Julia Stewart:
Hello, this is PMA PR Director Julia Stewart, and welcome back to PMA’s audio blog, “Ask Dr. Bob.” Chief Science Officer Dr. Bob Whitaker has been discussing in recent posts the various aspects of building a food safety culture, and challenging the industry to look at food safety from a different perspective.

Bob, I know you get asked frequently about the ins and outs of product testing. How does product testing fit into the food safety culture you’ve been describing? What are the pros and cons?

Bob Whitaker:
Julia, we could have a whole host of posts on the positives and negatives, and the do’s and don’ts, of product testing and what it all means. But the top line is that you need to look at the uses for testing in your operations and consider how testing helps you manage risks.  Understand that testing is only a tool; you cannot test your way to food safety.  Unless you have the proper risk assessment and risk management practices in place and working properly, testing is meaningless.

These days, we are confronted with the need to test water, soil amendments, process environments, equipment surfaces and even seeds.  You need to look at how these efforts relate to your risk assessment and risk management goals, and then determine whether testing these factors will help you manage the risk better or if the tests will help verify the effectiveness of a process.  Similarly, in the last few years pressure to test raw and finished products has increased.  Again, you must understand what these tests can and cannot tell you, and work with your customers to develop the smartest testing program; one that helps you manage potential risks, and one that gives them greater confidence in that risk management program.

Know also that testing can get expensive. I have seen instances where meeting certain testing requirements can add as much as a dollar in costs to a box. Buyers and sellers have to ask themselves if that is the best use of their money to improve food safety. Regardless of where you stand on testing today, one thing is certain: testing methodologies have improved dramatically over the last few years, and research is being conducted now that should help us develop more statistically significant sampling programs. Eventually, costs will equilibrate and accuracy and significance will improve, and that can only help our industry in the future.

We also talked about testing in a post we made last year, on June 10, 2008 – I invite our listeners to check it out for more discussion on the limitations of product testing.

Julia:
Thank you, Bob. I think there’s definitely a perception out there that testing ensures safe product, when we know that trying to find some of these pathogens is like trying to find a needle in a haystack. This is an important topic our members should consider as they work to continuously improve their food safety programs.

Thanks very much to our listeners, please join us again next time!

Julia Stewart:

Hello, this is PMA PR Director Julia Stewart, and welcome back to PMA’s audio blog, “Ask Dr. Bob.” PMA’s Chief Science Officer Dr. Bob Whitaker has been discussing in recent posts the various aspects of building a food safety culture and challenging the industry to look at food safety from a different perspective.

Bob, I know you get asked about audits a lot. What is the role of audits in a food safety program and how do audits fit into the comprehensive culture you’ve been discussing?

Bob Whitaker:

Julia, as I have referenced in previous posts, sometimes the food safety discussion in our industry is over shadowed or somehow equated with discussions on what audits are best and how many we have to do.  While I understand the frustration many producers feel regarding the multiplicity of audits they are asked to endure, this all-consuming furor over food safety audits is unfortunate because  audits are only a tool; a snapshot in time, actually a snapshot in time that you get to pose for. Realistically, taking an audit is like taking an exam when you know when the exam will be scheduled, you already know all the questions that will be on the exam, and you already have all the answers too. How many of us wouldn’t want to have had that situation back in high school or college?  I am guessing we might have made better grades!

Minimally, food safety audits are a mechanism to demonstrate to yourself, senior management and customers that you are following your food safety program, and that you can verify it through your audit that day.  At their best, food safety audits are excellent training opportunities for employees. Audits offer a chance to have an independent set of eyes critique your program, and are a time when you can step back from all other responsibilities and critically look at your food safety program and how it is being implemented… it can be an important learning experience. 

Julia, you’ve heard me say before that risk assessments and risk management are key to an effective food safety program. Audits won’t ever take the place of conducting a comprehensive risk assessment and then designing risk avoidance and risk management programs to respond to that audit. Audits won’t ever take the place of having a corporate-wide food safety culture, 24 hours a day, 7 days a week, 365 days a year. 

As discussed earlier, there is a change going on right now in the United States on how audits are viewed.  Food safety crises like the Peanut Corporation of America incident have called to light issues regarding third party certification.   Today there is a great deal of attention being paid to the use of globally benchmarked standards and third party auditor accreditation.  Benchmarking can be a useful means to drive harmonization of food safety standards,  so long as it does not lead to everyone moving to a least common denominator as a food safety or audit standard.  Many have pointed out that there is already a great deal of commonality in the content of existing food safety standards, and my experience in the industry tells me that is largely true.  Perhaps what we really need is the recognition of equivalency between various audits and standards by buying groups, thereby giving producers an array of food safety schemes to choose from – and eliminating some of the redundancy where multiple audits covering the same basic content are required.  If the various standards and audit checklists could be recognized as equivalent, suppliers could chose a third party and standard or scheme based on relevance to their operations, service quality and price, and then supply those results to their buying partners for verification of their food safety programs.  It seems that the real culprit that leads to frustration from the supply side is variability in how food safety audits are executed and standards are interpreted.  FDA has issued guidance on conducting third party certification audits and many third parties have adopted globally recognized ISO 65 accreditation – this provides a roadmap for certifiers that covers everything from auditor qualifications and training to corrective actions procedures and conflict resolution systems, to help bring about standardized and measurable performance in their operations.  This might offer a good solution to the variability the industry has seen over the last 10 years, and ease some of the frustration.  

Julia:

Thank you, Bob. I know our members are looking for relief from the current environment of audit fatigue. Now you’re helping us understand ways to overhaul the system that’s resulted in audit proliferation,  but more importantly you’re helping us to understand where audits properly fit within a food safety program – they are one element, but they aren’t the be-all and end-all.

Thanks very much to our listeners, please join us again next time!

Julia Stewart:

Hello, this is PMA PR Director Julia Stewart, and welcome back to PMA’s audio blog, “Ask Dr. Bob.” Chief Science Officer Dr. Bob Whitaker is joining me again to discuss various aspects of building a food safety culture. 

Bob, you’ve said earlier that some food safety programs just make companies good at being audited – they don’t have true food safety programs that respond to risk and contribute to a food safety competency. How do we alter our discussion to go from audits to risk assessment?

Bob Whitaker:

Julia, food safety is about risk assessment and risk management. We are all risk assessors and managers in our daily lives, whether we do so consciously or subconsciously. We routinely evaluate the risks associated with everything we do and then we take precautions to manage those risks.  For example, when we cross the street, we check to be sure no cars are coming; when we drive a car, we be sure it is in good working order, the brakes work, its full of gas and we obey (at least most of the time) traffic rules and regulations to minimize our risk of an accident.  When it comes to produce food safety, it is important to be sure our food safety programs are similarly risk based.  Simply developing a food safety program that supplies the paperwork required by whatever auditor is being employed does not address the food safety needs of your company. 

Doing a risk assessment does not have to be hard.  Start out by making a simply line drawing.  If you are a grower begin at the point you select the land you intend to grow a crop on through land preparation, planting, growing, harvesting, cooling, right up to the point where you no longer control the fate of the crop.  Processors, transportation companies, distribution centers, and any other handlers can follow the same process picking up where they impact the produce supply chain. It is important for all those who handle our produce to understand the risks associated with their place in the supply chain and adopt risk management strategies to minimize those risks.

As you perform your risk assessments, reach out to all the experts who are available to you for their expert advice and input on the risks you should be considering, and how to manage them effectively. You already have lots of experts within your own organization. Who knows your operations better than the people who work for you?  You have to step up and take responsibility for preparing your company’s food safety program.  Too often I hear growers and processors say “just tell me what I have to do and that’s what I’ll do for my food safety program”.  How can anyone else possibly know your operations and therefore your risk profile better than you?  In any produce company I have ever been around, there is always at least one guy who knows more about his growers and their practices than anyone else. There are also usually harvest and process guys who have incredible knowledge of what they do and why.

Use these people, combining them as you need to with those who have the technical knowledge to understand the microbial, chemical or physical risk implications of those practices.  Once these people start talking, I guarantee you that you can build an effective risk management system and practices that mitigate risk…and best of all, your employees will own those practices, because they had a hand in developing them.

Julia:

Thank you, Bob. Once again you’ve helped us look at food safety from a different perspective.

Thanks very much to our listeners, please join us again next time!