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Food Safety Auditors on Patrol

With over a million food operations in the U.S. of all types, the arena of food safety is vast and protecting it is a tough assignment.

Countless tons of foods travel through interstate commerce and internationally daily. The complicated route that most foods take from farm to plate is remarkable and catching the random contaminates as they filter through is challenging. Keeping up with food safety requires a broad background, not just in the microbiological, chemical and physical hazards ever present, but a firm understanding of the supply chain and the risk passed from step to step.

The first duty of a food safety auditor is to detect non-conformances with standards. The standards are themselves complex, reflecting the industry, and its wide risk of exposures. Not to mention that the standards can be imperfect by themselves; it takes a knowledgeable person to interpret them in every situation. Scientific justification exists for most standards, but standards may vary dependent on the scope of the audit, the operation, commodity, regulation and many other factors.

Technical skill is needed, along with the ability to think on one’s feet, focus and determination. A sense of where trouble might be hidden sometimes comes with experience. In addition to the skills needed, an auditor must constantly stay tuned-in to the latest developments; for example, a food safety auditor not realizing we have gaps in knowledge of produce safety would be truly in the dark.

What the Jensen-Frontera Salmonella outbreak showed me, as an auditor, was that my thinking has to change, while I am still left with some unanswered questions.

If a failing score instead of a superior score was issued, would this have stopped the Jensen brothers from selling their products and prevented the outbreak? Does industry expect the audit process to provide a high number to satisfy some buyer, a low number to rule out a supplier, or is the expectation to find problems and to make diligent corrections?  (I believe auditors providing high numbers are a bit more popular, but the ones finding problems much more effective!)

And now the really tough questions: are the Jensens guilty of not knowing that conditions in their plant could poison the nation? And is the auditor who didn’t “see the Listeria problem coming” someone aiding and abetting … an accomplice?

Unfortunately, I don’t have good answers to these questions. Maybe the legal process will sort it out, but what a terrible way to learn.

The audit is a risk assessment whereby perspectives change with the methods used. Seeing the facility or operation through the lens of the audit template questions gives one type of perspective, performing a risk assessment based on conditions and their interrelationship might be another (of course, somehow they should coincide).

In retrospect, we can see now that the melon-packing-process hazards were connected in time, temperature and moisture, and further connected with the growth of Listeria on cantaloupes. Audits, the way they are currently conducted, are not likely to detect subtle relationships like these.

Business relations as well as practicality affect the scope of the audit. The audit scope is very important to determine, for the auditor is more or less bound by the constraints.

Food safety auditing is a big business and growing rapidly. We should accept that in the business world relationships will develop. The human element will always be with us, but food safety auditors these days are carrying a lot of weight and need to use their growing power wisely … not to penalize companies, but to improve the situation. It is not our role to police the industry, but we can feel like a soldier on patrol sometimes in our work and sometimes feel like we have come under fire.

Protecting the food people eat is a shared responsibility, one way too big for even an army of auditors.

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Roy Costa, a registered professional sanitarian with 30 years of environmental heath practice in the academic, government and private sectors, is the founder and owner of the consulting firm Environ Health Associates and author of the Food Safety & Environmental Health Blog.

© Food Safety News
  • Well-thought out article, Roy. Here’s an additional thought regarding audits: An audit is a snap-shot in time–what is clean today may not be clean tomorrow.
    Unless a facility is willing to take food safety seriously every day and elevate the respect of QA Departments, the continuing saga of food safety will continue to haunt us.
    And of course, the more we continue with interest in food safety, the more we learn. Listeria was only brought to the forefront of food safety issues when? (Not when it was discovered, but when it became evident in food safety issues and that flies in drains transferred it)?
    One thing is certain, food safety issues will continue, especially since food production/shipping has gone global.

  • Roy, I agree that private auditing is very challenging and complicated. I own a restaurant auditing company and work with owners and managers eveyday. Owners pay me to find as many violations as I can find which can sometimes cause the manager on duty much heart ache.
    Some owners will deduct part of a manager’s bonus based on my inspection scores. it’s very important that I’m fair and consistent every time, especially since someone’s income is on the line. I often have to defend my inspections to managers who refuse to take responsibility for bad performance.
    Despite the confrontations that we may encounter from operators about tough inspections, as auditors, we have an obligation to document every food safety deficiency we witness for the owners, managers, and customers.

  • It is not the role of the food auditor to consult to the food business – this is where conflict of interest comes in. The role of the food auditor is to assess compliance against the selected and agreed audit criteria (or set of rules).
    Working as a certified food safety auditor for the past 18 years, I still go into every audit with the notion of “if I had to defend my actions in a court of law tomorrow – could I?”.
    This motivates me to make sure my collected evidence is strong, my recording and reporting is thorough and I don’t pass opinion on what I think would be a good idea for the business. If food businesses want opinion from me, they can hire me as a consultant.
    I also greatly appreciate that an audit is only a snap-shot in time and a food auditor cannot possibly look at everything due to time constraints and audit scope.
    As for the hazard of listeria not being picked up in this cantaloupe outbreak, basic risk assessment or hazard analysis is one of the most poorly done areas in the food industry. HACCP requires us to identify everything that can wrong with food (identify hazards), not just three or four issues at each step of the process. Therefore, the one thing that should be a priority in every food audit (standard dependent) is for the auditor to review the hazard risk assessment / hazard analysis that the company has documented.
    Maybe if this had been done correctly by the food company and assessed correctly by the food auditor, listeria would have been identified as a probable risk to cantaloupe and this particular outbreak could have been avoided.

  • Roy, I agree that private auditing is very challenging and complicated. I own a restaurant auditing company and work with owners and managers eveyday. Owners pay me to find as many violations as I can find which can sometimes cause the manager on duty much heart ache.
    Some owners will deduct part of a manager’s bonus based on my inspection scores. it’s very important that I’m fair and consistent every time, especially since someone’s income is on the line. I often have to defend my inspections to managers who refuse to take responsibility for bad performance.
    Despite the confrontations that we may encounter from operators about tough inspections, as auditors, we have an obligation to document every food safety deficiency we witness for the owners, managers, and customers.

  • Given that the audit report listed 3 majors and non compliance with FDA guidance, is this a problem with the audit?
    Could the standard that was actually used be at fault? Would something along the lines of a GFSI standard audit have caught the problem?

  • In Jensen-Frontera’s case, were they cleaning the affected equipment? Had there even been a SOP for cleaning it? Audits need to take an in-depth look at the management of the facility they are inspecting. Can the facility show and produce continuous, verifiable records indicating that the facility is taking care of daily basic requirements such as sanitation, maintenance, and pest control. PCA showed us about circumventing audits. If a facility has to do a major clean-up before an audit they also are not the type of company to use barcoding to verify inspections and be able to show a regular schedule to inspections and pest control. They probably also can’t show that sanitation and maintenance issues have consistently been reported and that corrective actions were taken to remedy those issues.

  • Amanda Evans writes: “I still go into every audit with the notion of “if I had to defend my actions in a court of law tomorrow – could I?”.
    I agree with this. At the same time, who are these folks supposed to turn to for answers? The auditor is often the most knowlegdable about the standard and conformance vs non conformance.
    The audit process is instructional as well as educational, especially for the well prepared. I agree that role conflict can develop, but we should write what we see, anyway.
    The danger is to be coopted or mislead by our own thinking that everything is ok because the auditee “is learning”. This is also the human element, we can call it “observational bias”.
    Amanda continues, “As for the hazard of listeria not being picked up in this cantaloupe outbreak, basic risk assessment or hazard analysis is one of the most poorly done areas in the food industry”.
    True. Both risk assessment and hazard analysis are arts, identifying the pathways for infection and their intersect with the process is challenging. The bugs know what they are doing and sometime we cannot tell where they will emerge; regardless, this is a fault in our knowledge and this is what got us in trouble at Jensen, we shouldn’t repeat this.
    Want to come to my HACCP class?
    Dennis Keith writes:
    “Despite the confrontations that we may encounter from operators about tough inspections, as auditors, we have an obligation to document every food safety deficiency we witness for the owners, managers, and customers”.
    I believe we will see better auditors enter the workforce as government downsizes its public health infrastruture. I am biased, but feel like ex regulators are better at sticking to thier guns when it comes to confrontation and resistance.
    Bruce Achterman writes:
    “If a facility has to do a major clean-up before an audit they also are not the type of company to use barcoding to verify inspections and be able to show a regular schedule to inspections and pest control”.
    That is the intersection between the audit template questions and the hazard analysis. If you properly execute them both you should be able to do an environmental risk assessment, and a management system review. These together are in the GFSI stanhdard. This process creates a score. But the problem is the score can be skewed by many other positive even with some big negatives.
    This is why I say the way we do audits has to change.
    If I didn’t get to everyone’s comments, let me say I appreciate them, and there is some very good thinking occurring.
    By the way, we have FDA coming to our Florida Environmental Health Association meeting in Orlando to talk about the impacts of the FSMA, we will be in Orlando in early May.
    Write me for details.
    Thanks much.