I believe we can do better and, thankfully, I am not alone. Many people have raised this issue. Richard F. Stier is one of these people . You may read his article on the Food Safety Magazine website. A link to the article is provided at the end of this post.
Well developed internal audit programs may be the solution to a lot of the issues facing the industry. The issues include: auditors and consultants conflict of interest; litigation against third parties; complications of the touted "command and control" provisions; imposition of convoluted cookie-cutter sets of requirements; confusion of audited parties about why they are subjected to subjective, constantly changing and a growing varieties of audit rules; insufficient time for the completion of thorough audits due to cost concerns; forced dishonesty of audited parties because of the pass-fail and critical business decision considerations that are associated with the audits; less than impressive results in the reduction of product safety issues in the marketplace; etc.
- Internal audits are legally safer for auditors
- Internal audits tend to be more professionally fulfilling (because results achieved against the ultimate goals for the operation are more readily visible)
- External audits are conducted against externally developed and generic set of requirements;
- Internal audits are against internally determined and more realistic (real to the operation) set of requirements
- Internal audits have more time availability than external audits, and can be conducted throughout the year
- Internal audits provided greater opportunities for deep-dive assessment of deviating instances
- Unlike external audits that are based on pre-determined sets of requirements, internal audits are designed to have surgical precision, using the modulated audit plan approach and mostly looking with greater intensity at areas where the operation needs improvement.
The present market place is replete with quack consultants and audit service providers who have capitalized on the status quo. They also dupe unsuspecting clients. Taking advantage of natural progression of things, outside parties capitalize on the fact that most businesses naturally progress by default. Businesses naturally improve their systems, programs and strategies. These may be in the form of increased communication with employees or employee training, better documentation of programs, record-keeping and filing systems that permit ready-access to records, better operation controls, improved work supervision strategies, etc. Since pursuing such improvements is the natural tendency of operations, it is unfair for outside parties to take credit for them simply because they asked some audit questions. With the “conflict of interest” rules that are normally associated with third-party audits, the auditors cannot advice the operations about how to proceed with these improvements. Therefore, it is fraudulent for the auditor to take credit for the improvements.
Based on these facts, any claim by any external party conducting external audits based on externally developed scheme that it has helped you to prevent recalls is bogus. Your company must roll up its sleeves to prevent recalls.
Fitting Shape to Shape
A dynamic system such as the food safety and quality assurance system that is ever-changing due to numerous variables requires a dynamic assessment approach. This can be most reasonably achieved through internal audits. Only in an internal audit environment can the many variables governing food safety and quality assurance be studied and effectively addressed. The unique dynamism within an operation cannot be effectively addressed by so-called standardized audits that are, by nature, generic with typically fixated sets of requirements. Standardized snapshot audits tend to provide a bulk of information that becomes obsolete as soon as the assessment is completed. Hence the phrase: "at the time of this audit" is frequently found or implied in generic audit reports. Audits need to be designed or (shaped) to fit the dynamic systems that they evaluate.
Posted by Felix Amiri