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Friday, 17 May 2013

The “C-Trend”- Evolution of Inspections and Audits in the Food Industry

Never mind the purported sophistication of the so-called modern day food inspection and auditing programs, the old ways have not gone away. With respect to food fraud, food safety infractions and quality failure incidents, the food industry is sadly stuck in the “catch-and-punish” mode. By now, the industry ought to have moved beyond this archaic model for ensuring good practices and system improvements.

One way to look at this is how audits and audit schemes have developed from spot-checks to the highly formalized and universally applied auditing systems or schemes. Another way is to consider the evolution of audits along the lines of documented programs. The trend presumably starts with simply verifying that facilities have documented programs. This moves to the phase of verifying the consistency of maintaining the documented programs. Finally, the highest level along this evolution line is the verification that facilities are able to legitimately or legally prove that they have documented programs that are consistently implemented and/or maintained with supporting records. The typical catch phrase that goes with the documented programs evolution is: “Say what you do, do what you say and prove it.”

A slightly different direction is taken in this post. I chose to call this the C-trend. Incidentally, the different development phases, from the somewhat primitive spot-checks to the highly sophisticated schemes, or from simply having documented programs to proving the consistent implementation, also show elements of the C-trend evolution. An overarching question is whether the old ways are gone even with the highly sophisticated schemes.

Catching the Deviants (or the ambush mentality of unannounced auits)
Inspections and audits during the era of catching operators red-handed were highly charged affairs. The intentions were completely punitive and performance was on the basis of assessed compliance. This was the era when you could hear operators say: “The inspector is coming. Quick, clean that up! Hide that! Do this! Do that! Put that away until she or he is gone!” Operators were predominantly preoccupied with putting on good appearances to avoid punitive measures or fines. Have these ambush inspections and audits, and the putting on of good appearances by operators stopped?

Confusion of Standards
Then came the era of limited understanding, little to no training, lack of direction, uncertainty about roles and responsibilities, different sets of expectations (or “standards”) of “compliance”, et cetera. This era saw many questions: “Why is regulatory inspection not enough?”; “Should we initiate audits or wait until the customers ask for them?”; “Why are we audited so many times and against so many standards?”; “Which is the best standard?” One is hard pressed to say that this confusion stopped.

Coercion of Compliance (Customer-demanded audits [announced or unannounced])
With the customer acting as king, this era saw audits and inspections dictated by customers. Consumers were simply viewed as opportunities for business and growth of profit margins. Auditing schemes, frequencies, inspection and audit services providers, auditors, acceptable scores or ratings were all dictated. Again, one is hard pressed to say that this coercion has stopped.

Cooperation of Parties (regulatory agencies, third parties, customers and suppliers)
Amidst an unmistakable pretentiousness, an era existed when customers, suppliers, regulatory inspectors and third party audit providers appeared to have cooperated. This was the era when private interests drove the cooperation and loyalty was fickle. Regulatory inspectors were willing to cooperate for as long as their jobs were preserved and the political interests or other agendas of the regulatory policy makers were satisfied. Customers were willing to cooperate for as long as their brands were protected. Suppliers were willing to cooperate for as long as they were able to continue selling to the demanding customers. Third party audit providers were willing to cooperate with their clients (customers) and the audited suppliers for as long as such cooperation continued to generate revenue. Meanwhile, the protection of consumers merited little more than a pretentious fore and after-thought. One wonders if pretentious cooperation has been completely eliminated from all inspection and auditing arrangements.  
Collaboration of Entire Chain for effective consumer and brand protection (the GCSE-FHP SSQA era)
This represents a quantum leap to the future. It eliminates the ambush mentality, confusion, coercion and pretentious cooperation. Consumers are not relegated to the sidelines. Inspection ratings and audit scores do not matter as much as the actual derived effect of consumer protection. Private interests are not abandoned. The respective interests of the collaborating parties are considered legitimate but they are not the driving force for loyalty to the collaborative efforts. They are pursued as the desired outcomes such that even if these interests are not immediately realized, loyalties to the collaborative efforts remain strong. The highly developed inspection and auditing guidelines are also not abandoned. Instead, they are better positioned and utilized. Existing guidelines contain sufficient details so as to play a significant role in true consumer protection. Fraudulent tendencies are busted through the genuine collaboration of the entire chain in the SSQA era.
To learn more about the SSQA program, you may visit these posts:

Posted by Felix Amiri
Felix Amiri is currently the chair of GCSE-Food & Health Protection. He is also the Director of Technical Services at Amiri Food Industry Support Services (AFISS) and the Canada/U.S representative for the World Food Safety Organisation.

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