Pundit’s Mailbag — Closer Look At Auditing Process May Require Rationale For Each Component Of The Audit
Jim Prevor’s Perishable Pundit, February 9, 2012
Our piece, Auditing and Food Safety, brought this note from a longtime Pundit contributor:
Bob raises a very good point. Very often, people require audits because they want things safe, because they wish to mitigate liability and because it may be required by law, regulation or clientele. Very frequently, they really don’t know what is being audited or why. They just know they need an audit.
Audit-standard developers and auditors themselves sometimes feel the need to justify their product by producing large and impressive checklists and reports, without much evidence that these individual items have much efficacy in preventing foodborne illness.
Harmonization efforts often resolve differences by simply doing more. So if audit-standard developer Smith thinks Question A is vital, and audit-standard developer Jones thinks that doesn’t matter, but Question B is essential, the resolution is often to ask both A and B and thus harmonize the standard.
The temptation is also always there to audit those things that are easy to audit and ignore those things that may be more important but are difficult or impossible to audit.
As Bob implies, the notion that every question asked on an audit is “science-based” is a bit of a stretch. There are very few controlled studies that have ever been done, and our knowledge of pathogens and their behavior is very limited, so the notion that “science” compels a 25-foot buffer zone and not a 20-foot or 30-foot buffer zone is a very hard case to make.
Of course, following the spinach crisis of 2006, there was a conscious decision to not allow the limitations of knowledge be an excuse for inaction. The thought was that the status quo was unacceptable and so we would, as an industry, have to do the best we could to improve food safety even while launching initiatives such as the Center for Produce Safety to improve the science and increase our knowledge.
Still, audits are burdensome, and it wouldn’t be a bad idea for audit-standard developers to have to publish a justification next to each question or line item. Why is this here? What will this prove? How will it enhance food safety?
The Rocky Ford cantaloupe outbreak led many to learn that audits are typically not done to determine if every possible thing that can enhance food safety has been done or even to ascertain if a facility is world-class. Audits are typically done just to confirm that some facility operates to industry standards, although the definitions here can be slippery
Making someone explain how those standards make food safer isn’t the worst idea one could proffer.
Many thanks to Bob Sanderson of Jonathan’s Sprouts for contributing to the industry discussion on this important issue.