US: Third-party audits and food safety responsibility
Posted: November 1st, 2011 - 3:11pm
It seems that all too often food plants implicated in foodborne disease outbreaks had recently undergone and passed inspections conducted by an independent third-party auditor. Then when regulatory agencies conduct an investigation of the facility, they find major sanitation and processing failures. So why is there such a disparity between third-party audits and government food safety investigations and why aren’t third party audits better at uncovering potential food safety problems?
Of course, food processors are ultimately responsible for the safety of the food they produce. However, the recent cantaloupe outbreak has led to questions about the liability of audit firms and whether they can be also be held accountable for food safety problems arising from the audited facility.
Last week, an article by Elizabeth Weise appeared in USA Today in which FDA cited dirty equipment and other processing failures as possible causes of Listeria contamination on fresh cantaloupes. The plant that produced the contaminated product had recently been audited and received a high score (96 percent) by the auditing firm. The FDA investigation uncovered major failures in the plant’s food safety processes.
One of the reasons for the disparity between third party audits and government food safety investigations is that they differ greatly in scope and intensity. The FDA evaluation that occurred at the cantaloupe processing plant after the Listeria outbreak was completely different in scale than the third-party audit that occurred prior to the outbreak. After a major food safety failure, plants are closely scrutinized by regulators in order to identify the source of contamination. This involves a team of investigators as well as extensive microbiological testing of food products and the plant environment.
Another reason for the disparity is that third-party audits are designed to determine whether plants are operating in accordance with their written food safety plans. Under the current system, the adequacy of the food safety plans may fall outside the scope of third-party audits.
One of the most troubling findings reported in the USA Today article is that the plant associated with the outbreak changed their food safety process from a system that relied on washing cantaloupes using an antimicrobial solution to washing using untreated water. A spokesperson for the audit firm said that the company believed that the change improved their food safety process. As someone who has conducted extensive research on food safety interventions, I can tell you that water will remove bacteria – but it won’t assure the elimination of Listeria and other pathogens – that requires one or more validated antimicrobial treatments.
Should the auditor in this case have questioned the process change that substituted untreated water for an antimicrobial? Do auditors have a responsibility to evaluate issues such as scientific documentation of the effectiveness of interventions? Or should audits be limited to evaluating whether plants are simply doing what is stated in their food safety plans? In the case of the cantaloupe outbreak, the lack of an effective antimicrobial intervention may have resulted in a catastrophic food safety failure. Is that failure solely the responsibility of the plant or is the audit firm partially responsible for not pointing out the need for a validated intervention? These are important questions that must be answered.
The food industry relies heavily on independent third-party audits to determine whether plants are operating under sanitary conditions and in compliance with their written food safety plans. This will only increase as companies strive to comply with non-regulatory requirements, including the Global Food Safety Initiative. I believe that if this approach is going to be successful, food safety audits should include an evaluation of the adequacy of food safety plans. Ideally, this should include an evaluation both scientific and in-plant validation studies for interventions. In order for this to occur, auditors will require additional food safety training. In addition, some system needs to be put in place to certify auditor competence.
This approach should help assure that plants are producing safe food. It will also protect audit firms from food safety liability. It’s very likely only a matter of time before audit firms and auditors are held accountable for food safety problems that occur in the plants they inspect.