- The idea is confusing to many people. Therefore the concept is ignored or incorrectly applied.
- Validation is not sufficiently done where it matters and wrongly applied where it does not fit.
A grievous mistake that continues to captivate many food safety management and assessment approaches is the after-the-fact syndrome. The food safety management and assessment industry appears to be pre-occupied with seeking solutions and conducting so-called validation exercises after buildings are completed and systems are established. This syndrome is why most certification and non-certification audits are conducted after everything is in place and the operations have been running for a while. A wrong approach indeed. The usual argument is that sufficient operating records need to be accumulated for auditors to see.
Closely related to the "everything in place before audits" is waiting to conduct after-the-fact testing of end products. There appears to be an assumption that safety or quality can be tested into finished goods. John Hunter, in his November 8, 2012 blog wrote: “Inspection does not improve the quality, nor guarantee quality. Inspection is too late. The quality, good or bad, is already in the product. As Harold F. Dodge said: ‘You cannot inspect quality into a product.’”
No Exemptions in the Validation Process
Examples abound of where ignoring the validation process is generally accepted in food safety management. For want of a better description, let’s call this the “committee of experts exemption”. This kind of exemption is driven by the misconception that if a committee of food safety experts comes up with suggested proposals or solutions, the suggested proposals or solutions are automatically valid and are exempt from further assessment to confirm their validity in ensuring the safety of food. The use of food auditing schemes appears to belong in this category of “beyond validation” activities (or validation untouchables). How do you validate your current food safety auditing program? How do you measure this against what it is expected to address – which is the actual safety of food? Do you have quantitative data to support the gains you have made in the actual production of safe food since enrolling in your auditing program and because of it? This validation of the audit program must not be ignored.