I note with interest the lead story of Monday, March 1, 2010 that “Food safety audits never enough”. There is no question that a simple food safety audit is not the ‘be all and end all’ in assuring food safety, whether at the retail, processing, manufacturing, or farm level.
However, to broad stroke the worthlessness of food safety audits is, in my opinion, a grave error. There is no question that over the past several years some high profile recalls and outbreaks, including outbreaks associated with deaths, have occurred in facilities that have had third-party audits.
The questions should be, “Who is the auditor?”, “What are the auditor’s credentials?” and “What is the motivation of the auditing firm that is conducting the audit?” Specifically, having auditors that do not have minimum credentialing of a Registered Sanitarian or Registered Environmental Health Specialist (R.S./ R.E.H.S.) is clearly the beginning of a recipe for failure.
Some of the national auditing firms that have teams of auditors who post on their websites that the minimum requirements are a high school diploma or equivalent and five to ten years of experience in a food plant clearly do not meet any credentialing standards that I would want to have as an auditor. Individuals who possess the correct credentials of the R.S./R.E.H.S. require a Bachelors Degree with 30 credits in the sciences, training, experience, and passing a state or national examination.
Motivation and hidden agendas must also be brought to the forefront. If the auditing company is selling pest control services, chemicals, laboratory services and training seminars the focus of the third-party audit may not be as pure as what it should be. Idealistically, the only business of the auditing firm should be consulting, and only consulting, with no other goods being sold. Having said that, there is another problem, which is in the expectations of the firms that are being audited. The fees that are charged for third-party audits vary widely and so do the amount of time spent during an audit. There is no question that one cannot go through five to eight retail establishments in a work day or a several hundred thousand foot processing facility in a day and have a comprehensive food safety assessment complete with an educational approach for compliance and management understanding as to corrective action.
What is a “pass” and what is a “fail” for an audit? The issue of pass and fail may well be reduced to a score, however, everyone would agree that it is the quantity and quality of the issue rather than a number assigned. I would hope that any competent auditor who went through a facility that did extremely well and the last observation they saw was raw sewage bubbling up in a food preparation area, regardless of score, that audit would be a fail and significant corrective action in terms of the food that was potentially exposed as well as the root cause would have to be addressed in a team effort with the auditor and the management team.
There are no standards for the auditor for any credentialing, there are no standards for reporting, there are no standards for scoring there are no standards for the level of reinspection, therefore there are problems with food safety audits, especially from some of the larger national firms. It is my opinion that we need not throw the proverbial “baby out with the bath water”, but rather tighten up and assess what we really are looking for in an audit and report, as well as having corrective action that is verifiable. However, one cannot dismiss the large numbers of food safety audits that are being conducted where management is garnering much needed and much welcomed information providing corrective action that is ultimately protecting the health and well-being of the consuming public.
Thankfully, these successes are not recorded in morbidity and mortality statistics.
I take umbrage at the notion that food safety audits are worthless, realistically I agree that some have become a lost leader into the more lucrative areas of major corporations -: chemical laboratories, pest control, training and equipment certification businesses.
That is not to say that there are not highly credentialed, qualified, motivated individuals in these firms. However, they are not the ones that are performing these routine inspections and that must change. There is room for a professional cohort of auditors who are compensated well for an appropriate audit that is well-executed, well-documented and understood by everyone involved.
This is going to become more critical as governmental resources, especially on the local, county and state levels, are cutting back on inspections and neither FDA nor USDA are funded nor staffed at optimal levels. Melvin N. Kramer, Ph.D., M.P.H., R.E.H.S. President EHA Consulting Group, Inc. www.ehagroup.com [email protected]