There may be more or fewer elements, depending upon the audit in
question. So what’s the problem? This is
a huge amount of material that must be
observed and commented upon. Since
the basis of audits is essentially, “Are you
doing what you have written down and
have you written down what you are
doing?” the audit must entail not only
watching what is going on in the facility,
practices and verification that the procedures are properly documented. Given that
each of the points highlighted above may have several sections, it is hard to envision
that even a good quality auditor can complete any evaluation in a day or two.
In addition, most audits are designed with large companies in mind. This is not to
say that food safety standards should be different for small and large companies, but
all too often the audit fails to account for how a small firm actually does business. In
small companies, people wear many hats and may even wear them more efficiently
than a large group of people in a large operation.
Auditing Is a Business/Conflict of Interest – Third-party audits are a lucrative
business for many. The New York Times article noted that audits made up over 50% of
one company’s revenue. Thus, there is an
incentive to keep a business going and
profitable. According to the Times piece,
“Auditors are also usually paid by the food
plants they inspect, which some experts
said could deter them from cracking
down.” I can’t verify that some auditors or
audits are more lenient because the firm or
auditor wants to keep the business. How-
ever, I can say that I have been in plants that have proudly showed me their past audits and bragged about how well they did, yet after I finished my work, I vowed never
to eat their products. I guess the bottom line is how ethical a person is, assuming that
they have the knowledge to do a good job. Along this line, one company reported
that a representative from an audit firm guaranteed that the company would pass if it
selected that audit firm. An auditor is not providing the client with good service if he
or she fails to do a rigorous audit.
Snapshots – An audit is a snapshot of an operation. The key for the auditor is to
be observant enough to ensure that the snapshot reflects actual operations. Companies that prepare for audits pose a problem, because the plant should always be looking its best. There are things that will point to plant operations being a bit different.
Two of these are fresh paint and new procedures that were initiated within the previous two weeks. When an auditor sees records indicating recent procedural changes, he
or she should always ask for training records to verify that people have been trained
on the new procedure(s) and then ask plant employees questions to ensure that the
training increased their competencies. Plant management tends to forget to do this, assuming that the new procedure itself will satisfy the audit.
Scoring – Scoring is definitely an issue with third-party audits. As an example, the
GMA-SAFE audit, which was designed to describe, in words, an operation’s quality
systems, ultimately had to develop a scoring system to be acceptable to certain customers. Managers love numbers, so audits have scores. I learned this firsthand during
my time in industry. I brought Mr. Katsuyama’s audit format with me and was asked
to create a scored audit. The new format was approved by management and put to
use. However, when potential packers began scoring poorly, the response from management was that we should lower the passing score.
Unfortunately, one of the most common questions auditors are asked is, “What do
I need to score to pass?” Passing is not the issue—ensuring safety is. It does not take a
major sanitation issue to create a problem. As noted earlier, the PCA achieved good
audit scores, but had serious problems that were not addressed.
Follow-up/Response – “Even when audits do turn up problems, it is up to the discretion of food companies to fix them.” This is a real problem. Unfortunately, when
most auditors complete an audit, their job is done. Follow-up is left in the hands of
the processor. However, one element that should be part of all audits is “Corrective
and Preventive Actions.” What has that company done to address such problems, be
they issues that were found by an outside auditor or picked up by the company itself?
Next, it is important to ensure that the corrective and preventive actions actually
solved the root cause of the problem. If there is a history of not following up, it
should be obvious to the auditor. In the case of the PCA, third-party audits uncovered
“Should a single company should be
allowed to impose their standards on
other companies? It is being done.”
but reviewing procedures and records to
ensure that these programs are being
properly documented, that records are
being maintained properly and that management is reviewing records to verify
compliance. This is a lot to do in an
audit that is often scheduled for only
one to two days. With so much material
to cover, it is easy to see how some areas
could be overlooked and a company
could receive a high score on an audit,
yet have serious defects.
ISSUES WITH THIRD-PARTY
AUDITS
Can third-party audits be improved?
Definitely. The repercussions from the
PCA debacle reportedly have affected
the way third-party audit firms do business. They are demanding more time
(and money) to do audits, have implemented mandatory failures and eliminated the provision that allowed a failing
company to switch from a final audit to
a pre-audit. There are many issues that
must still be resolved, however. Let’s
look at some of these.
Audit Length and Complexity – In
an effort to be widely applicable, audit
questionnaires have expanded year by
year. Firms add more questions to keep
up with their competitors, yet the time
to complete the audit usually remains
the same. In addition, most audits do
not evaluate the linkages between audit
elements. To properly evaluate any one
of the items mentioned above requires a
review of procedures, viewing of actual
