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    How to choose a food safety auditor – Critical Characteristic 4, Handling Data

    Tuesday, July 20th, 2010

    Julia Stewart:
    Hello, this is PMA PR Director Julia Stewart, and welcome back to PMA’s audio blog, “Ask Dr. Bob” where we’ve been talking with PMA’s Chief Science & Technology Officer Dr. Bob Whitaker about the critical characteristics to consider when choosing a food safety auditor.

    Ok, Bob, we’re in the home stretch on this series so tell us what we need to know about the last of the four critical characteristics, data handling. 

    Julia, data handling is not always so obvious when thinking about food safety auditing, but is becoming increasingly important. Almost every food safety standard I know of requires keeping significant amounts of data available for inspection by third party or government auditors.  Keeping this data demonstrates that you measure and verify your food safety program daily. And, if a customer, partner, or regulator asks to see your food safety program, you need an efficient way to show them that data. 

    What do I mean by “data”?  Well, data includes your food safety audits, and any microbial testing you do of water supply, equipment sanitation testing, environmental testing, or product testing.  Pre-plant risk assessments, pre-harvest risk assessments, or internal audits or inspections you might perform are data. You can extend this out to include verification records, farm or ranch maps, SOP’s — as far as you want to go.

    So, a legitimate question to ask an auditor is about the systems they have for handling data. Some have very sophisticated systems, others do not.  You may want to use a specific vendor of your choosing for data handling or build your own data handling system; that’s your choice, but you should have a data handling system.

    What characteristics are important in any good food safety data handling system?  Are there specific attributes growers and processors need to consider?

    Well, I’m not a computer techie so I’d advise the listeners to check with an IT expert to be sure the system has all the security and back-ups needed to protect data integrity, and to make sure that it is easy to use and move around in.  Then, you can consider a few other things:

    First, you need to have a system that permits you to store your food safety data in an organized fashion.  You want to be able to access your audits or microbial data easily by either time or location.

    Second, ideally you’d like to give your customers access to the data using a password protected mechanism.  Being able to share your data with customers is an absolute must these days, so they can understand your strengths and how you address any deficiencies via corrective actions.  If your customer needs to have the data electronically transferred, you want your auditor’s or your own system to be able to accomplish this transfer automatically and efficiently.

    Third, the best data systems will permit you to use your data.  That sounds intuitively obvious, but I don’t think many in our industry actually use the data they have to their best advantage. Far too many of us have an audit or microbiology tests done and we look at them, make sure they are alright and then file them away. If designed properly, a data base system should permit you to sort through data and identify trends. It’s also useful to be able to automatically create graphics based on microbiology results from sanitation swabs so that you can identify equipment requiring additional care, or improved practices for effective sanitation. There are a number of potential benefits from using data to identify trends.

    Last, there are increasingly new technologies out there today and you want a data system that can use these technologies as appropriate for your needs.  For instance, GPS-based graphics that can access satellite maps of your farm or ranch and can be tied into food safety data are not only useful for you as an operator but are nice to present to customers and regulators.
    Bob, this brings to a close this series on choosing a third party auditor.  Is there any last piece of advice you would like to leave our listeners with?

    You know, food safety audits continue to be a flawed but necessary tool in our food safety programs.  Selecting a good third party auditing company that matches your food safety needs, or developing a positive working relationship with the third party your customer mandates can only help improve your company’s performance. It is your responsibility to make sure you maximize the value you get from your audits.

    Thank you, Bob. You have certainly outlined the importance and benefit of choosing an auditor with care and purpose, and once again you’ve got us thinking in a completely different way.

    Thanks very much for listening, this concludes our series on choosing an auditor. If you would like to submit a question for Dr. Bob to cover in a future blog post, you can email him at askdrbob@pma.com

    Until next time!

    How to choose a food safety auditor - Critical Characteristic 3: Corrective Action Opportunities

    Tuesday, July 13th, 2010

    Julia Stewart:
    Hello, this is PMA PR Director Julia Stewart, and welcome back to PMA’s audio blog, “Ask Dr. Bob” with PMA’s Chief Science & Technology Officer Dr. Bob Whitaker. Bob, on our last post you talked about the real value in the corrective actions process and suggested that there are real opportunities for an operation. What are those opportunities?

    First off, corrective action is an opportunity for the audited operation to improve its food safety program.  Spend some time and go through the deficiencies list and the auditor’s observations.  Ask what you can do to address the deficiency and make sure you understand the issue. Call the auditor to get a clarification if necessary. Reach out to experts, local agricultural extension, commodity boards, trade associations or even fellow producers to get help. In this search for information, don’t forget your internal experts. Preparing corrective actions is an excellent opportunity to gather input and teach.  Use your production personnel, quality assurance staff, human resources supervisor, and anyone else in your organization with knowledge of your food safety program.  Using a food safety “group approach” gives you greater creative input, provides an opportunity to reach out to employees on food safety, and gives them feedback on the audit itself. When corrective actions are developed together, it builds consensus and gives you greater reach inside your company to enforce the corrective actions you identify.

    Secondly, developing a written corrective actions plan provides your company with verification that you had an audit, identified issues, and then spent the time to earnestly address those issues.  From a company perspective, one of the worst things you can do is have an audit where a deficiency is uncovered and then not do anything about it. And, if you’re unfortunate to have a future food safety issue where your products are shown to cause public health issues, follow up investigations by regulators will uncover your earlier audits as part of the investigation. If you failed to address the deficiencies with written corrective actions, it may be perceived as negligence on your part and make a bad situation worse.

    Thirdly, a well developed corrective actions plan is a great way to demonstrate to customers, regulators and even your own employees that you are serious about your responsibility to deliver safe products every day. Should you encounter a regulatory inspection and they ask to see previous audits, you can not only show them the audit, but also your corrective actions. It creates a positive view of your company and the priority you place on food safety.  It also sends a message to your employees that you expect constant improvement on food safety issues and you are willing to make changes to accomplish it. 

    Lastly, the corrective actions process gives the audited entity an opportunity to respectfully disagree if you feel the auditor has been incorrect in evaluating your program.  At the end of the day, you know your operations best.  If you have done a risk assessment properly, addressed them with risk management practices, can demonstrate your management practices are effective, and that your employees understand how to implement your plan, then you have a basis for presenting a logical argument if you disagree with an auditor’s observation. Don’t get emotional — be logical, provide data, be timely and constructive. My personal experience is that third party auditors will listen and you can carry on a constructive, positive dialogue. Any good third party auditor is always looking to improve, understand their market better, and meet their client’s needs. In some cases, you may want to even consider including your customer in this discussion.  Again, a proactive, well thought out two- or three-way exchange will demonstrate your diligence in food safety to your customer and auditor, and also provide you with an opportunity to understand their perspectives as well.  

    So this is another area where building that relationship with your auditor is a good thing,

    Thanks Bob.  Again, you’ve helped us understand how to turn what could be a difficult situation into opportunity for learning and growth. Thanks for joining us, listeners. Next time we’ll cover the fourth and last critical characteristic of choosing a third party audit company.

    How to choose a food safety auditor – Critical Characteristic 3, Corrective Actions

    Tuesday, July 6th, 2010

    Julia Stewart:
    Hello, this is PMA PR Director Julia Stewart, and welcome back to PMA’s audio blog, “Ask Dr. Bob” with PMA’s Chief Science & Technology Officer Dr. Bob Whitaker. We’re in the middle of a series of posts about choosing a food safety auditor.

    Bob, during all our discussions you have alluded to the importance of completing any audit with the development of corrective actions.   Can you detail what you mean by this for our listeners?

    Sure.  This is our third Critical Characteristic in choosing an auditor. Sometimes I think the corrective actions segment of the audit process may just be the most important element of the audit.  Unfortunately, I also think we tend to lose sight of it. In the context of selecting a third party auditing partner or in meeting with a third party designated by a customer, it is very important to understand what their process is for developing and submitting corrective actions following an audit.

    A good corrective actions process starts with an auditor exit interview the day the audit is conducted, and is not complete until you address with written corrective actions each area where deficiencies were identified. In terms of a third party auditor, look to see if they have a formal process for filing corrective actions. Their corrective action process indicates the audit firm’s depth and tells you as a customer of theirs that they recognize the value a good corrective actions program brings to you.

    At the end of an audit, you should be presented with a list of deficiencies or items that need further attention.  You will likely get an informal list of issues at the exit interview with your auditor immediately following your audit, and then a more formal written audit report further listing deficiencies a few weeks later.  Unfortunately, I think many times, we tend to take the final audit report, check out the score, send it on to our customer and then file it away.  If we do that, we are missing a great opportunity to improve our food safety programs and communicate with our customers regarding the priority we place on food safety. 

    So you feel that there is real value in the corrective actions process and that a third party auditing company needs to provide its customers with a mechanism to prepare corrective actions after an the audit has been performed?

    Absolutely, Julia. Corrective actions development is actually a real opportunity for a producer to use that audit internally with your employees as a training tool and externally to communicate to your customer your focus on improving your food safety performance.

    Bob hold that thought there. Let’s delve into those opportunities of corrective actions in our next one.

    Thanks very much for listening in today.  If you would like to submit a question for Dr. Bob to cover in a future blog post, you can email him at askdrbob@pma.com.  And if you haven’t already signed up to receive Ask Dr. Bob posts by email, we invite you to do so today – just go to the home page of the blog and type your email address into the “subscribe” field you’ll find on the home page of the blog.

    Thanks for joining us, and see you next time!