Opinion: food safety audits by Dr. Bob Whitaker
Do we have it backwards?
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 last three years, I have probably been involved in twenty 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.
During grower food safety events we often talk about why having a food safety program is important, 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 like sanitation practices and worker hygiene and how to identify and manage potential cross contamination hazards on the farm and 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 look quite so pristine as it does during an audit? Its 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 last decade discussing how to conduct an effective hazard analysis and train producers in this art instead of wordsmithing 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, its 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 whatever 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 simply 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 expert 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, its 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 that 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.