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Saturday, 14 October 2017

Unannounced Audits: A Needless Regression

Why is the industry going back to the past days of sneaking up on food operators to catch the deviants?

With all of the growing euphoria around unannounced audits and the fake sense of attainment, here is a reality check question: What will happen differently when operations fail to meet the stated requirements during the unannounced audits that is not already happening without them? This question needs to be examined from two perspectives: From the perspective of operations that can afford and have the setup for unannounced audits and from the perspective of operations that cannot afford and have inadequate setup for unannounced audits. Perhaps a third perspective can be added for an operation that can afford and has the setup for unannounced audits but sufficiently negligent to warrant unannounced audits. From each of these perspectives, what is likely to happen during unannounced audits that is not already happening during announced audits in terms of required follow up actions?
Proceeding with unannounced audits is a regression. In a food industry that claims to have attained higher levels of scrutiny, systems should have also developed to the point where the right things are done as a normalized routine. Incidentally, this normalized routine is the expectation behind the suggestion of unannounced audits. Only a small number of issues are expected to be found during unannounced audits. If only a few issues are expected, it is needless to have such audits. If, on the other hand, things have not developed to the point of expecting only a small number of issues, then it should already be known that significant issues will be found. In that case, unannounced audits are equally redundant.

Where the audited parties cannot be trusted and deemed to need unannounced audits, the battle is already lost. The untrustworthy parties cannot be trusted on the day following the conclusion of the unannounced audit. Keep in mind also that as soon as the auditor arrives, the audit is no longer unannounced. The auditor cannot physically and at once see everything, everywhere in the facility when he or she arrives. Those who cannot be trusted and must be caught red-handed are also predisposed to, and are adept at, cunning ways. They will have tricks that they can play even during unannounced audits. They can still put up appearances. On the other hand, if operations can be trusted because of their integrity and commitment to doing what is right at all times, it is a futile engagement to try to catch them red-handed. They do not need unannounced audits.
From all angles of view, unannounced audits do not represent progress. They are a needless regression.

The pursuit of unannounced audits debases the intelligence and level of commitment attained by many food operations, particularly the operations that can afford such audits. The already attained level can and needs to be further raised but it is certainly much higher than is portrayed by the suggestion of unannounced audits.
By the way, the notion of "being audit ready" leads to doing everything only for the audit and only within the narrow confines of stated requirements. Everything should instead be done to consistently ensure the safety and satisfaction of the consumer. With respect to all that must be done by every operation to protect the consumer, the typical audit (announced or unannounced) does not cover nearly enough scope, nor does it proceed with sufficient precision. Even the accuracy of the typical audit in detecting realistic concerns in every situation is, at best, questionable.

It is not disputed that current arrangements are in dire need of modification. However, the proposal of unannounced audits is regressive. If the food industry is to see substantial, meaningful and productive progress, audit proceedings need the infusion of a different kind of thinking. Audit proceedings need different methodologies and different criteria for assessing success or attainments than are currently pursued by different parties.
Posted by Felix Amiri

Felix Amiri is currently the chair of GCSE-Food & Health Protection, and a sworn SSQA advocate. 

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