This discussion was prompted by a March 5, 2009, article in the New York Times entitled “The Trouble with Food Safety Audits,” written by Michael Moss and Andrew Martin. In my opinion, the article contained some errors, but it clearly highlighted problems inherent with third-party audits. I have written about my concerns with third- party audits in past issues, and though I conduct audits as part of my services to the food industry, I am well aware of the problems within the system.
Here are some of the key issues mentioned in the Times piece and how we, as an industry, can address them.
Expertise in the Field, Processes or Product Being Audited – The Times reported that one of the auditors sent to the PCA plant was “an expert in fresh produce, who was not aware that peanuts were susceptible to salmonella.” It is imperative that auditors understand the products and processes they audit in addition to understanding the audit process itself. Firms around the world have been recognized as having the expertise to conduct audits to certify that a company meets the requirements of the International Organization for Standardization (ISO). In the food industry, especially in Europe, Asia and Africa, ISO certification is an important part of doing business. Yet, I have been in many food plants with ISO certification for quality (ISO 9001), food safety (ISO 22000) and environmental concerns (ISO 14000) that received certification from auditors who were experts in car batteries and electric light bulbs.
Auditing is a Business– According to the Times piece, “auditors are also usually paid by the food plants they inspect, which some experts said could deter them from cracking down.” I can’t verify that some auditors or audits are more lenient because they want to keep a plant’s business. However, I can say that I have been in plants that proudly showed me past audits and bragged about how well they did. After I finished my work, I vowed never to eat their products due to the plant’s conditions. The auditor is not providing the client with good service if he or she fails to perform a rigorous check.
Follow-up– “Even when audits do turn up problems, it is up to the discretion of food companies to fix them.” Unfortunately, when most auditors complete an audit, their job is done. One element that should be part of all audits is corrective and preventive actions. If the plant has no history of follow-up, that should be on record for the auditor. In the case of PCA, private audits uncovered a number of problems at the processing plant. However, it is not apparent that the plant took rapid action to eliminate the cause of these problems.
One of the points that emerged in the advisory board chat was the need to get away from scores on audits. I had an excellent audit teacher back in the early 1980s named Allen Katsuyama. He designed an audit format with three columns: Observation, Recommended Action(s) and Corrective Actions. Ideally, the completed form would be returned to the different groups within the company with instructions to fix the problems. Unfortunately, one of the most common questions asked of auditors is “What do I need to pass?” Passing is not the issue. Ensuring safety is. It does not take a major sanitation issue to create a problem.
I encourage food safety managers and others concerned to take a look at the Times article and start thinking about solutions. This issue will elicit a great deal of discussion in the days to come, so be prepared to get involved.
