Third-party audits provide an invaluable component to the safety of the U.S. food supply system. Multiple independent companies and audit programs provide literally thousands of independent checks and balances to the food supply system with no direct cost to taxpayers.
These audits are voluntary tools of the food manufacturer and are not meant to replace regulatory inspections. Usually, audits do not include microbiological sampling; however, a representative review of microbiological test records is part of the program evaluation. As a voluntary activity with no legal status, the audits depend on openness and disclosure to accomplish their full function. They are not meant to uncover deceit or fraud.
They are best described as professional service; a consultation activity that the facility can take advantage of the recommendations in full, in part or not at all. The deficiencies observed in the audit report can be resolved to the satisfaction of the facility or the buyer of product from the facility through pre-arranged agreements or program enhancements. Examples would include announced or unannounced visits; reports to all interested parties; and follow up to resolve deficiencies through a variety of reporting methods.
The food industry utilizes audits in a number of ways to supplement food safety programs as a manufacturer of food, the distribution of input or output, or a purchase of an ingredient, packaging suppliers or finished products.
One of the uses of third party audits is the training component for new and existing employees responsible for the actual day-to-day execution of the facility’s food safety program. Responsible personnel are encouraged to accompany the auditors/inspectors during the audit as well as the closing session. The training component is particularly important to small and medium size companies without a large corporate staff.
In addition, the standards and the experience of the entire organization is part of the transmission of best practices to each processing facility involved. The motto of the food industry is that there are no secrets when it comes to food safety best practices—the entire industry benefits.
Third-party audits also provide an opportunity to recalibrate a facility’s own self-inspection, part of a standard food safety program requirement.
Additionally, third party audits can provide a new set of eyes to view the operation, without the natural familiarity that occurs over time with regular staff in the day-to-day routine.
Finally, audits may be a component of a supplier approval program between companies. Other components may include Certificate of Analysis, independent lab analysis, transactional requirement, plant visit, as well as other components to ensure a safe and predictable supply to the purchasing organization.
The AIB GMP Audit
AIB has been conducting food safety audits for 60 years and is a pioneer in this field of activity. The company stresses the value of physical inspection of a facility’s plant and equipment, in addition to an audit of programs, policies, procedures and other documentation. Many characteristics of the AIB Good Manufacturing Practices (GMP) audit may be observed in other firms’ third-party audits. Below are some details regarding AIB’s program:
Report of AIB GMP Audit
AIB GMP reports are content-rich, with an average of 68 comments and observations, and typically run 10–20 pages. The AIB GMP Standards consider over 300 elements, fewer than five categories. In recent years, the total number of observations for improvements offered and reported exceeds 150,000 per year in the US alone.
Score of AIB GMP Audit
Scoring is based on observation of deficiencies against the Standard being utilized and reported in five categories, each with a maximum of 200 points awarded. Therefore, only a score of 1,000 would indicate no opportunity for improvement against the GMP Standards.
In addition, even if a facility has a score of, say 900, it may still have a serious observation in one of the five categories of the Standards. Not unlike a performance review, a lower number in one category, balanced off with good performance in the other four categories does not mean that improvements are not needed. The report should be taken as a total document, not just a score.
Superior /Excellent Rating of AIB GMP Consolidated Standard
These terms have been part of the AIB Consolidated Standards for many years and were intended as recognition of achievement for management and plant personnel to encourage them to keep improving their GMP compliance program. In most facilities, this has been useful for year to year improvement and reduction of food safety failure risk.
AIB encourages that companies do not use the rating and/or the score alone as part of the review of a potential supplier. The comments and observations provided by the report should be used in its entirety for the best indication of the plant’s food safety program. Also, corrective action confirmation may be necessary to complete a supplier approval process.
Announced /Unannounced Audits
AIB International supports the use of both announced and unannounced audits as an important component of ensuring the food supply of the U.S. food system. The AIB audit report clearly states whether the audit was announced or unannounced.
Announced audits provide the best opportunity to train onsite personnel to validate the effectiveness of onsite self-inspection and to transfer the best practices from one firm to another. Unannounced audits provide the best day to day view of the operations. They provide the best insight for companies purchasing products from a facility and should be used in conjunction with other requirements (Certificate of Analysis, independent lab analysis, and purchasing protocol, history, etc.), to lower the risk of a food safety failure.
Frequency of Audits
Most AIB GMP audits are conducted once per year, typically in a two-day visit. Most companies use the audit event as an opportunity to truly assess how they stack up against the AIB Consolidated Standards and prior audits.
Audit Company—Client Relationship
Audits are paid for by the facility/company having the service provided, not unlike financial audits which are also self-paid.
AIB auditors are full-time employees who do not receive incentive pay for audit results. As a part of their extensive training, AIB auditors are instructed to maintain a professional demeanor that is conducive to a constructive interaction with their clients.
AIB current policy is that auditors are rotated out after three consecutive visits.♦