Third party audits -- Passing the buck or coming full circle?

19.apr.09
Roy Costa

In the absence of food safety regulations in many commodities or the
lack of oversight in general, companies have turned to the private
regulation of the food supply. On an individual and voluntary basis,
dozens of auditing firms and hundreds of private parties are looking
closely at the safety of thousands of suppliers. The supplier-food
safety scheme is pushing all the way back from the retailer to primary
producer or farmer. As each link in the supply chain tightens standards,
there will be a corresponding improvement in the safety of final
products.
The third party food safety business model is that buyers "accredit" or
approve the third party food-safety firms they will accept audits from,
and suppliers are free to hire whatever firm they wish to satisfy the
buyer. The supplier pays the auditing firm directly and the auditing
firm sends the audit findings to the buyer. The buyer does not pay for
the audit and the findings do not bind his purchasing decision.
Third party audits have the capacity to improve food safety and provide
another means of protection in the wake of government inaction or even
failure. Third parties use private food safety standards developed
either in partnership with prospective buyers or in formal expert groups
at the national and international levels. They provide the basis for
determining "conformance" whereas regulations provide the basis or scope
of the regulatory inspection, which is "compliance". Third party audits
cannot take the place of regulatory inspection in protecting the
consumer for the simple fact that only government has the legal power to
enforce compliance. Third party audits since they are voluntary often
take on a collaborative air. A buyer maintaining good working
relationships with his auditing companies makes sense and adversarial
relationships are not productive. Bias can easily slip in when the audit
customer and the auditing firm grow too close. Bias can enter from the
supplier side as well. When choosing an auditing firm a supplier may
decide to select a firm based on price, personal knowledge of the
company and its personnel, as well as the strength of the auditing
system and its recognition.
The premise for any company to hire an auditing firm is the needs of the
buyer who is more than likely requesting the audit. The consumer
benefits from the third party scheme in more consistently safe products
but protection is weak when the most hazardous facilities continue to
operate. Disqualification of a supplier is the responsibility of the
buyer, but the audit findings in no way bind the buyer. Third parties
can rate a firm but they cannot dictate to the buyer who to use. In such
an unregulated system, unsafe operations continue to operate and
distribute unsafe food to consumers who continue to become ill and die.
Unsafe operations continue even when audits reveal clear significant
problems and more troubling, sometimes auditors do not clearly report
unsafe conditions.
Bias can work in another way. Since the auditing firm really wants the
suppliers business, relationships between suppliers, auditors and firms
may develop. If those personal relationships cloud the findings and
discretion of the auditor, the system becomes very weak.
Shifting the weight for protecting the consumer to third parties alone
is not a good system and is simply "passing the buck". There must be at
the basis for the model, a comprehensive and competent authority with
enforcement powers and consistent presence. We cannot rely upon
independent third parties for this. Government authority backing up the
system greatly improves the third party model and gives it credibility
especially when efforts are coordinated with industry. Government acting
in tandem with industry third parties and thus the industry itself
brings us full circle in the evolution of food protection efforts. Such
an effort would pave the way for a significant improvement in the safety
of foods and the protection of consumers.
Roy E Costa, R.S., M.S./M.B.A. Public Health Sanitarian Consultant
Environ Health Associates, Inc 1.386.734.5187 www.haccptraining.org
www.safefoods.tv rcosta1@cfl.rr.com