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, as we were talking about in our previous post, we many times hear from growers and processors about their frustrations with some auditors. So, what can a grower or processor do if a “bad” auditor shows up to do an audit?
 
Bob:
Julia, first let’s put some perspective on this.  As in every occupation, there are people that are good at what they do and there are those that are not so good.  In the years I have been in the produce industry, I have been fortunate to work with a number of third party and government auditors who are professional, well trained and dedicated to doing a good job.  Indeed, I would say the overwhelming majority of the auditors I encountered really worked hard to do a good job. But, I have also seen the other side of the spectrum; the un-prepared, inexperienced, authoritarian types that can make an audit difficult and really bring very little value. 

Julia:
So what should a person do if a poorly prepared auditor arrives to audit their operation?

Bob:
There’s a real fine line here regarding what you can do.  But, there are a few things an operator needs to keep in mind:

First, understand that in reality an auditor needs to be a “little removed” or detached.  They are not there to be your friend.  They are there to be an impartial observer and evaluator of your food safety program.  They can only base their evaluation on what they see and on the documentation and data you present to verify you’re following your program every day. They can also assess your operational food safety performance by asking questions and using those answers to support their observations and your documentation.  You want an auditor that has this professional detachment because it will result in a more fair and unbiased assessment of your food safety status.

Second, previously we discussed the importance of the operator meeting with the third party prior to conducting an audit — whether you are the one selecting the auditing company or whether your customer is mandating a specific one.  If an operator can meet with the third party before hand to gain a better understanding of the auditor’s capabilities and expertise, I think you can reduce some of the frustrations of having a bad auditor.  The third party auditor will also come away from this discussion with a better understanding of your expectations and perhaps use this knowledge to assign an auditor that is ideally suited for your type of operation.

Third, I often tell growers and processors not to be a victim of their auditor.  Be an active participant in your audit.  Be professional and prepared.  Make sure you have a responsible party accompany the auditor, have your food safety documents available for review, and be able to answer questions.  Invest the time in your audit and make your own observations.  If you think the auditor gets off track, is argumentative, over-steps their bounds, or fails to understand an aspect of your program, politely and professionally ask for a clarification. If you cannot reach resolution, make sure the auditor understands you disagree and that you request further discussions on the issue with the auditor and their supervisor.  Sometimes, an auditor can even call a supervisor on the spot to get input and address your concerns immediately.    

Last, keep in mind that you are paying for this service.  If you are selecting a third party auditor to work with and you get an unqualified auditor, then you can terminate your relationship and interview other third party companies for future use.  If the audit company is mandated by a customer, I think you need to let your customer know of your dissatisfaction.  Nobody, however, is impressed with an emotional rant.  Document your issues with the auditor, provide your reasoning and any data that you have that supports your practices and why they are acceptable risk mitigation methods. Be professional.

Julia:
Thank you, Bob, for providing some clarification and suggestions for a very tricky situation. Listeners tune in next time when Bob will discuss the third important element in choosing a third party auditing partner, the corrective actions process.  See you then!

Julia Stewart:
Welcome back to our listeners to another installment in our series on how to select a food safety auditor. This is PMA PR Director Julia Stewart and during our previous sessions, Dr. Bob Whitaker, PMA’s Chief Science & Technology Officer has discussed the first characteristic of a good third party auditing partner: the auditor’s approach. Today, we are focusing on the second critical characteristic of a good auditor and that is their qualifications. Bob, what training and experience should a grower or processor look for in an auditor?

Bob:
 In the best case, a third party auditor, or for that fact a government auditor, should be knowledgeable about your product line and production practices, experienced in auditing your type of operation, and technically knowledgeable regarding food safety and its foundation technologies.  You want your auditor to be professional, respectful and efficient. 

If you are trying to select a third party or you are meeting with a third party company that has been mandated by a customer, it is important for you to ask about the auditors experience and the ongoing training programs a third party auditing company requires for their auditors.  We all know that our businesses have changed considerably in the last several years.  This is doubly true in food safety, so it is important that our auditors have current training.  If you were selecting a financial accounting firm to perform your yearly audit, you would want to know if their auditors have the proper education and are undergoing yearly IRS training to be sure they are competent and will do the best job for you and your investors.  Well, it’s the same when you are selecting a third party food safety auditing firm.  You are relying on them to give you a professional and informed assessment of your food safety program and it’s not just important to know their qualifications, it is your responsibility.

Julia:
Bob, I have seen this topic discussed in the context of “accreditation” and you’ve written comments to FDA on accreditation of third party auditors.  How does accreditation fit into looking at qualifications and as being a potential solution to inconsistent audit practices?

Bob:
You know, it might be part of the answer.  I am seeing a trend toward the use of accredited third parties for food safety auditing on a global basis.  This is certainly a pillar of the Global Food Safety Initiative or GFSI and the GlobalGAP benchmarking programs.  We also saw guidance issued by FDA last year on the operation of third party audits.  Auditor qualifications are just one aspect of third party accreditation.  At the heart of the issue on the proliferation of food safety audits has been the lack of confidence by buying groups that food safety auditors perform competently and consistently. 

How many times have we heard that the content of the audits is almost exactly the same, it’s how the audits are performed that is variable?  So, if accreditation means that all third parties and perhaps even government auditors have to meet specific criteria and receive training on a regular basis, and that the auditors are “audited” to be sure they perform up to expectations, then it will be a valuable component of a comprehensive food safety program.  Any tool that can bring consistency, and therefore confidence, for both buyers and suppliers, is a good thing.

Julia: 
Auditing the auditors that makes sense.

Thanks Bob.  We frequently hear about frustrations with some auditors and, in fact, you mentioned in an earlier post that “everybody has a bad auditor story”.  So, on our next post I’d love to hear your suggestions on how a grower or processor can deal with a ‘bad auditor’. We’ll look forward to that and to having our listeners back with us.

Thank you, and goodbye!

 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, in our last post you talked about the first characteristic of choosing an auditor – understanding their approach. Well, we have a follow-up question to that. Many times the producer doesn’t get to select the third party auditor; so what happens if your customer mandates a particular audit company who isn’t willing to spend the time and use a more holistic approach like you described?

Bob:
That’s a good question.  I know suppliers feel they need to fulfill the requirements of the buyers.  It’s the way our industry operates, but I would suggest that food safety is an over-arching issue; in other words, the safety of your product is YOUR responsibility and it’s in the best interests of your customer that the audit you both rely on as a tool to measure your food safety performance be conducted properly.

So, work with the third party first.  Talk to them.  Understand their expectations and clearly communicate yours to them. But, if you feel that you and the third party auditor are not on the same page, not working toward the same goals, call your customer that mandated this particular auditor and explain the issues. Talk to them about your desire to have a successful audit program that serves both of your interests, and that there seems to be a problem with the audit company. Ask for their assistance in talking to the auditor and request a conference call between the three of you to ensure you are all working toward the same objective.  I think most customers would welcome this type of proactive partnership toward ensuring the products you supply and they sell are as safe as they can be.

Julia:
I would think the customer would appreciate it. So does this same approach of engaging the third party auditor and the customer extend to the audit itself?

Bob:
You bet.  I’ll get into this in more detail when we speak about corrective actions, but the grower or processor being audited needs to be an active participant in the actual audit.  Make sure you have a responsible person accompany the auditor. 

Let me stop there.  Who is a responsible person?  Someone that knows the operation well and can answer any food safety question the auditor might have. And, this person must have access to the records required for verification, and be able to produce them for viewing by the auditor.

Be professional and polite — the same you expect from your auditor. Take notes on what you see during the inspection and document review so you can look at them later during the exit interview with the auditor and with your own internal food safety group. An open discussion of the audit with the auditor and your recommendations for corrective actions is an important piece of any auditing process, and permits you to have input into the process. It promotes a dialogue that will improve both your operations performance and the ability of the auditor to audit it effectively.

Julia: 
Well Bob once again you have us thinking differently about what the interaction should be between a produce supplier, a third party auditor, and even the customer.  Thank you.  We look forward to next time when we will discuss your second critical characteristic to consider when selecting a third party auditor. 

Remember listeners, you can email Dr. Bob at AskDrBob@pma.com
Thanks for joining us!