Auditors and public health: a request

I still can’t say no to students.

Beth Driscoll, MA, CPHI(C), CHA, PMP (I’m not sure what all those initials mean) and PhD Candidate, Policy Studies, at Ryerson University (that’s in Toronto, which is in Canada) writes:

My name is Beth Driscoll, and I am inviting you to participate in a brief, online survey.  This survey will take approximately 15 minutes to complete, and investigates the perceptions of Global Food Safety Initiative (GFSI) auditors’ role in public health.  This survey is being conducted for my doctoral research project at Ryerson University.

To participate in this project, you must:

•]be fully certified to conduct GFSI audits for at least one benchmarked scheme;

• have completed at least five GFSI audits of that scheme; and,

• be fluent in English.

The survey is not intended to investigate or assess the GFSI, a GFSI benchmarked Food Safety Scheme, Certification Body, Accreditation Body, government or other organization.  Should the responses to the survey questions contain information that would identify one of these organizations, the identifying information will be anonymized prior to use.

Conflict of interest declarations: I am a contract employee for NSF International.  This information is being collected solely for my researcher’s graduate degree, and is not being collected for any organization associated with the GFSI or NSF International, nor do I conduct GFSI audits. 

If you choose to participate, you will be asked to complete an online survey about your professional identity and your understanding of your role in public health through the audits you conduct to a Global Food Safety Initiative (GFSI) benchmarked Food Safety Scheme.  The survey is confidential is using Opinio, Ryerson University’s Online Survey Program, and all data is stored at Ryerson University.  This study has undergone review through the Ryerson University Research Ethics Board and if you have questions about your rights as a research participant, you may contact the Ryerson Research Ethics Board at [email protected].  If you have any questions about the survey please contact the researcher, Beth Driscoll, at [email protected]  or Dr. Richard Meldrum at  [email protected] before continuing.

Please feel free to forward this email to anyone you feel may be qualified to participate.

To participate, please go to the following website: https://survey.ryerson.ca:443/s?s=6004

AMS administrator wants to help fill food safety gaps

Tom Karst of The Packer reports that when it comes to produce safety, Elanor Starmer wants the USDA’s Agricultural Marketing Service to be a big part of the solution.

supermarket_produceStarmer has been the AMS administrator since January, succeeding Anne Alonzo in the post. Previously, she had served as senior advisor to Agriculture Secretary Tom Vilsack.

While she may have less than a year left in her post before the next administration names a new AMS administrator, Starmer said she is trying to accomplish all she can in the limited time left.

Speaking with The Packer June 21 during the United Fresh Produce Association’s annual conference, Starmer said the USDA-AMS wants to help various sectors of the industry understand how they will be affected by Food Safety Modernization Act regulations.

Starmer said AMS wants to help the industry be aware of USDA resources and tools. For example, research agencies can look at the realities of compliance with the water standards or what the manure standard might look like, she said.

Starmer said the USDA has ongoing work and communication with the FDA to make sure that the USDA’s Good Agricultural Practices and Good Handling Practices audits are correctly aligned with FDA regulations. At the same time, the USDA GAP program is being benchmarked with the Global Food Safety Initiative.

Collaboration collaborationists: Trust us is terrible soundbite for food safety

Last night, I chatted in my terrible French with our host and his far better English, with Amy there to mediate the difficult parts, about his parents’ emotional shit-fest during Nazi occupation in World War II.

gfsi.collaboration.bs.jun.16The short version: his father had been chosen to be killed by Germans in retaliation for the killing of a German soldier, and while awaiting death, American troops rolled into town, post-Normandy, and his father was spared.

The son showed me a photograph of the German boss being transported out of town on the front of an American Jeep, hands on his head.

That’s one of the reasons this lovely French family loves Amy: she’s American.

Collaboration, which has been touted for decades as essential in the academic enterprise and yesterday ad nausea in the food safety world, also has a different meaning: Collaborationists.

Selling out.

I’ve covered this before, but food safety collaboration is over-rated, especially if it’s driven by a top-down organization.

Just because a lot of salaries from the United Nations Industrial Development Organization (UNIDO) and the Global Food Safety Initiative (GFSI) signed a memorandum of understanding on jointly developing food safety capacity building projects, means nothing (upper right, propaganda image).

Will fewer people barf?

Yet the collaborationists falling over themselves to follow is at once both nauseating and vomit-inducing.

Philippe Scholtes, Managing Director at UNIDO, said, “The World Health Organization estimates that up to 600 million people fall ill every year after eating contaminated food. Our collaboration with GFSI will further strengthen and promote multiple benefits of safe food for social inclusiveness, sustainability and industrial development.” 

Will fewer people barf?

Mike Robach, Chair of the GFSI Board of Directors, added, “We are very enthusiastic about the potential to have a bigger impact in these key regions, thanks to this collaboration with UNIDO. Multi-sector collaboration is the way forward in achieving food safety across borders and barriers. Our joint efforts within this partnership will take us further and faster towards our vision of safe food for consumers, everywhere.”

collaboration.german.trustWill fewer people barf (lower left, propaganda image)?

Individuals create and innovate, and bring others to the table.

Individuals who are steady and focused need someone to take them out of their comfort zone, as much as the erratic need steadying support.

That is the challenge of any collaboration, bringing those elements together, and being better than the individual.

Otherwise, it’s just a collaborationist following a paycheck.

Maple Leaf Foods blows itself

Eight years after Maple Leaf Foods cold cuts laden with Listeria killed 24 Canadians and sickened another 50, the company now announces, with fanfare, it will require all of its protein, ingredient and packaging suppliers to become food safety certified to a Global Food Safety Initiative (GFSI) standard in 2017.

Audits and inspections are never enough.

Organizations, groups, awards, they’re all designed to blow the insiders.

The families of the victims probably don’t feel they were blown.

Great. Make the data public.

  • More than 225,000 farms and food manufacturing facilities are certified to GFSI recognized standards globally.

No one cares if you kill people.

Maple Leaf is doing a tap-dance to avoid substantive issues.

  • Put a warning label on your cold-cuts, especially for expectant mothers;
  • make your testing results public; and as I frequently remind my daughters.
  • stop dicking around.

Regarding your audit claims, Maple Leaf sucks.

  • safety audits and inspections are a key component of the nation’s food safety system and their use will expand in the future, for both domestic and imported foodstuffs., but recent failures can be emotionally, physically and financially devastating to the victims and the businesses involved;
  • many outbreaks involve firms that have had their food production systems verified and received acceptable ratings from food safety auditors or government inspectors;
  • while inspectors and auditors play an active role in overseeing compliance, the burden for food safety lies primarily with food producers;
  • there are lots of limitations with audits and inspections, just like with restaurants inspections, but with an estimated 48 million sick each year in the U.S., the question should be, how best to improve food safety?
  • audit reports are only useful if the purchaser or  food producer reviews the results, understands the risks addressed by the standards and makes risk-reduction decisions based on the results;
  • there appears to be a disconnect between what auditors provide (a snapshot) and what buyers believe they are doing (a full verification or certification of product and process);
  • third-party audits are only one performance indicator and need to be supplemented with microbial testing, second-party audits of suppliers and the in-house capacity to meaningfully assess the results of audits and inspections;
  • companies who blame the auditor or inspector for outbreaks of foodborne illness should also blame themselves;
  • assessing food-handling practices of staff through internal observations, externally-led evaluations, and audit and inspection results can provide indicators of a food safety culture; and,
  • the use of audits to help create, improve, and maintain a genuine food safety culture holds the most promise in preventing foodborne illness and safeguarding public health.

 

ITALY-G8-G5-AGRICULTURE-FARMAudits and inspections are never enough: A critique to enhance food safety

30.aug.12

Food Control

D.A. Powell, S. Erdozain, C. Dodd, R. Costa, K. Morley, B.J. Chapman

http://www.sciencedirect.com/science/article/pii/S0956713512004409?v=s5

Abstract

Internal and external food safety audits are conducted to assess the safety and quality of food including on-farm production, manufacturing practices, sanitation, and hygiene. Some auditors are direct stakeholders that are employed by food establishments to conduct internal audits, while other auditors may represent the interests of a second-party purchaser or a third-party auditing agency. Some buyers conduct their own audits or additional testing, while some buyers trust the results of third-party audits or inspections. Third-party auditors, however, use various food safety audit standards and most do not have a vested interest in the products being sold. Audits are conducted under a proprietary standard, while food safety inspections are generally conducted within a legal framework. There have been many foodborne illness outbreaks linked to food processors that have passed third-party audits and inspections, raising questions about the utility of both. Supporters argue third-party audits are a way to ensure food safety in an era of dwindling economic resources. Critics contend that while external audits and inspections can be a valuable tool to help ensure safe food, such activities represent only a snapshot in time. This paper identifies limitations of food safety inspections and audits and provides recommendations for strengthening the system, based on developing a strong food safety culture, including risk-based verification steps, throughout the food safety system.

Show us the data, forget the faith; food sickens millions as company-paid checks find it safe

William Beach loved cantaloupe — so much so that starting in June last year he ate it almost every day. By August, the 87-year-old retired tractor mechanic from Mustang, Oklahoma, was complaining to his family that he was fatigued, with pain everywhere in his body.

On Sept. 1, 2011, Beach got out of bed in the middle of the night, put his clothes on and walked into the living room. His wife, Monette, found him collapsed on the floor in the morning. At the hospital, blood poured from his mouth and nose, splattering sheets, bed rails and physicians.

He died that night, a victim of Listeria monocytogenes. Beach was one of 33 people killed by listeria that was later traced by the U.S. Food and Drug Administration and state officials to contaminated cantaloupes from one Colorado farm. It was the deadliest outbreak of foodborne disease in the U.S. in almost 100 years.

“He died in terror and pain,” says his daughter Debbie Frederick.

That’s how Stephanie Armour, John Lippert and Michael Smith begin their food safety and aduits and inspections opus for Bloomberg. The Today Show may run a version this morning, because I taped a bit for it at Brisbane’s Channel 7 studios last week.

About seven weeks after Beach started eating cantaloupes, a private, for-profit inspection company awarded a top safety rating to Jensen Farms, the Granada, Colorado, grower of his toxic fruit. The approval meant retailers such as Wal-Mart Stores Inc. (WMT) and Wegmans Food Markets Inc. could sell Jensen melons.

The FDA, a federal agency nominally responsible for overseeing most food safety, had never inspected Jensen.

During the past two decades, the food industry has taken over much of the FDA’s role in ensuring that what Americans eat is safe. The agency can’t come close to vetting its jurisdiction of $1.2 trillion in annual food sales.

In 2011, the FDA inspected 6 percent of domestic food producers and just 0.4 percent of importers. The FDA has had no rules for how often food producers must be inspected.

The food industry hires for-profit inspection companies — known as third-party auditors — who aren’t required by law to meet any federal standards and have no government supervision. Some of these monitors choose to follow guidelines from trade groups that include ConAgra Foods Inc. (CAG), Kraft Foods Inc. and Wal-Mart.

The private inspectors that companies select often check only those areas their clients ask them to review. That means they can miss deadly pathogens lurking in places they never examined.

What for-hire auditors do is cloaked in secrecy; they don’t have to make their findings public. Bloomberg Markets obtained four audit reports and three audit certificates through court cases, congressional investigations and company websites.

Six audits gave sterling marks to the cantaloupe farm, an egg producer, a peanut processor and a ground-turkey plant — either before or right after they supplied toxic food.

Collectively, these growers and processors were responsible for tainted food that sickened 2,936 people and killed 43 in 50 states.

“The outbreaks we’re seeing are endless,” says Doug Powell, lead author of an Aug. 30, 2012, study on third-party monitors called “Audits and Inspections Are Never Enough.” Powell, a professor of food safety at Kansas State University, says Americans are at risk whenever they go to a supermarket.

“You need to be in a culture that takes food safety seriously,” Powell says. “Right now, what we have is hidden. The third-party auditor stickers and certificates are meaningless.”

In some cases, for-hire auditors have financial ties to executives at companies they’re reviewing. AIB International Inc., a Manhattan, Kansas, auditor that awarded top marks to producers that sold toxic food, has had board members who are top managers at companies that are clients.

Executives of Flowers Foods Inc. (FLO), which makes Tastykake, and Grupo Bimbo SAB in Mexico City, which makes Entenmann’s pastries, Sara Lee baked goods and Wonder Bread, serve or have served on AIB’s board.

“There’s a fundamental conflict,” says David Kessler, a lawyer and physician who was FDA commissioner from 1990 to 1997. “We all know about third-party audit conflicts. We’ve seen it play out in the financial world. You can’t be tied to your auditors. There has to be independence.”

As flawed as the inspection system is in the U.S., it’s more problematic with imported food, especially coming from countries with lower sanitary standards, says Michael Doyle, director of the University of Georgia’s Center for Food Safety. In some emerging markets, farms growing food for export to the U.S. aren’t inspected at all.

The U.S. will import half of its food by 2030, up from 20 percent today, Doyle says. Bloomberg Markets visited growers in China, Mexico and Vietnam and found unsanitary conditions for produce, fruit and fish exported to the U.S.

Auditors evaluate their clients using standards selected by the companies that pay them, says Mansour Samadpour, owner of IEH Laboratories & Consulting Group in Lake Forest Park, Washington, which does testing for the FDA. The auditors sometimes follow a checklist that the company they’re inspecting has helped write.

“If you have a program for adding rat poison to a food, the auditor will ask, ‘Did you add as much as you intended?”’ Samadpour says. “Most won’t ask, ‘Why the hell are we adding poison?”’

Not only has the government outsourced auditing to the food industry; the auditors themselves often outsource their vetting to independent contractors — people over whom they don’t have direct management control.

While Primus Labs declined to comment directly for this story, it did supply a response from its law firm, Kaufman Borgeest & Ryan LLP in New York. Auditors, the statement says, serve at the pleasure of their clients and cannot go beyond what they are asked to do.

“Third-party auditing will continue to be as effective as those requiring the audits (buyers/suppliers) and the audited suppliers make them,” the law firm writes. James Markus, a lawyer representing Jensen, didn’t return calls seeking comment.

From the outset, the FDA lacked the resources to inspect all of the country’s food producers.

The food industry moved to fill that vacuum with private auditors in the 1990s. Danone SA (BN), Kraft, Wal-Mart and other companies created the Paris-based Global Food Safety Initiative in 2000 to write guidelines for third-party auditors.

The program, whose vice chairman is Frank Yiannas, Wal- Mart’s vice president for safety, requires companies to be audited once a year. It doesn’t mandate testing for pathogens. In 60 manufacturing plants, Wal-Mart suppliers reported a third fewer recalls in the two years after adopting GFSI standards, Yiannas says.

In some cases, companies use their own auditors to check suppliers. In 2002 and 2006, Nestle USA, a subsidiary of Vevey, Switzerland-based Nestle SA (NESN), refused to use Peanut Corp. of America as a supplier. Nestle inspectors found rodent carcasses and pigeons in Peanut Corp.’s Plainview, Texas, plant.

Nestle’s rejection didn’t stop Lynchburg, Virginia-based Peanut Corp. from doing business with other customers or seeking approval from third-party auditors. In 2008, AIB International auditor Eugene Hatfield gave Peanut Corp.’s Blakely, Georgia, plant a “superior” rating.

And there’s a whole lot more. Our take on all this is below:

 

Food Control

D.A. Powell, S. Erdozain, C. Dodd, R. Costa, K. Morley, B.J. Chapman

http://www.sciencedirect.com/science/article/pii/S0956713512004409?v=s5

Abstract

Internal and external food safety audits are conducted to assess the safety and quality of food including on-farm production, manufacturing practices, sanitation, and hygiene. Some auditors are direct stakeholders that are employed by food establishments to conduct internal audits, while other auditors may represent the interests of a second-party purchaser or a third-party auditing agency. Some buyers conduct their own audits or additional testing, while some buyers trust the results of third-party audits or inspections. Third-party auditors, however, use various food safety audit standards and most do not have a vested interest in the products being sold. Audits are conducted under a proprietary standard, while food safety inspections are generally conducted within a legal framework. There have been many foodborne illness outbreaks linked to food processors that have passed third-party audits and inspections, raising questions about the utility of both. Supporters argue third-party audits are a way to ensure food safety in an era of dwindling economic resources. Critics contend that while external audits and inspections can be a valuable tool to help ensure safe food, such activities represent only a snapshot in time. This paper identifies limitations of food safety inspections and audits and provides recommendations for strengthening the system, based on developing a strong food safety culture, including risk-based verification steps, throughout the food safety system.

Retailer double talk on produce safety

My friend and Randy Bachman-inspired guitar player Roy Costa writes:

One of the hallmarks of protecting the fresh produce supply is a concept known as “buyer-driven” food safety controls. In the absence of regulations, the produce industry has been working under private standards drafted by the major buyers of produce, meaning the large retailers — the major supermarket chains. While the need to satisfy the retailer that foods supplied to them are safe, retailers themselves have been less than effective in ensuring that the people they commission to buy for them, their own buyers, only deal with operations with acceptable food safety systems.

This means that many, if not most retailers, will buy produce from firms that have not been verified by competent third parties or by the retailers themselves (second party verification), when it is opportune for them to do so. For a revealing piece on this issue see The Perishable Pundit.

The sad truth is that when buyers can get produce from a vendor at a cheaper price, the requirements for safety take second place.

Even worse, buyers utilize the unapproved firm as a lever to get the operator with a food safety system, and subsequently higher production costs, to lower their price.

Even small operations may invest hundreds of thousands of dollars in satisfying the strict rules of the Global Food Safety Initiative (GFSI). Often, firms must hire food safety personnel due to the overwhelming amount of self-inspection and paperwork involved. Laboratories and auditors must be paid for. Many times there are requirements for structural improvements and maintenance, chemicals to clean and treat water and many other similar costs to be borne day in and day out by suppliers. Thanks to the attitude of the major retailers, these suppliers cannot typically charge more for their products, and must absorb the costs as best they can while trying to stay competitive.

It is unfair to say the least that buyers for the major retailers would use the lower priced unapproved supplier as leverage to keep down their costs. Instead of rewarding suppliers for diligent efforts that not only protect the retailer, but public health in general, they are causing animosity; many conscientious produce operators are indignant at the current double standard, but the fear of losing customers precludes most of them from expressing their exasperation.

“Food safety culture” is a much used phrase and one preached to the supply chain by many of the world’s largest retailers. Retailers should be reminded that food safety culture begins at home, and such talk becomes a mockery in the eyes of the producer when retailers say one thing and do another.

Not all produce firms have had an opportunity to be qualified by third party accreditation under any private scheme, but the population of certified firms is growing, Part of the reason for the shortfall is that the auditing firms performing such audits are themselves overwhelmed and lack the necessary manpower.

In order to maintain pressure on the supply chain, the buyers for the major retailers have set deadlines for compliance, but then have to announce that another grace period or extension has been granted. Some relatively large producers of fruits and vegetables have just decided that the retail communities demands for conformance with third party food safety standards is a bluff and carry on business as usual; and they find most retailers are willing to buy their products anyway, on the basis of price and quality.

Lawsuits involving the produce industry cost retailers many millions, however, too many are seemingly willing to take a chance as long as the short term economic benefit is there.

I am sure the food safety experts at the nation’s leading retailers cringe when their buyers go outside the approved supplier list, yet the corporate decision makers do not always value a food safety department’s input.

Again, this is not food safety culture, when a firm puts short term profits over safety and public health; this is the antithesis-corporate greed.

Such business practices are undermining food safety efforts and causing many a bitter attitude among firms who have invested millions over the years to satisfy the demands of retailers, only to have their competitors flaunt such food safety efforts and prosper.

 

Wal-Mart Frank: Are you a food safety manager or a food safety leader?

There goes WalMart Frank again, hammering home the need for food safety leaders and that culture thing.

Frank Yiannas, vice president – food safety, Wal-Mart Stores, Inc. writes in the latest Global Food Safety Initiative (GFSI) newsletter that management and leadership are different. A manager’s job is to oversee and optimize organizational processes to deliver results. A leader’s job is to change the process to deliver even greater results.

Frank says one term (management or leadership) is not inferior or superior to the other. They’re just different: and the food safety world need both; — good food safety management and more food safety leadership — as they are both critical to protecting public health.

• Food safety management focuses on the administration of set procedures within an established risk management system; food safety leadership focuses on the creation of new, science-based, and more effective risk reduction strategies, models, and processes. This quote by Stephen Covey illustrates this point quote well. He said, “Management works in the system; leadership works on the system.”

• Food safety management relies on formal authority to accomplish its objectives; food safety leadership relies on the ability to influence others to achieve success. Traditionally, food safety managers coerce others to comply because they have authority over them or their operation. In other words, they get others to comply by holding people and organizations accountable. Food safety leaders, in contrast, get others to do the right thing not because they’re being held accountable, but because they’ve been able to influence them to want to do so. They help others become responsible for food safety – not just accountable for food safety. There is a big difference between the two.

• Food safety management involves working with others based on functional roles; food safety leadership involves working with others in a collaborative manner. Food safety managers work with others in traditional ways to accomplish their objectives. Often times, whether visible or not, they’re protecting their organization’s interests whether it be academia, regulatory, or industry. In contrast, food safety leaders seek genuine win-win solutions for all stakeholders. They recognize they can do more to advance food safety by working constructively with others than by working alone.

Traditional food safety management vs. behavior-based food safety management

Frank Yiannas, vp of food safety at Walmart and the author of the 2009 book, Food Safety Culture, penned a piece for GFSI’s (Global Food Safety Initiative) latest newsletter about why behavior-based food safety management is key to enhancing food safety. An edited excerpt is below:

The term food safety management system, as traditionally used, often refers to a system that includes having prerequisite programs in place, good manufacturing practices (GMPs), a Hazard Analysis of Critical Control Point plan, a recall procedure, and so on. It’s a very process focused system. A behavior-based food safety management system is process focused, but it’s also people focused.

At the end of the day, food safety equals behavior. And to improve the food safety performance of your organization, you have to change people’s behaviors.

Traditional food safety managers are focused on the principles of food safety, temperature control, and sanitation – the food sciences. They believe that managing these scientific principles will lead to food safety success.

Behavior-based food safety managers have mastery over the food sciences. But they understand that the food sciences are not enough. They understand that achieving food safety success requires not only an understanding of the food sciences, but of the behavioral sciences too. Accordingly, they are students of behavioral change theories, the behavioral sciences, and principles related to organizational culture.

Traditional food safety managers place an overemphasis on training and inspections in an attempt to change behavior and achieve results. They believe that desired behavior change can be achieved by simply training employees and inspecting processes and conditions against established standards. But as stated so elegantly by B.F. Skinner (1953), behavior is a difficult subject, not because it is inaccessible, but because it is extremely complex. While both of these activities (training and inspections) are important, behavior-based food safety managers realize they are not enough to achieve food safety success. They understand the complexity of behavior and, before jumping to an overly simplistic solution; they study and analyze the cause of the performance problem (lack of skill, ineffective work system, lack of motivation, etc) to propose the right solution.

Traditional food safety management often addresses specific food safety concerns and strategies in isolation or as individual components, not as a whole or complete system. In other words, it approaches food safety with a sort of linear cause-and-effect thinking. Behavior-based food safety management realizes that this sort of linear cause-and-effect thinking is not fully adequate to address complex issues related to an organization’s food safety culture or an employee’s adherence to food safety practices.

Behavior-based food safety management understands that there are numerous factors (physical, organizational, personal) that affect performance and they consider the totality of the numerous activities an organization may conduct and how they are linked together to influence people’s thoughts and behaviors.

Traditional food safety management relies on formal authority to accomplish objectives. Food safety managers get others to follow them or their program because they have authority over them and hold them accountable to the rules. Behavior-based food safety managers also use a system of checks and balances, but they use them differently. For example, they use them to observe employee behaviors related to food safety, give feedback and coaching (both positive and negative) based on the results, and provide motivation for continuous improvement.

More importantly, behavior-based food safety managers have figured out a way to go beyond accountability. They’ve figured out a way to get employees at all levels of the organization to do the right things, not because they’re being held accountable to them, but because they believe in and are committed to food safety. They create a food safety culture.

Food safety, D.C. style; hold the pea sprouts

Sorenne got to play with Marian Nestle’s hair while waiting to go to dinner, Amy talked to some dude from Switzerland and maybe arranged a trip to one of her favorite previous countries to live in, and I apparently pissed off everyone during my talk to 600-or-so delegates at the Global Food Safety Initiative meeting in Washington today.

Food safety auditors can sometimes suck. And I said so, with suggestions on how to make things better.

Dinner was served with pea sprouts (right, color isn’t great but they’re on top of the chicken), which I scraped to the side, as did Amy, and then the two people sitting on either side of us. Irony can be pretty ironic sometimes, especially at food safety meetings.

But we had fun, and I was grateful for the invitation.