The one simple question that dramatically changed my perspective on food safety audits.
I have been a food safety auditor and inspector for 25 years. During this time, I have lived with the belief that I was generally doing a good job and helping the food industry improve their standard of food safety. This was until yesterday when I got a dose of reality from my friend who is also a food safety professional. He asked me a question that completely changed my perspective and the way I viewed food safety audits. It is not often that a simple question can do this to me and it was so profound I decided to write about it.
My friend asked me — “As food safety auditors do you think we are improving the standard of food safety or are we hindering it?”
Well! of course my response was “we are improving it”. We are passionate about food safety and we want food companies to achieve the highest possible standards. Food safety requirements have never been more comprehensive and in theory if food safety audits and inspections are done according to the established standards by trained qualified and experienced auditors then of course we must be helping improve food safety.
In my previous company, I was the Quality Director responsible for ensuring our auditors and inspectors were calibrated and were consistently meeting the high standards that were expected. Food safety professionals have access to some excellent lead auditor training courses and food safety certification schemes demand a very high level of experience coupled with audit skills and competence to audit against the food safety standards or certification scheme. Couple this with our company’s own internal auditor training and calibration requirements and we had a very extensive and high-quality program.
Even though we had an extensive program I could not help but notice that it was extremely challenging to calibrate every auditor. Apart from the human factor i.e., personality, experience, knowledge etc, probably the main contributing factor to the challenges in calibration was that food safety audits and inspections rely heavily on risk assessment (which is not an exact science). You can calibrate a thermometer to read the exact temperature, but how do you calibrate a human to assess risk the same?
So we can agree that food safety auditors are all human and while we may not be calibrated like a thermometer, with all the training, knowledge and experience we should get pretty close.
Then I started to think about how the food industry perceives a food safety audit and the auditor. Regardless of whether it is regulatory, certification or a customer audit in the majority of cases it is seen to be like a “test”. A test that must be passed. In many cases it even becomes a “game”. A game where the auditor is trying to find non-compliances and the auditee is trying to prevent the auditor from finding the non-compliance. Depending on the personalities of the auditee and the auditor this can end up being a power struggle. Food safety then ends up in the hands of this power struggle. A struggle that many times becomes more about ego and “right fighting” rather than about risk assessment and continuous improvement. For a positive outcome the aim is for a win-win situation. The auditor gets all the valid data and info he needs to make a valid risk assessment and the auditee gets an accurate picture on where they need to focus to make the next improvement step. However, it often ends with a win-lose or lose-lose situation and when one side loses then food safety loses.
Let me give you some examples from my own experiences where I have seen food safety lose because of a win-lose situation.
“Customers, confusion and coloured hooks”
At a food manufacturer I was inspecting I found four sets of different coloured hooks on the walls at different parts of the warehouse. On the day of my inspection I found that the Insect light traps (ILT’s) were hanging from the yellow hooks. I asked my escort about this and he said that the coloured hooks coincided with different customer requirements for where the ILT’s needed to be positioned. Yellow, was for customer A, blue for customer B, red for customer C, etc, you get the picture. So, when customer A came to inspect the factory all the ILT’s went on the yellow hooks. Clearly a lot of effort and time had gone into this system, but I could not help the feeling that their efforts could have been applied better somewhere else. Where was the science behind this? What were the risks? Why was the factory doing this? This became a case that the factory was doing this to make their customers happy. What kind of a message did this send factory staff? Did this add value or increase cost and cause confusion? The company lost and the customers won, but did this help the factory improve?
“The law is the law”
In some countries in Asia, there was a trend that some regulatory bodies were requiring UV lights to be installed in certain areas of the plant. The logic was that UV light is known to kill bacteria, so the food processing plants needed to install these UV lights as part of the hygiene program. As a result, we found rooms with numerous unprotected UV lights mounted on the ceilings with no evidence that they were in fact an effective microbial control. One light was found to be broken and to have contaminated product situated below. The company was upset that I failed them, because these UV lights were a government requirement! I lost and the auditee lost. The only winner seemed to be the UV light supplier. Did this improve food safety or hinder it?
“Foreign material control overkill”
An ingredient blending site I inspected was found to have a metal detector situated directly after a fine mesh punch metal sifter screen. The size of the sifter screen was 1mm and the best sensitivity of the metal detector was 2.5mm ferrous. In theory the fine mesh screen was a far better control of foreign material than the metal detector. While I had no problem with an additional foreign material control device situated on this line, I asked out of curiosity why they had installed the metal detector. Their answer was because their certification auditor required it and the auditor required it to be managed as a CCP. So not only was this an extra cost to buy the detector, there were extra labour costs, extra documentation and extra audit requirements for very little added value. The auditor won and the auditee paid for it, but there was no real improvement in food safety.
At the closing meeting the auditor communicated the findings and risks to the factory team, but the factory got upset with the auditor because they were not happy with the results. They threatened the auditor and even tried and bribe her. In stressful situations like this it is common that an auditor may capitulate. The auditor loses and the factory thinks they have won. But in the end assuming the findings were valid, food safety loses.
“To the lazy hunter the woods are always empty”
Sometimes auditors are told by their audit companies not to find too many issues or not to find any major issues which could jeopardise the certificate. Alternatively, auditors sometimes choose to cast a blind eye or to do a superficial audit. This makes the job so much easier as the report does not take as long to write and the factory is happy because they get a good result. While the auditor and auditee both feel like they have won, food safety comes out as the biggest loser.
There are many other examples like this and I am sure you can relate to these with examples of your own.
Whose food safety program is it?
While on the surface it appears that the auditors or the standards are not being realistic and practical, what is an even bigger concern to me is that food companies are letting this happen. Why? Is it because they do not want to lose the business, or they want the certificate or they do not want to anger the regulatory body in fear of a fine?
Why are food companies allowing this to happen? It is clearly not reducing risk, it is adding cost and causing confusion and undermining culture. It is a classic case of the tail wagging the dog. This is about egos and personalities and not about food safety.
What if food companies…
1. set their standards higher than what is externally expected of them
2. they wrote their programs for the people that are using them, not for the auditors.
3. they undertook tasks that added value and that were not shrouded in red tape.
4. they ensured their internal auditors were as good if not better than the external auditors.
5. used audits as a way to proactively drive improvement and not as a test that must be passed at all costs
….would we see stronger food safety cultures and higher standards of hygiene and food safety?
Are food safety auditors improving food safety or hindering it?
Regulatory, customer, certification or systems auditors need to step back and think about some of the requests we make. Be careful of responses like “do it because the standard says so” or “do it because I said so!”. These are lazy egotistical responses. An auditor’s job is to do thorough audits, collect as much data as they can, apply the standards practically and realistically based on each unique situation and risk assessment then communicate that risk clearly. If we can do this, we will help the industry improve but if we do not, we are going to be a hinderance.
I think that in general food safety auditors’ hearts are in the right place and we want to make a difference but that increasing business demands and the ever-increasing complexities of food safety compliance are not making it easy. I think it is time for food companies to reconsider the purpose of a food safety audit. It is your food safety program and you do not do this to please the auditor!
As a food safety coach, I have found myself focusing on the root causes of food safety failures. Up until yesterday, I had identified 7 main root causes:
1. Lack of strong leadership
2. Weak food safety culture
3. Ineffective problem solving and root cause analysis
4. Lack of resources (time, money and people)
5. Lack of standards and specifications
6. Lack of accountability and responsibility
7. Lack of effective training and talent development
Could I have possibly found root cause #8?