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

    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?

    Bob:
    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.  

    Julia
    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.

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