Copyright © Global Coalition for Sustained Excellence in Food & Health Protection, 2011 and ALL subsequent years: Unauthorized use and/or duplication of this material without express and written permission from this blog’s authors and/or owners is strictly prohibited. Excerpts and links may be used, provided that full and clear credit is given to Global Coalition for Sustained Excellence in Food & Health Protection with appropriate and specific reference and/or link to the original content.

Tuesday, 12 March 2013

Voluntary Disclosure of Product Safety System Non-conformances - An Open Challenge:

A true value-added audit realistically identifies strengths and weaknesses in the operation for the purpose of capitalizing on what is beneficial while improving areas of weaknesses.

Are facility managers therefore voluntarily disclosing system non-conformances that inspectors or auditors might have missed? Are inspectors and auditors, requesting the disclosure of system non-conformances that they (the auditors or inspectors) might have missed? If not, why not? 

Under which product safety and quality system or scheme do audited managers willingly disclose weak points in their operations without penalties?

Sad Truth
Do you cringe at the idea of voluntary disclosures during audits or inspections? You are not alone. Although such voluntary disclosures represent that for which the industry yearns, the popularity of the idea wanes as soon as it is mentioned. Voluntary disclosures cannot be popular because they stand in complete contrast against that which the industry wishes to eradicate (DISHONEST BEHAVIOUR) but finds itself heartily and slavishly embracing. The notion of "compliance enforcement" leaves people in chains. These chains do not prevent wrong-doing. They only drive it underground. Is it any wonder then, that many in the industry are uncomfortable with the idea of voluntary disclosures?


  1. During customer inspections the opportunity raise potential improvement to systems which will be of mutual benefit should not be missed, whether this then forms part of the report is a judgement call by the party writing the report. Both parties should be sensitive to the cost benefit of any proposed actions arising. It is an opportunity for Technical management to raise potential safety and quality issues and leverage support for capital investment.
    Audits by third parties are a different matter as the element of dialogue between supplier and customer before the decision to go on record is largely absent, the system and documentation is being judged against a specific standard and the auditor has undertaken to carry out the audit in a prescribed manner. It is professional for an auditor to ask to be shown internal non conformance documentation, but I suspect that the query relates to matters which are not documented and may be more the opinion of the individual(s) involved in the audit rather than the people who are responsible for the financial health of the company. Most audit protocols require senior management presence at opening and closing meetings to show commitment to the audit process and this is an opportunity to raise issues which may be outside the precise scope of the audit and may not be documented in the report. There is a clear difference between pure audit roles and consultancy but much does depend on personal relationships and trust. It is clear to me that there wil be a reluctance to raise unidentified non conformance issues if they are attributable and might result in covert disciplinary action.

  2. If an auditor is really good, a company won't sneak too much by him. If they choose to hide things that are crucial and can be harmful to the ongoing success of the business, it will be of their own doing when the #@&% hits the fans down the road. Auditors and inspectors can have such different views on issues regardless of what the company chooses or chooses not to disclose.

  3. Until a protocol can be developed whereby voluntary disclosure of non-conformance can occur without penalty it remains unlikely that operators will comply, however much they may wish to. Legal departments will be concerned about exposure and liability, HR departments will be concerned about negative publicity and brand protection and operations will be concerned about additional debits on the inspection that may lead to lower scores, loss of customers and sales, loss of performance bonus and other tangible negative consequences. It's unfortunate because voluntary disclosure is a noble ideal and inspectors and operators should be partners with a common purpose; protecting the health of the public. The conversation should remain open in the hopes that a workable protocol can be developed for voluntary disclosure without recrimination.