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Tuesday, 6 September 2011

“Superfluous”, “Non-crucial” Audit Elements

 “Superfluous” may be too harsh a term. Nevertheless, there are elements that are not crucial to food safety in many audit checklists. The fault may not lie with the schemes that use these checklists. The extra and non-crucial elements may be well-intended. In practice, however, the interpretations of such elements often veer away from the real intent of the food safety audits. Veering interpretations are not exclusively offered by the audited parties. Some auditors insist on interpretations that make no sense when what really matters regarding food safety – the safety of the food consumer – is considered.

All food safety audit considerations ought to be essential to food safety. The assessment or investigation of food safety requirements must examine how such requirements contribute to food safety and product quality. The evidence sought to confirm compliance with the considerations must likewise focus on the contribution of such evidence to food safety and product quality. After all, this is the focus of food safety and quality system audits. If it cannot be determined that the checklist elements have roles in ensuring food safety or quality of products, they should not be included in a food safety and quality system audits.

To further explain this point, let us take a look at one example. Almost all of the audit schemes on the market today require the verification of documented procedures and records. A common interpretation of this requirement is for documents and records to have the signatures of the verifiers. To some audited parties and auditors, the mere presence of signatures satisfies the requirement. So we ask: How does the mere presence of signatures on documents and records contribute to food safety or quality for that matter? How consistently true is it that the mere presence of signatures on documents and records actually verifies the effectiveness of the procedures?

The intent of verification is clearly something different. Where audit standards fail to properly explain the intent of this requirement, its inclusion as part of the assessment scheme leans in the direction of being “superfluous” or “non-crucial”.

Well intended verification has to do initially with the confirmation that the written procedures are in fact effective in ensuring operation controls such that predictable and identified risks are mitigated. Secondly, verification is expected to look at the correct and consistent application of the written procedures in the actual processing or related operations. Therefore the evidence sought to confirm compliance with this requirement ought not to be the presence of signatures on documents. This is often the only extent to which many audit reports go. A close look at the actual frequency of failures within the system is a better parameter to examine. The current auditing landscape does not lend itself to a sufficiently thorough examination of these kinds of parameters. Besides, many auditors are sooner happy than otherwise when verification signatures are provided on the “corrective action” reports. Irrespective of how many times the same type of deviation recurs, the auditors issue “pass” grades as long as each instance has “corrective action” documentation.

The known challenge is that audits are snapshots. Also, as a result of cost management concerns, audits are conducted over a relatively short duration. In connection with the time limitations, the typically overwhelming number of audit elements to review during a single audit also has a direct effect on the depth to which investigations can be conducted. These factors limit the extent to which it may be confirmed that procedures are in fact effective in ensuring operation controls, or that the procedures are correctly and consistently applied in the actual operations.

Other examples of superfluous audit elements include the requirement for facility’s to have and ensure “that documents in use are current”. The intent of this requirement is often insufficiently explained, inadequately applied and improperly assessed during audits. The requirement itself, as stated in the checklists of several audit schemes, has only a partial significance. Documents may be “current” but they may lack validity or effectiveness for the intended purpose.

There are many more examples of these kinds of elements in the audit checklists used by current schemes. Perhaps you know some. Please share your thoughts!
Posted By Felix Amiri
Felix Amiri is the current Food Sector Chair of GCSE-Food & Health Protection

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