What Does the Future Hold for Third Party Audits?
Throughout all the discussions about food safety in the last six months, one group has escaped being noticed. I am surprised we havent heard more about the third-party auditing companies working in the produce industry. Since the early 1990s, when the fast-food chains first asked for third-party audits, fresh-cut processors have complied, expanding their food-safety programs to cover the standards they advocate.
There are numerous sources of information on food-safety standards, and many people take advantage of training seminars, books and articles written on the subject. But, lets face it, auditors get our attention. If the audit is announced, weeks of preparation ensue. If the audits are unannounced, then food safety has become entrenched throughout production. In fact, audits are so much a part of the processing life that some companies have hired a person just to handle auditors and all of the required recordkeeping and corrective actions.
Each buyer has an approved auditing company and, in addition to those audits, some buyers even conduct their own. One processor estimated they have an audit every other week. It would seem important that we are all working to streamline the audit process to direct resources toward better problem solving and safer practices. One has to wonder how audits are created and how they will change as the government works to improve its oversight of the produce industry.
Where Do The Questions Come From?
We cant ignore the position the government plays in contributing to the standards adopted by third-party auditors. In fact, government regulations make up the foundation of these audits. Once the standards set by the federal and state governments for good manufacturing practices, worker hygiene and plant sanitation have been covered, the auditing companies get creative and customize their audits with additional requirements dictated by their customers or their in-house experts.
Buyers contribute to the audits substance by identifying specific practices they want monitored. The QA specialists that work for foodservice and retail food companies stay on top of their game by attending food safety summit meetings and exchanging information in peer group meetings. They also learn from experience and you can bet that many questions they add to an audit probably resulted from a failure in their system.
Additionally, the auditors and their supervisors contribute to make sure the audit questions are realistic and up to date. These people are experts in quality assurance, sanitation, pest control and other food safety specialties. Plus, they are on the ground looking at production details every day. They know what works and what doesnt.
Are Auditing Companies Audited?
Most auditing companies hire their own auditors using different philosophies. Some companies hire auditors to be full-time employees, and others bring them on as contractors. Every auditing company also has its own unique training philosophies. There are no standards covering audits or auditors, but there may be soon.
If there are federal or state regulations on the horizon for produce, we must assume that the auditing process may be scrutinized by the regulators and may be standardized. At this time, FDA is not equipped with enough personnel to conduct third-party audits, but it may be planning a new system to serve the industry.
USDAs Federal-State Audit Verification
There is already a process in place for the federal government to audit produce companies for adherence to GAPs, but from what Ive seen, it doesnt go far enough. Several years ago, USDA responded to a request by New Jersey to develop an audit verification program so their growers could demonstrate adherence to GAPs for their retail customers. The program (highlighted at www.ams.usda.gov/fv/fpbgapghp.htm) is fee-based, has been expanded to more than 30 states and involves both USDA and state departments of agriculture.
The verification program is based on the FDA guidance document covering GAPs and employee hygiene, but does not go much further. Depending on what FDA implements as a result of the spinach outbreak, the verification program may change. I dont know if the two agencies work together on this program, but we should be aware of how, or if, the program could be used to monitor the industry.
We have recently seen a draft of the guidelines from California regarding food safety practices in the field, and expect third-party audit procedures to change to reflect what is finally adopted. Whatever comes out of this effort to update our food safety standards, lets hope that the new standards will be specific enough to assure safety and allow us to streamline the audit process so that fewer audits will be needed.