As audit requests accelerated during the early 2000s, quality assurance managers in the milling and baking industry grew concerned. Jennifer Robinson, today vice-president of corporate quality assurance at Bay State Milling Co., was then at Cargill in quality management. Its facilities were being audited an average of three times a year, usually to a different standard each time. She described how in 2009 Cargill evaluated the cost of all this and found it exceeded $23,000 per facility per year. Applying this figure to the hundreds of thousands of food facilities around the world, they came up with a figure of $6.5 billion in redundant audits.
“This became the rallying cry of the AACC International Food Safety Quality Task Force,” Ms. Robinson told a gathering at AACC’s 2015 annual meeting. “At that time, there was no alignment between audit customers and audit schemes. We called it ‘audit soup.’ ”
The task force did a side-by-side analysis of the various audit schemes and found 96% congruence in matters covered.
“All of today’s audits are good,” noted Joe Stout, president and founder, Commercial Food Sanitation, LLC. “Success depends on a combination approach of audits and inspections, on benefiting from the best of both worlds.”
Experts agreed that there is not one audit or inspection program that fits the needs of all bakeries and snack food manufacturers. “The choice … depends predominantly on what a manufacturer’s customer requires or the needs of the manufacturer,” observed Camila Yoo, food safety professional, AIB International, a third-party audit group. “Global Food Safety Initiative (GFSI), Safe Quality Food (SQF) and Good Manufacturing Practices (GMP) are similar in that they are all established to ensure food safety, but they are different in the way the audit/inspections are conducted in terms of the standards used and the proportion of time allocated to inspection versus audit,” she continued. “Even between certification audits, there are differences.”
As an example, Ms. Yoo contrasted Food Safety System Certification (FSSC) 22000 and British Retail Consortium (BRC). “Requirements are more general in the FSSC 22000 standard compared with the BRC standard, which is more descriptive,” she noted. “Compared with FSSC 22000 or BRC, GMP inspections put more weight on the physical inspection than audits.”
“Choice can also be culture-driven,” said Kristopher Middleton, technical manager, US Food Division, Eurofins, which has a significant practice in food plant auditing. “The standard should be selected to match the company culture and in-house expertise. For example, if you have ISO experience, then you may like FSSC 22000, a GFSI-benchmarked food safety standard based on existing ISO standards.”
While satisfying a customer — or ensuring regulatory compliance before the Food and Drug Administration inspector arrives — audits serve additional purposes. “Facilities benefit in other ways than verification of performance against example,” Mr. Middleton said. “Audits can help reduce errors and increase employee buy-in. That’s because audits are not just about changing and improving company culture.”
Company internal audits are essential to complying with most standards. Performed at least once a year, such audits should probe all aspects of food safety in the plant. How often the different elements of the food safety management system are subject to an internal audit should be based on a risk assessment conducted by the food safety or HACCP team. Mr. Stier described these activities as important learning and training opportunities.
Food safety experts advise hiring a consultant to do a gap evaluation to help management decide what works best for a given facility. This helps the facility bridge gaps between its current food safety management system and a certification-level program, noted Ms. Yoo. It is also useful when new versions of standards are released. “A gap assessment will evaluate the established procedures, programs and documentation to measure how well the facility’s food safety programs align with the selected certification standard requirements,” she explained. Altogether, it may take a facility one to two years to get ready for its initial audit.
So, you’ve done the gap analysis, selected a standard, written the documents and taken the training courses. What’s next in preparing for a third-party audit or government inspection?
“Ideally, a plant shouldn’t need to prepare. It should be audit-ready all the time,” Mr. Stout said. “But being ‘on’ 24/7, 365 is hard.”
Jim Kline, president, The Ensol Group, a consulting firm specializing in bakery and snack plant projects, agreed, “Once a company embraces a set of standards, then it must follow them every day, and then it will be ready for an audit. Readiness is an ongoing matter.”
The need to be ready on a continual basis is another reason for in-house audits, according to Mr. Middleton. “These make sure your system is effective and ready for an audit,” he explained.