February 11, 2009 -- EHA Consulting Group, which has over 25 years of experience providing food safety consulting, released comments today about the qualifications and competencies of food safety auditors.
The potential for under-qualified and lack of third party audits by many of the processors who purchased the recently recalled Salmonella contaminated peanut butter and peanut product may have had an impact on the number of cases of Salmonellosis and deaths according to EHA's President, Dr. Melvin N. Kramer.
Salmonella typhimurium has been reported in 600 cases across 44 states and Canada, and attributed to peanut butter incorporated into a plethora of food products. These cases have resulted in eight deaths. This outbreak is an embarrassment to the U.S. Food and Drug Administration (FDA), state regulators in Georgia, and industry.
The facts, as reported by the FDA, contain observations that the firm is alleged to have put into interstate commerce peanut butter and other peanut products that had previously tested positive for Salmonella by a private laboratory contracted by the firm.
These products were subsequently re-tested and found to be negative for Salmonella, and then put into interstate commerce and shipped to the firm's approximate 2,100 clients who utilize the peanut products for countless human and animal foods. The widespread effect of Salmonella typhimurium traced to peanut butter has captured the attention of President Obama, who has promised sweeping changes in food safety. The issues surrounding the FDA and the regulatory aspects are being addressed by the Congress of the United States in what will sure to be a series of public hearings.
The Salmonella typhimurium outbreak and the subsequent recall are somewhat different than other highly publicized outbreaks and recalls. This is an ingredient-driven outbreak rather than a commodity-driven outbreak. Major food processors incorporated the contaminated peanut butter and peanut products into their own food items.
What isn't well known by the general public is that many major food processors are inspected by third-party auditors to ensure that the products they receive are wholesome, unadulterated, and conform to regulatory standards, as well as their own internal standards. This, in effect, not only checks on food processors' suppliers, but also augments governmental regulatory inspections.
The peanut firm in question proudly touted on its website the fact that they routinely underwent third-party auditing. Questions have been posed as to where are the third-party audits for all of the 2,100 companies who purchased product from this plant, many of whom are luminaries in consumer food products routinely sold at our nation's finest supermarkets, grocery stores, and specialty shops.
In the February 5, 2009 USA Today, Kellogg openly stated that they are reviewing how they qualify food safety suppliers after its third-party auditor gave the Georgia plant a "superior" rating. Unfortunately, the differences involved in auditor competencies vary greatly. Is it possible to distinguish what exactly defines an auditor/inspector or auditing/inspection company as truly qualified to provide services to a facility? EHA Consulting Group, Inc. believes the answer is categorically "Yes."
Unfortunately, many people are aghast that there are no required certification or registration standards that industry universally applies and requires of third-party auditors. In an internet recruiting poster, posted by a large and prestigious international third-party auditing firm, corporate recruiters advertise that their minimum requirement for a Lead Auditor is a "High school diploma, or equivalent, plus ten (10) years food processing experience (food plant experience in a responsible position related to food safety)."
This is not in the best interest of the public's health nor of the corporate brand from which ingredients or products are procured. Moreover, this may lower the quality of inspection due to the fact that the individual performing the audit is not a registered public health professional. Furthermore, some of these firms actually have other business interests that are far greater in the profit perspective than auditing; namely pest control, laboratory services, certification of equipment and/or the sale of chemicals.
Major food companies like Kellogg, that purchase raw materials or finished products made by other firms and privately label them with its brand, require that its brand specifications are complied with for a variety of non-public health reasons having solely to do with their brand, its quality, and its identity.
EHA Consulting Group, Inc. believes that having auditors encompassing backgrounds clearly grounded in food safety, environmental health, microbiology and epidemiology best serves the client who is requesting the audit, and most importantly protects the public's health.
Most states require that anyone who performs these inspectional services publicly or privately must be a Registered Sanitarian (RS) or Registered Environmental Health Specialist (REHS). Achieving this professional status ordinarily requires a minimum of 30 credits in the sciences and a Bachelor's Degree, plus completion of a written examination. How can food processors ensure that the third-party auditing company they trust to guide and assist them in the elevation of food safety affords them the best service possible?
EHA Consulting Group, Inc. believes that the answer is simple. Food safety audits must be conducted by registered public health professionals who are not only qualified, but nationally credentialed. They bestow upon the auditor the ability to concentrate on the root causes for the potential of food-borne disease to occur from a particular product or facility.
At the same time, it is required to focus significant attention to regulatory standards and compliance in terms of food protection, employee health, temperature control, insect and rodent control, plumbing, lighting, ventilation, structure, and documentation of their HACCP plan, SSOP's and GMP's.
The question that follows in this issue involves price. Is price a function of inspector qualification and education or the ability to explain issues related to best industry practices during an audit? Yes, there is a direct correlation between the effectiveness of the inspection, the qualifications of the inspector and the potential pressures of selling goods and services rather than just performing a professional, unbiased food safety inspection.
Factually, the company who performed the food safety audit at the Georgia peanut butter plant does sell other goods and services. Industry does not like to wake up to headlines from the Centers for Disease Control (CDC) like we had this morning stating that 600 individuals were made ill and eight people have died from a consumer product contaminated with Salmonella.
Appropriate third-party auditing conducted by competent and dedicated professionals focused solely on the inspection and not the sale of chemicals, laboratory services or pest control services will significantly decrease the probability of illness attributed to food. EHA Consulting Group, Inc. for nearly the past three decades, has held these principles to be a sacred trust between us, our clients, and the countless millions of people whose health and well being we have a part in protecting.
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