, are not as good at determining the validity of that system, in other words, how well that system is actually working to make safe food. An astute auditor can see signs that the plan is valid through results of pathogen testing, through the process parameters that are set up, but there are factors that limit this.
- Auditors often cover a broad range of facilities and process types (even within the same commodity) and so it is difficult to have an in depth understanding of every process in every facility an auditor visits. They will not have the vast knowledge of a given pathogen as compared to a PhD who has studied that pathogen for years.
- Audits are often one day in duration, so there is little time to get into the nuts and bolts of the process. Audits will look at the broad systems that are in place and make sure they are being followed (such as GMP’s, supplier control, pest control, HACCP), but to look at the validity of a process can take days, especially when there is the lack of support documentation such as pathogen testing.
- In most cases, auditors are not conducting microbiological analysis of the environment or of the finished product. They may look at results that are on file, but they themselves are not swabbing surfaces or pulling product from the end of the line and sending to a qualified laboratory. As was seen in the PCA case, a company may only show select results from a less reputable laboratory. So to what degree can an auditor, in a day or so, evaluate the laboratory being used, the methods that laboratory is using, and the sampling scheme used by the plant?
- Auditors will count, in part, that the facility actually knows what it is doing. If a facility has been processing cantaloupes for years, it is easy to make the assumption they must have some clue of what they are doing. They can question why a change was made, in this case the change in process, but to make a call on the safety of that change is more difficult.
- Companies being audited do want to pass the audit. Their business depends on it. When they hire an auditor, it is less likely they will put themselves in a position to fail….and that may mean hiring someone they know who will not put them through the ringer. Indeed, this a conflict of interest. But this practice of having the supplier pay for their own audit was started years ago by the purchasing companies requiring the audits. To get out of paying for audits of every supplier, they had the idea to make the supplier pay for the audit. Sure, the customer company provides a list of audit firms or auditors from which the supplier can choose, but still, the supplier still hires that person.
Because of these limitations associated with third party audits, they are not a guarantee of product safety. Rather, they are just a part of the entire food safety system that a company uses to ensure safe food. If a company uses the fact that they passed an audit as sole reason for why they believe their food is safe, then that company probably does not have true food safety systems in place. The goal of the audit for the food company is to assess their systems and provide feedback on where improvement is needed. Each aspect of the audit is there for a reason, so food companies need to embrace the intent of the requirement, not just to throw something in place to pass the audit.
While there has been a ratcheting up of requirements through GFSI (SQF and BRC) on both what is required in audits and what is required for someone to be a qualified auditor, some of these issues still exist. Even with government based inspection, there are similar shortcomings. Audits are an important part of our food safety system, whether internal, second party, third party , or government, but the responsibility for food safety ultimately falls on the company producing the food. Food companies must use these audits as guideposts for continual improvement. Employees, managers, and just as importantly, executive management must thoroughly understand their process and product. They must challenge themselves, with the help of auditors, to ensure their food safety system has addressed all possible food safety hazards.
by Martin Bucknavage 12/1/12
