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Friday, 29 November 2013

Food Safety Audits - Observations to ignore, admit or contest:

In the blog by Petrie-Flom Center of Harvard Law School, posted on December 5, 2013, following the deadly Listeria outbreak linked to cantaloupes, Ching-Fu Lin observed as follows:
“ . . . Many commentators have pointed out the problematic agency-client relationship between the third-party auditing firm and the company to be inspected.  As the company to be audited selects the auditor and pays the certification fees, and numerous auditors are competing for clients, it is rational to expect that auditing firms would cut corners instead of living up to the highest safety standards.  There is, in effect, a race to the bottom due to a conflict of interests. . . . Third-party audits and certification have numerous merits in constructing a food safety regulatory framework based on supply chain control and prevention, but they also face serious challenges that may undermine the overall effectiveness. . . .”
Do you agree or disagree, in part or completely?
Should the food safety auditing community ignore these observations, admit they are true or provide a defense?
In the concluding part of the March 5, 2009 New York Times article, Michael Moss and Andrew Martin made this statement:
“Food safety advocates say that audits can play a useful role in improving sanitation and catching problems. But in case after case, the audits have failed to prevent major outbreaks.”

Earlier on in the article Mr. Moss and Mr. Martin stated:

“An examination of the largest food poisoning outbreaks in recent years — in products as varied as spinach, pet food, and a children’s snack, Veggie Booty — show that auditors failed to detect problems at plants whose contaminated products later sickened consumers.”

How would you respond to Mr. Moss and Mr. Martin and why? Are things better today than they were in 2009? Do we have any evidence today to counter what Michael Moss, Andrew Martin and others have observed?

In considering this question you should also read the following:

The Insider Critique of Private Food Audits  written by Mark Jarvis, CEO at Steritech and the Audit Critique by Martin Bucknavage. Mr. Bucknavage is a member of the Department of Food Science at Pennsylvania State UniversityLink Update, July 25, 2014: Unfortunately, the "usefulness of private audits" link to these critiques provided on page 2 of  the  the New York Times article appears to have become broken. You may go to the main New York Times article hereFood Problems Elude Private Inspectors -

Another Insider observation/Opinion:

Any connections to Food Safety Modernization Initiatives?

How likely was it that some FSMA policy makers read this New York Times article and other comments like the Mark Jarvis’ insider critique? How likely was it that their thinking was influenced concerning third party audits as a result of reading these comments? For example, in relation to the insider critique points about “auditor competency” and the “predominant model in third party auditing”, how do you think the policy makers might have responded? Could these statements and observation have had anything to do with the FSMA Proposed Rule on Accreditation of Third-Party Auditors? Could they have had any part in the proposal by FDA to specifically require its separate recognition of third party audit companies and accreditation of third party auditors?

There seems to be FDA’s reluctance to outright accept the equivalency of third party certifications under the Foreign Supplier Verification Programs. Why do you think this is the case? Did the 2009 New York Times article and similar comments elsewhere have any influence in these matters? Could other food safety modernization initiatives elsewhere be similarly influenced by these comments? Could regulatory policy makers have been influenced, NO, should regulatory policy makers proceed cautiously with accepting third party certification schemes due to the continuing avalanche of recalls that affect food operations claiming to have been "certified"?

Posted By Felix Amiri
Felix Amiri is the current Food Sector Chair of GCSE-Food & Health Protection

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