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Food Safety Audits: Do We Have the System Backward?

Opinion

(This article by Bob Whitaker, Ph.D., was originally posted here, and is reposted with his permission.)

I was at a grower training event on the Food Safety Modernization Act (FSMA) awhile back, and it was a great event with impressive participation from the growers. The speakers were wonderful, and the content was carefully prepared. Over the past three years, I have probably been involved in 20 different food safety education programs aimed at helping growers build effective food safety programs. In some ways, they have been a great experience and, based on feedback from the attendees, I know they have made a difference to growers and given them the information to start them down the path to building successful food safety programs. However, no matter how rewarding the events have been, I have often walked away a little frustrated. The event I attended most recently left me with the same slight feeling of frustration.

http://www.dreamstime.com/royalty-free-stock-photography-farmer-woman-cabbage-field-image16727927During grower food safety events, we often talk about why having a food safety program is important and how it is critical to have a program to protect your own business, protect your customers and, ultimately, public health. We talk about emerging science, the importance of foundational food safety programs such as sanitation practices and worker hygiene and how to identify and manage potential cross-contamination hazards on the farm and in the packinghouse. After going through this information and basically laying out the why, how, and what of food safety, often some brave soul in the audience will raise their hand and ask, “So what score do I need to get in order to pass the audit?” And that’s when the frustration sets in. How did passing an audit become a substitute for actually building a risk-based food safety program?

So much of the food safety discussion we have in this industry is centered on passing a food safety audit. In fact, for many, the food safety audit is the basis of their food safety efforts. A buyer mandates that a grower or supplier must have a food safety audit, so the goal is to pass the audit. Sounds logical enough, but food safety audits don’t really make food safer. This all-consuming furor over food safety audits is unfortunate because audits are only a tool, a snapshot in time, actually a snapshot in time that you get to pose for. Realistically, taking an audit is like taking an exam when you know when the exam will be scheduled, you already know all the questions that will be on the exam, and you already have all the answers, too. How many of us wouldn’t want to have had that situation back in high school or college? I am guessing we might have made better grades! How many times do we see a food safety recall and the report we read in the news includes a statement that says the unfortunate operation received a “superior” score on their most recent food safety audit? If you look deep in your soul, how many can say that they didn’t do a little extra cleaning the day of their last food safety audit and that your operation doesn’t always look quite so pristine as it does during an audit? It’s only human nature; we all want a good score, but how does that serve food safety?

Minimally, food safety audits are a mechanism to demonstrate to yourself, senior management, and customers that you are following your food safety program, and that you can verify it through your audit that day. At their best, food safety audits are excellent training opportunities for employees. Audits offer a chance to have an independent set of eyes critique your program and are a time when you can step back from all your other responsibilities and critically look at your food safety program and how it is being implemented. It can be an important learning experience.

I sometimes think that if we had spent half the time we have spent as an industry over the past decade discussing how to conduct an effective hazard analysis and train producers in this art instead of word-smithing existing food safety standards and audits and lamenting the duplicity of some of those audits, we might be better off as an industry.

Hazard analysis is really not a foreign concept to most people. People assess potential hazards and manage them in their daily lives all the time, whether we do so consciously or subconsciously. For example, when someone drives a car, they manage the risk of an accident by making sure the car is in good working order, the brakes work, it’s full of gas, and an effort is made to obey (at least most of the time) traffic rules and regulations to minimize the chance of an accident. When it comes to produce food safety, it is important that our food safety programs are similarly risk- or hazard-based. Simply developing a food safety program that supplies the paperwork required by whichever auditor is being employed does not address the food safety needs of your company.

Doing a risk assessment does not have to be hard. Start out by making a simple line drawing. If you are a grower, begin at the point you select the land you intend to grow a crop on through land preparation, planting, growing, harvesting, cooling, right up to the point where you no longer control the fate of the crop. Processors, transportation companies, distribution centers, and any other handlers can follow the same process, picking up where they impact the produce supply chain. It is important for all those who handle produce to understand the potential cross-contamination hazards associated with their specific operations and adopt management strategies to minimize those risks.

As you perform your risk assessments, reach out to all the experts who are available to you for their advice and input on the hazards you should be considering and how to manage them effectively. You already have lots of experts within your own organization. Who knows your operations better than the people who work for you? Too often I hear growers and processors say, “Just tell me what I have to do and that’s what I’ll do for my food safety program.” How can anyone else possibly know your operations and, therefore, your risk profile better than you?

But, see, that is where the rub is in food safety. Doing a real hazard analysis does not have to be hard, but it does require personal engagement. It’s not just answering a series of published audit questions; it’s taking the time and investing the human resources to review your operations, think about how the food might get contaminated, assessing what the likelihood of that contamination might be, determining how to manage that risk, determining who should be responsible for management, and how you are going to verify that the risk is managed all day every day. Since all produce operations are at least somewhat different, one-size-fits-all approaches will never be as successful in managing contamination hazards as operation-specific hazard analysis and management programs.

In any produce company I have ever been around, there is always at least one person who knows more about his growers and their practices than anyone else. There are also usually harvest and process guys who have incredible knowledge of what they do and why. Those are the folks who can help you build an effective food safety program. Once you create a team of experts who know the science of food safety and the folks who have to live it every day and get them talking, my experience tells me that you can build an effective hazard analysis and management system and practices that mitigate risk. And, best of all, your employees will own those practices because they had authorship in developing them. That kind of engagement is the best tool we all have to better manage food safety risks; audits are not even close. In fact, the best kind of audit would be one that verifies the farm or packing facility or processing plant is operating in accord with the operations-written, hazard-based food safety plan. Too bad we can’t start over and place hazard analysis first and properly use audits to verify their veracity.

© Food Safety News
  • J T

    The grocery stores are so concerned that the growers have stellar food safety audit scores, but then they don’t hesitate to contaminate the produce as frequently as possible themselves. They allow hundreds of people with unwashed hands and no hairnets to leisurely stroll through the produce isles and feel up as much produce as possible. If an apple falls on the floor, the produce worker will put it right back on the shelf with the other apples. When you go to check out, you are placing your fruits and vegetables on the exact same conveyor that had a leaking package of raw chicken on it right before you got there. Retailers are HYPOCRITES.

  • Ollie

    I could not agree more with your take on audits. I have seen this first hand even in food processing facilities where the goal is to get a good score during an audit, but during the rest of the year, the emphasis on food safety is only minimal and required record keeping subpar. In my opinion, it is the front line managers, who have to insist on complying with the food safety programs; but they also need the support from upper levels of management as well.

  • Gary

    An effective food safety and quality program (they go hand-in-hand) ultimately comes to two things:

    1. Culture
    2. Engagement

    If a company doesn’t have the food safety and quality culture where each employee is thinking about what and how they do things impact food safety or quality then the company is at-risk.

    Engagement, how can management in a company that wants/desires a food safety or quality culture engage employees?

    I think the biggest challenge in both areas is management. Management has to lead by “doing the right thing” regardless of the potential consequences. In my 15 years plus experience this is the #1 challenge. A current example is the incident with Jon Acosta; actually this was more than an incident, but rather a saga. He wanted to do the right thing and implement a food safety culture, yet was thwarted by senior management and even the CEO. To make matters worse he was fired over it! Ridiculous!

    Honestly, in many cases it takes a food safety incident, scare, or recall to really get management on board which is a travesty.

  • Paul_LK

    Excellent discussion! I’ve done hundreds, perhaps thousands, of inspections and audits of military units over the years. An important factor that is difficult to generalize and quantify is the interpersonal relationship between the inspectors/auditors and those being scrutinized (auditee). First, the auditee must be confident that the auditor knows what he/she is talking about by avoiding the “Chicken Little” syndrome, where every violation is equally hazardous. Second, without being condescending, the auditor should use the opportunity to educate the auditee about the underlying reasons for the standards. In both cases, the quality of the education, training, and experience of the auditor is paramount. But there will always be somebody who will defy authority and reject knowledge that is not first-hand. In these cases, the auditor has an ethical responsibility to protect public health.

  • Albert Chambers

    Bob

    Great opinion piece. Undertaking a hazard analysis is the key starting point. It’s the rigour that is the challenging, the “hard” part. That’s why micro, small and medium sized food businesses need to have toolkits built on rigorous hazard analyses (providing the good science) available to them to carefully adapt to their particular circumstances. This HACCP-based approach can work.

  • ben

    Great read. It should never be about the inspector coming to look, but about how clean you can be day to day.

  • AuntyMM

    so we see the regulations that are designed to protect us by creating a level playing field are also creating a level ceiling on product quality, as prof. julie guthman has observed: http://www.ucpress.edu/book.php?isbn=9780520277465

  • Jim

    The problem with an audit being only a “snapshot” is quite effectively alleviated by an auditing partner that probes deeper into historical records and methods of discrepancy management so as to gain a better understanding of the overall operation. If you hire an auditing body and they only consider that which they see during the audit, you are complicit in their producing a sub-par product. “Garbage in, garbage out.”

  • Anonymous

    I understand your frustration, but I think you have to consider the human aspect. You have the variable of many different personalities in industry. There are business people who do want to make the effort in developing well-designed risk-based programs. There are others who just want to meet the bare minimum requirements, which seems to be what you’re talking about. This is the reason for the food safety audits. The intent of the audit is to verify that food safety requirements are being met. But you also have to consider the limitations of the audit itself. The audit must be designed to ensure that those food safety requirements are being met to ensure that no adulterated product is being shipped. There has to be constant evaluation of the food safety audit to determine whether the food safety audit is providing the desired outcomes (which is food safety). There is an interplay between industry, the frequent changes happening in microbiology and in technology, and the food safety audits that occur. This is why frequent evaluation of the food safety audits and even of the food safety regulations themselves is crucial.