Third-party audits and food safety - Part III: The role of the auditor and the difference between certification and accreditation

A thorough and probing certification process can only be led by auditors with in-depth knowledge and sector-specific expertise, and who are able to help organisations minimise risks, improve systems and processes and deliver confidence for stakeholders throughout the food supply chain.

Martin Bucknavage, member of the Department of Food Science at Pennsylvania State University, reviewed two of the audits conducted at the Georgia Peanut Factory plant (see Part 1). His findings included:

• Manufacturers need to be more critical of audits, including determining “What are the credentials of the auditor?” and
• “Are they familiar with the type of processing operation they are auditing?” and finally
• “Did they evaluate all of the risks associated with that type of operation and the type of product they make in performing the audit?” 

The integrity of the audits and the integrity of the certificate are of the utmost importance. As Cor Groenveld, Global Product Manager Food Services at LRQA, recently commented; “Firstly, I truly believe that these can only be delivered by a trained auditor who knows audit skills but also who knows the sector. I think that this is often a weak spot and we have seen too often with other companies in other certification bodies that auditors do not have enough knowledge of the sector they are auditing, so making sure that the auditor has that knowledge is crucial - that is a starting point.”

The second thing that is really important is that an auditor has to ensure that he really looks in depth at the corporate objectives and strategies and understands the vision of the company. From there the auditor needs to find out what are the real risks in the organisation and the processes and try to focus on these risks. It has to be a risk-based approach, which is the only way that an auditor can do an effective audit. Essentially an effective auditor needs to be ‘bilingual’ - they need to be able to speak the language of the shop floor as well as that of the board room to achieve a complete understand of an organisation.

Thirdly, the certification process has to be linked to driving improvement. Again, the technical expertise of the auditor and the certification has to support the company to drive continuous improvement. An auditor can challenge the organisation, without being a consultant of course, and support the organisation by doing a robust and in-depth audit.

Finally, and with criticism being levied at the auditing process that sparked the cantaloupe Listeria outbreak last year, the point needs to be made that what happened at Jensen Farms was a second-party audit. There is widespread lack of understanding on the difference between a second-party and a third-party audit. The official definition according to the International Register of Certified Auditors (IRCA) is that a 2nd Party Audit relates to audits of contractors/suppliers undertaken by or on behalf of a purchasing organisation. IRCA goes on to define 3rd Party Audits as audits of organisations undertaken by an independent certification body or registrar or similar third-party organisation.

What happened at Jensen Farms was not a third-party assessment but a second-party audit because it was done to a Primus standard, not a certification standard or scheme.

The role of certification

The responsibility for driving positive change across the food supply chain is not solely the responsibility of regulators, retailers and manufacturers. Certification bodies have a vital role to play in bringing confidence to the stakeholders of assessment and certification. With organisational objectives focused on delivering safe food, at LRQA we take our responsibility seriously as do many of our counterparts within the certification industry. We are actively driving change by putting in place the mechanisms to effectively train our existing assessors to ensure that their sector and technical expertise is maintained and enhanced. In parallel, we are continuing to invest in recruiting new assessors to ensure that we can meet the ‘stakeholder demands of tomorrow’.

But who governs the certification industry? Well, ISO/IEC 17021: 2011 - the standard for certification bodies - ensures that the regional or country-specific accreditation bodies assess the certification industry against a consistent standard.

It has also extended the competence requirements to encompass all staff engaged in the certification process. ISO/ IEC 17021 has clear benefits for certification bodies that are looking to set themselves apart through their transparency, expertise and independence. For these reasons ISO/IEC 17021 offers tangible, consistent benefits that translate into increased trust and confidence for all stakeholder groups.

In parallel, there are many legislative controls in countries throughout the world that add another layer of protection for consumers in terms of regulating the food supply chain. Yuri Cosco, from LRQA, explained further: “In Belgium, we have a system which is called Self Checking Guides, which is government regulated. The different food sectors can set up guidelines that have to be used as a basis for the Food Safety Management System of the companies in the sector. The government then authorises Certification Bodies (CBs) (after accreditation and the necessary paperwork) to audit the companies with the specific guide as a basis. There are several advantages for the companies:

• Financial incentive
• Fewer government audits
• For some sectors, it facilitates export

“This approach means that the government then can focus on companies that are not assessed by CBs and that are thus considered as higher risk.

“The government has already done studies that point out that companies having a certified system have fewer nonconformities from the government during official inspections.”

Influential organisations in food are helping to position food safety management systems firmly on the corporate and regulatory agenda. LRQA’s key alliances with organisations such as the GFSI and the Foundation for Food Safety will deliver added value to clients through technical insight and enable us, along with other major certification bodies, to extend their sphere of influence. Referring to the calls by the FDA for reforms to third-party auditing, Vel Pillay, Food Safety Programme Manager LRQA Americas, made an insightful remark: “There is a general lack of understanding in the difference between certification and accreditation. If we take the FDA as an example: initially, the FDA indicated that they wanted to become a certification body to grant certification to third-party auditors or audit body. They since have changed their statement to becoming an accreditation body to certify third-party auditors and audit bodies. Fortunately, there is a group of very powerful people from the industry currently working with FDA to educate them on the role of audit bodies and, as the FDA does not have the resources to inspect all food manufacturing institutions, this may be a way of getting more resources from the government akin to the Belgium model.” Commenting further on the calls for reform, Cor Groenveld, said: “Using GSFI recognised certification delivered by licensed and accredited certification bodies is the way forward.

“Although certification will never be a guarantee things will not go wrong, the controls put in place by using GFSI and accreditation enlarges the level of integrity of the audits themselves and in turn the certification.”

Conclusion

At LRQA, we believe that the auditing processes, which were essentially checklist driven, coupled with the alleged lack of relevant experience of the auditor, were complicit in producing a less than effective report. This approach contributed indirectly to both the 2009 Peanut Factory crisis, as well as the 2011 Jensen Farms crisis. The systems and processes of both organisations were clearly ineffective. A robust assessment approach, one that looked at their systems and processes, embedded continual improvement as a fundamental component and featured a risk-based methodology, would certainly have mitigated the risks to all of the stakeholders of both organisations to a greater extent, including, most importantly, the consumers whose lives and health were put at risk.

LRQA have proactively worked with food safety stakeholders, including manufacturers, retailers, suppliers and industry experts, to move the food sector away from a checklist-based approach to auditing towards a process-based management systems approach. This approach looks at the underlying systems and processes that organisations have in place rather than the ability of that plant or factory to convince an auditor on a given day that they comply with a series of items on a checklist. It is not enough to have a strong standard or scheme, organisations need registrars or certification bodies that:

• offer auditors that have extensive experience and proven competence in the sectors they are auditing in,
• can provide a robust process-based management systems approach to auditing,
• stand up to the client when nonconformities are found, and finally,
• help the organisations being audited to reduce risks, improve food safety performance and link their food safety management systems objectives to their overall corporate objectives.

What is clear is that organisations across the food supply chain, including some of the world’s leading manufacturers and retailers, are increasingly recognising the benefits of independent assessment and certification, not only in terms of the cost savings, but also in terms of the benefits and value it brings. Those organisations that are prioritising potential auditor CVs and certification body methodologies and credentials, rather than focusing on price, have clearly understood what is at stake. This approach is helping to drive consumer and other key stakeholder confidence as well as ultimately helping to safeguard the lives of people around the world. On the road to food safety, this can only be seen as a positive step.

This is the third part of a three-part article. See also Part I and Part II.