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.
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.