Food Manufacturing – December 2012: “Audit ‘Utopia’”

Third-party audits can provide great value in measuring the strengths and weaknesses of a facility’s food safety program. However, friction can occur between third-party auditor groups and pest management professionals regarding what should be checked and the appropriate measurement levels for the pest management portions of food safety audits. We also can find some inconsistencies between individual auditors where interpretation of the standards vary from one auditor to another.

How can we create audit perfection? The National Pest Management Association (NPMA) has reached out to third-party auditors in the past, and there are plans to repeat this process along with the release of the new 2013 revisions to the NPMA Food Plant Standards. Meetings such as these can provide a valuable opportunity to share concerns for the betterment of the standards used to measure pest management.

An Audit’s Purpose

The intent of the audit is to measure and identify what components are working well in the program as well as identify weaknesses. This certainly can provide value to the food facility being audited and the pest management company when well-designed and relevant standards are used. Recent trends in some of the audit standards, particularly the Global Food Safety Initiative (GFSI)-based standards, can also provide some additional benefits which support integrated pest management.

Under the GFSI audit-based inspections, food facilities can be held accountable for reacting to deficiencies reported by the pest management firm during service inspections. This is accomplished by using a corrective access process where the food facility assigns an individual the task of correcting the deficiency. From there, follow up is performed to ensure the corrections have been made. This approach can also help reduce the frustration that some pest management professionals may have felt in the past over not being able to get important sanitation or structural issues corrected.

Quality Reporting

The correction of sanitation and structural issues that impact pest problems is an essential part of integrated pest management. Keeping this in mind, pest management professionals must be very deliberate in what is reported under sanitation and structural issues. Reports must focus on sanitation, facility personnel behaviors or structural issues, which are either directly related to a current pest issue or are likely to result in a future pest problem. Therefore, cleaning the caked flour residue out of a piece of production equipment must get first priority when flour beetles are found in the area. However, a crack in the sprinkler room floor may be left unreported if no pests have been reported in the area. There may be a list of 30 items that can be written during any one inspection. However, the technician must continuously assess and prioritize issues in his or her reports based on the level of pest risk.

Taking Corrective Action

In addition to auditing the corrective action process under the GFSI audit schemes, the food facility may not be given a certificate unless the audit deficiencies are corrected. This provides additional motivation and support for correction. Under the non-GFSI-based audits, a passing score and certificate can be awarded without corrective actions being completed. A facility will be held accountable for correction under the GFSI based schemes, which will close the gap between discovery and correction.

There is also a new trend in holding auditors more accountable for their inspections and reports. Under the GFSI auditing system, the authorized audit groups are held accountable for their programs through independent GFSI oversight. GFSI certifies groups like Safe Quality Food Institute (SQF) and British Retail Consortium (BRC) to audit the GFSI schemes. This additional layer of oversight can lead to positive outcomes in terms of the overall quality of the audit.

New federal governmental oversight and accountability is also being provided, which has led to auditors being called on to testify as a result of major food borne illness outbreaks. Although there are concerns over holding auditors accountable for facility conditions that may not be present at the time of the audit, this notion can certainly influence the way an auditor accesses a facility. With the knowledge that he or she may be called upon to defend his or her audit in a court of law, facilities can come to expect a greater level of scrutiny.

Changes in the NPMA Food Plant Standards

The NPMA food plant standards were designed to help align the third-party audit standards, provide pest management expertise on audit requirements and provide guidance for pest management professionals on proper pest management in food plant facilities. Previous editions of the standards included a chart which could be used to determine rodent equipment spacing and frequency of service. This chart has now been removed in favor of greater allowance for professional judgment in determining equipment placement. Another important element of the standards is the education program for pest management professionals. An online exam to measure food plant pest management knowledge is available.

The Future of the Audit

While the perfect audit may never exist, there are certainly some positive trends in auditing for both the pest management industry and the food industry. The pest management industry has a duty to help its processor clients perform quality pest inspections, evaluate the conducive conditions found for pest related risk and complete the proper documentation. It is also the duty of pest management firms to check that issues are being resolved, documented and reported to clients. Many third-party auditor groups will be supporting this process in their audits with the changes that are occurring in audit standards.

Patricia Hottel is technical director at McCloud Services based in South Elgin, Ill. McCloud Services serves the largest food-related brands in the U.S.