FDA needs to fix ‘audit creep’ if it can says Georgia fruit and veg growers

Audit creep is not something Chapman was knowingly called while visiting farms – maybe behind his back.

For this story, audit creep refers to the expanding inclusion of more requirements on growers of fresh produce, many which have nothing to do with food safety. The Georgia Fruit and Vegetable Growers Association explains excetpts below from a submission to the U.S. Food and Drug Administration on ways to improve preventative controls for produce safety (thanks to Tom Karst of The Packer for continuing to keep his eye on comments being submitted).

Food safety has long been a crucial part of GFVGA with the creation of the Georgia Good Agricultural Practice Food Safety Program (GA GAP) in 2000. We provide food safety education to producers across the southeast at various conferences as well as one-on-one farm visits. The GA GAP program also helps in the implementation of food safety plans, documentation and training on farms and in packing facilities as well as preparing producers for third party food safety audits.

Currently, there are more than 75 farms or packing facilities that have passed a certified third party food safety audit through the GA GAP program. We have provided one-on-one food safety training at approximately 300 farms and packing facilities across the southeast.

The 1998 FDA document, Guide to Minimize Microbial Food Safety Hazards for Fresh Fruits and Vegetables, has served as the basis for food safety policy in the United States. It has allowed our nation and the produce industry to set a foundation from which sound, safe farming and handling practices were established.

The Georgia Fruit and Vegetable Growers Association supports a federal food safety policy. Federal oversight is seen as the only way to establish and enforce a level playing field for all parts of the industry from producer to broker, retail chain to consumer.

In the current situation with no federal oversight, the food safety industry is decided by each retail supplier, food service organization, or brokerage firm. In 1998 there were no problems with food safety audit company checklists drifting far from the common foundation of the new FDA guidance. As consumers became more educated about their food and food sources and technology allowed for more quickly identifying food borne illness clusters, retail organizations began asking for more stringent food safety standards to lower their liability and tout their safer food supply.

They also began to demand the inclusion of non-food safety related materials such as business practices and sustainability on third party food safety audits. These tighter standards and non-food safety related demands are not bad, however they are not based on any science or industry practice; simply the idea that more is better.

Over the past twelve years this “audit creep” has continued and audit company’s marketing teams and delivery systems have grown more sophisticated. Many retail chains will pick one audit company format and require all suppliers use that service. Many of the larger producer, packer, shipper operations with multiple customers must undergo multiple audits.

Research has shown all audits contain 85% to 90% of the same questions. This proves to be a monetary, personnel, and time burden as audits begin at $750 (not including auditor travel expenses), audits last on average one to one and a half days and the auditor must be accompanied at all times during the audit. Food safety is no longer a small piece of the marketing program but an integral cog in the entire operation.

The common message from grower members of GFVGA is they see the value of food safety programs and are willing to make the necessary changes. What growers do not like is having the audit standards change year to year. Many of the grower’s customers will require one audit company and format one year and change to a different required audit company and format the second year. While most of the information is encompassed in their food safety, the difference in audit format, audit expectation, different metrics and constant change takes time and money.

The Georgia Fruit and Vegetable Growers Association supports a common foundation with the updating of the 1998 FDA guidance. We feel any federal food safety program, guidance and/or oversight should consist of science based regulations. This is one area that will require substantial time and resources as the research is simply not available. One example is water quality. In the absence of definitive microbial standards for irrigation water, the authors of the California Leafy Greens Market Agreement Best Practices Document have chosen to use the U.S. Environmental Protection Agency’s recreational water standards. Scientific research is needed to show if these standards are appropriate for irrigation water. …

The expense of a food safety program is not in implementing the program, changes and documentation. The expense is in having a third party audit. If federal guidance does not require a private audit from a third party, much of the monetary anxieties are taken away. An argument can be made that a smaller operation has less literal hands involved and can be more closely monitored. However E. coli and other harmful bacteria do not know whether they are in a 2 acre field or 200 acre field. Having a food safety program in place with documentation to remind and ensure Good Agricultural and Handling Practices are used is beneficial for all farms and consumers.”

Respectfully submitted,
Beth Bland
Director of Education and Food Safety
Georgia Fruit and Vegetable Growers Association


Finally, a focus on the ‘fallacy’ of food safety audits

“They called me crazy at Masters and Johnson. But I’ll show them.”
The demented Dr. Bernardo from Woody Allen’s 1972 film, Everything You Always Wanted To Know About Sex (But Were Afraid to Ask).

A week ago I asked, with all the recalled products related to Samonella in peanut paste, what problems did the third-party auditors uncover and what was done about such problems?

A few weeks ago, Chapman and I wrote that,

Third-party audits are an incomplete form of verification that provide a limited view of a producer’s facilities and documentation but do not effectively reduce risk. …At some point, folks will figure out that all these outbreaks of foodborne illness – like Salmonella in peanut butter – happened at places that passed so-called independent audits.

Ten years ago, I told the Ontario greenhouse tomato growers they should have their own in-house food safety expertise to help farmers produce safe product and to market the program, with test results, to buyers and consumers.

They said I was crazy.

This morning, the N.Y. Times and USA Today are reporting that Peanut Corporation of America, the Blakely, GA firm at the epicenter of the Salmonella shit storm, had “regular visits and inspections” of its Blakely, Ga., plant in 2008, not only by federal and state regulators but by independent auditors and food safety companies that made “customary unannounced inspections.”

Kellogg’s auditor, the American Institute of Baking checked out Peanut Corp. of America’s Blakely, Ga., plant in 2007 and 2008 and gave it superior ratings both times.

"That’s frightening," says Michael Doyle, director of the Center for Food Safety at the University of Georgia.

Andrew Martin of the Times writes that,

Peanut Corporation of America’s statement was released as food manufacturers and public health officials tried to determine how so many inspectors missed what some have said were obvious problems at the plant, including improper sanitation procedures, live roaches, mold and slimy residue on floors and equipment.

Kris Charles, a spokeswoman for Kellogg, said,

Had Kellogg known of the problems at the plant that the Food and Drug Administration detailed recently, “we would have discontinued the relationship with P.C.A. immediately and would not have accepted any ingredients from them.”

Jim Munyon, president of AIB International, based in Manhattan, Kan., said the company would not have received a superior rating if his auditors had seen the filth the federal government described.

“It would mean that we didn’t see it on the day we were there. What goes on the rest of the time, we don’t know.”

He did say that AIB wouldn’t see internal test results unless PCA shared them. "They show us only what they want to show us," he says.

Doug Powell, an associate professor of food safety at Kansas State University, said the salmonella outbreak at Peanut Corporation of America showed the “fallacy” of independent audits, which are commonly used to verify food safety, animal welfare claims and organic production methods. While the intent might be good, he said, the results are usually withheld from the public.

“Companies say they do all this testing. Great. Show us the data. They won’t. Given all the outbreaks, why should we believe them?”