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.

Saturday, 6 July 2013

Celebrating the Liberation of Food Safety & Quality System Auditing

The entire food industry may one day celebrate its liberation from the tyranny of the monotonous checklist and the strangle-hold of superficial compliance. You may very well be in the position to bring  your food business into this celebration sooner than you may be thinking at this moment.

Initially intended as a tool, a digression has occurred and several monotonous versions of the checklist are now slavishly used from audit to audit and from operation to operation. Checklists no longer serve, but are served by, the industry. The enslavement is further entrenched where dictatorial checklists are viewed as “standards”. 

With the growing popularity of their use under the guise of “level playing fields”, monotonous checklists have flooded the market to undermine the very notion of level playing field. Although the field can never be leveled, this notion of “leveling the field for all operations” is applauded in many circles but it remains a myth. There has never been, and there will never be a level playing field. Other than serving as an unfortunate distraction, having a level playing field is not even necessary. I fully understand that this may seem to pose a challenge to the whole idea of equity and fairness in certification programs. In reality, it poses no challenge. The real common ground that matters with respect to food safety and quality management (with or without certification) is the goal of assuring consumer safety and satisfaction. This, by default, provides the equitable and sufficient ground for the assessment of different operations. It also provides the correct frame of reference.

Internal audits are also in need of liberation from monotonous checklists. The hurdles in this instance are the window-dressing tendencies that must be abandoned.

The freedom sought for the industry entails using an alternative approach that makes sense. And you may be wondering what this alternative approach could be. The auditing community has always used what I am about to suggest. Before I get to that, let me stress that I am personally very fund of using checklists. In fact, I strongly recommend this practice but we must avoid a zombie-like use of counter-productive checklists. If we truly want audits to be effective, efficient and relevant, we must discontinue the use of monotonous checklists. These are easily recognizable.

Features of Monotonous Checklists

Some distinguishing features include the following:

1. Monotonous checklists attempt to exhaustively cover everything that has to do with food safety and quality management system;
2. They require all of the same elements to be reviewed during each audit;
3. Monotonous checklists have pre-set number of elements for review from operation to operation;
4. They tend to focus on “compliance” and some contain stated criteria for assessing compliance or non-compliance; (side note: audit compliance is often mistaken for consistent commitment).

5. In some instances, the checklists have governing guidelines which are essentially the expanded explanations of the listed elements and the compliance criteria. They seldom include specific  instructions about the actual controls to be implemented on the food processing or manufacturing floor for ensuring the safety and quality of food with real-time confirmation of desired outcomes. 

Scheme owners attempt to revise audit checklists and guidelines from time to time. The attempts, in many cases, amount to no more than the re-naming, re-numbering, or re-grouping of previously stated requirements.

Occasional revolts against the monotonous checklist also occur in the auditing world to cause other forms of mediocre reaction. Yet, the monotonous checklist remains a tyrant. The revolts have been in the forms of complaints from small companies who say they are too small for the elaborate audits. A more general revolt is against the cost of audits, particularly in terms of time requirements and the associated fees. Some partial responses to these complaints include provisions like: The GFSI Global Markets Capacity Building Programme and Protocol; the SALSA Audit Scheme;  the BRC enrolment programme, and other forms of express audits or preliminary assessment arrangements. Almost all of these attempts are made without relinquishing the use of monotonous checklists or some compromised formats of the same checklists. The attempts also do not forego the ulterior motives of drawing operations to enlist in the supposedly "higher" level programs that ensure greater profit for the scheme owners.

Why does the industry need non-monotonous checklists?
Let us start with some undeniable facts. Every audited system is expected to change for the better – i.e. continuously improve. Situations are predictably different from day to day, from operation to operation and from audit to audit. With so many desired, predicted and anticipated changes, it only makes sense to have matching assessment tools. Using a tool that lags behind changes within the system assessed is unproductive to say the least. For example, a checklist used to ensure the proper construction, development and establishment of an operation is very likely to become an obsolete assessment tool when the operation is fully constructed, developed and established. A checklist that assesses the consistency of running and managing the operation as intended will be more relevant. A checklist that probed if an operation had documented programs during an initial audit is likely to be an irrelevant checklist when the operation has fully documented programs during subsequent audits. A checklist that assesses the consistency of maintaining the documented programs will be more relevant. From one audit to another, the audited entity is expected to have improved. Continuing to assess the same acceptable things that do not change from audit to audit becomes a redundant enterprise.

How can checklists be made non-monotonous?
The redundancy and monotony of checklists can be eliminated by progressively moving with the times for each operation, and from one audit to another. This can be done with considerations given to advances made within the operation, tracked incident trends, emerging situations, new regulations, new published research, new information pertaining to the industry, recent occurrences within the industry, recent occurrences within the operation, etc. Non-monotonous checklists are essentially “Live Checklists”. A simple type is the audit agenda. Instead of covering only a sketch of what is to be covered during the audit, the agenda could be expanded to cover in detail what is to be examined. This requires input from all parties involved in the audit and the scope of what is assessed is expected to vary from one audit to another depending on previous findings, emerging situations, tracked trends and other new information. 

The agenda checklist does not need to have pre-set criteria for assessing the level of compliance and there is essentially no need for an audit guideline. The operation's program manual should already have all of the criteria for compliance assessment and the experienced auditor should be sufficiently competent to determine the acceptability or non-acceptability of audit observations.

Non-monotonous audit checklists that are more highly developed than the agenda may be required for more complex operations. Irrespective of whether or not a third party is involved in the audit program, the decision on what checklist to use lies with the operation's audit team and company management. In cases where third parties are involved, the third party’s audit personnel are expected to work with the operation's audit team. In every case, a determined effort must be made to avoid redundancy and monotony.

Please feel free to share your comments or concerns about the thoughts expressed or suggestions provided in this post. With knowledgeable and caring individuals joining the conversation, we can become truly "free at last".

The strategy and guidelines for the development of non-monotonous audit process is one of the areas where the SSQA concept is well ahead of its time: What Are You Missing? 
Posted by Felix Amiri
Felix Amiri is currently the chair of GCSE-Food & Health Protection, and a sworn SSQA advocate.

No comments:

Post a Comment