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?

Bob:
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. 

Julia:
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?

Bob:
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.

Julia:
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!

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!