Food Safety / Sustainability / Processing

Third-Party Audits: Adopting an Open Door Policy

August 1, 2011
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Bigger welcome mats are being laid out for third-party auditors as the food industry reconciles itself to customer and public demands for greater transparency.

Customers are casting a wider net in plant audits, moving from line operations to the far corners of manufacturing sites to assure their suppliers are doing everything possible to meet new standards for sanitary procedures, worker safety and other practices not directly related to product integrity. Source: Orkin.


At a 1987 signing ceremony for a nuclear weapons reduction treaty with the Soviet Union, Ronald Reagan famously said, “Trust, but verify.”

Manufacturers can relate. Some may wax nostalgic for a simpler time when a man’s word was his bond. If that was ever the case, it most certainly is not in today’s business world. As any manufacturer can attest, customers expect transparency and demand access to the production floor. Independent verification that good manufacturing practices are being followed is almost a condition of doing business.

Industry guidelines and self-certifications are going the way of the electronic pager. Pressure for third-party audits and documented procedures is coming from multiple directions, most notably trading partners. Speaking at Food Engineering’s 2011 Food Automation & Manufacturing Conference, Dennis Treacy, chief sustainability officer at Smithfield Foods Inc., described the hog producer’s efforts to rehabilitate its environmental record by seeking certification to ISO 14000, the environmental standard of the International Organization for Standardization. The Smithfield, VA-based firm’s 480 hog farms were certified in 2002, with processing facilities brought into compliance two years later.

“There was a cost,” Treacy allows, “but we needed third parties coming in and seeing we were doing what we said we were going to do, because nobody believed us anymore.”

The Food Safety Modernization Act (FSMA) will require food companies to, among other things, demonstrate a management system for food security is in place, according to Mark E. Powers, regional security manager for MillerCoors LLC, Milwaukee. The legislation primarily focuses on imported products, but in-plant defenses also will be more closely scrutinized. “You can’t get to what FSMA says without historical records of CCTV recordings, access-card use, et cetera,” says Powers. While food defense is addressed in audit standards under the Global Food Safety Initiative (GFSI), he predicts more rigorous requirements soon will be in place.

The GFSI food safety audits are more rigorous than the proprietary standards that have existed for years. Almost 13,000 North American food and beverage sites have been certified so far, and worldwide, 120,000 certificates have been issued, a four-fold increase in three years, according to Catherine François, director of food safety programs at GFSI’s headquarters in suburban Paris, France. “Many European-based retailers no longer have their own proprietary schemes [audit programs] and rely on third-party certification for food safety management,” she states. François says circumstantial evidence indicates fewer audits are occurring at some European food companies.

American processors regard the prospect of fewer audits with a healthy dose of skepticism. In a straw poll, no US food professionals indicated they expect fewer audits. Most say they are audited four to nine times annually, and the GFSI audits are taking two to three times longer to complete than the proprietary standards developed by organizations such as AIB International and Silliker Labs. Some welcome the change: “What has been done in the past by third-party auditors has not nearly been rigorous enough,” one manager says.

While self-certification is possible with many ISO standards, GFSI involves multiple levels of third-party review. GFSI is the review body for SQF, BRC and other standards. The companies that offer the audits also must be certified, and their auditors are certified only to inspect production processes with which they have a demonstrated level of expertise. Their inspections are not limited to the review of good manufacturing practices and proof of functioning prerequisite programs; they also demand evidence of oversight by senior management and corrective actions taken when a problem occurs.

Video monitoring by third parties is being used by some food companies to augment in-house audits of food safety and animal welfare programs. Source: Arrowsight Inc.

No gain with pain

Wherever livestock is involved, animal welfare has emerged as a hot button rivaling food safety. Conditions of confinement are addressed in legislation approved by several states, most notably California’s Prevention of Farm Animal Cruelty Act, better known as Prop 2. Though not in effect until 2015, Prop 2 is reshaping practices involving veal calves, gestating sows and laying hens. As with similar legislation signed into law in June by Oregon’s governor and in May in the state of Washington, Prop 2 mandates the use of crates and cages that allow captive animals to lie down, turn freely and fully extend their limbs and wings.

Traditional battery cages for hens have been on the way out in Europe for a decade, and next year, they will be banned, as egg producers complete the transition to enriched colony housing. JS West & Cos. in Modesto, CA converted housing for 10 percent of its flock of 1.5 million laying hens to enriched colony two years ago. Last year, the system was the first to be certified by the American Humane Association (AHA), which began offering third-party audits of slaughter facilities in the UK in the mid-1990s.

“The conventional [hen housing] system is not inhumane, in my opinion,” offers Jill Benson, vice president of JS West. On the other hand, “we realized there was a societal shift,” with members of the public demanding to know more about farm practices for industrialized production. The vast majority of egg operations are held to standards developed by the United Egg Producers, but those standards only apply to battery cages and cage-free production. Because AHA’s standards are science based, JS West adopted them for enriched colony.

AHA emphasizes it is separate and distinct from the Humane Society of the United States (HSUS), the activist group that takes a more adversarial approach with industry. American Humane consulted with animal husbandry scientists when drafting its certification program, points out Kathi Brock, director of strategic partnerships for the Englewood, CO organization. One of the experts helping to shape the certification audits was Temple Grandin, the designer of humane livestock-handling systems praised by both industry (the American Meat Institute touts her work) and People for the Ethical Treatment of Animals (PETA). “Our mission is animal welfare, but if animal welfare is too expensive, you haven’t helped anyone,” says Brock. “It has to be economically feasible to convert to enriched colony.”

At JS West, partial conversion came with a $3.7 million price tag, and if Prop 2 passes muster in court, “our family alone will face a bill of $30 million,” says Benson. Statewide, she estimates California egg producers will have to invest $556 million to convert. The housing’s impact on production still is being evaluated. “She eats a little more feed,” Benson says of the laying hens, “but her livability is good and production is good.” Brock predicts the system should make JS West a preferred supplier for companies such as Unilever, which only accepts eggs from operators with the American Humane Certified designation. (Unilever officials did not respond to requests to confirm that requirement.)

Cage fabricators already have revised their designs to allow conversion of battery cages to enhanced colony, a capability that adds hardware cost for all egg operations, regardless of where they do business. But many are rallying around the tougher standards and stricter certification in part to blunt more extreme requirements. “The beauty of the AHA is that they look at the science and have an advisory council that is really a solutions-based group,” suggests Greg Satrum, co-owner of Willamette Egg Farms in Canby, OR. “Unfortunately, we have some groups that are looking to erode consumer confidence. The way to combat that is through transparency.”

Industry finds its voice

Finding a reasonable middle ground is essential if onerous requirements are to be avoided. “We’re starting to tell our story to the world,” says Smithfield’s Treacy. Providing an organized response to critics is the essence of the Center for Food Integrity, a four-year-old group that includes the Coalition for Sustainable Egg Supply. The latter group includes McDonald’s, Michael Foods and the American Veterinary Medical Association, while the former unites farmers, ranchers, university researchers and a few processors such as Foster Farms and Tyson in the mission of “building trust and confidence in today’s food system.”

Another industry initiative is the Professional Animal Auditor Certification Organization Inc. (PAACO), Redfield, IA. Audit training and auditor certification for animal welfare have been provided since 2005. AHA requires its auditors to be PAACO certified and ISO 9000 trained. The down side of unqualified audits spurred PAACO’s formation, according to Mike Simpson, executive director. A pork packer lost three weeks of production when a food safety auditor who “didn’t know animals from up” gave the facility a failing grade because he mistook a standard hog watering system as a danger to the pigs’ health.

Pork and poultry are on the front lines of the animal welfare debate because those segments are most closely linked to industrial practices. To counter the criticism, groups like the National Pork Board are raising their standards and winning industry support. When the pork board introduced the PQA Plus certification for on-farm hog production, Hormel announced it would only purchase from pork producers who are PQA Plus certified.

“If it’s happening with broilers and hogs, why won’t it happen with dairy and beef?” Simpson asks rhetorically. All food production involving livestock will face animal-welfare audits at some point, he predicts, and PAACO wants to ensure the people conducting those third-party audits are qualified.

Fewer than 300 individuals are PAACO certified, however, and most only are certified for poultry. Many are employees of the companies whose facilities they audit. One processor says his firm’s PAACO auditors conduct in-house audits at facilities other than the one where they work, and while the results so far have been accepted by customers, the system is vulnerable to conflict of interest charges.

Though useful for continuous improvement and generally accepted by customers, internal reviews based on the AMI Foundation’s checklist fall into the category of “biased” audits, points out Len Huskey, director of animal welfare at JBS USA Holdings Inc., Greeley, CO. “It’s only human nature for employees to be on their best behavior” when an auditor is recording livestock slips and falls, stunning outcomes, the use of electric prods and other activities covered by the AMI audit. Remote video monitoring, on the other hand, delivers an unbiased audit, which is why JBS extended a pilot program with Arrowsight Inc. in its Souderton, PA facility last year to its seven other beef slaughter plants.

From their control room in Huntsville, AL, Arrowsight’s staffers, under the direction of PAACO-certified supervisors, emulate the AMI slaughter audits performed in person, with two important differences. An in-house auditor observes 100 cattle being unloaded from trailers, for example, and notes which ones slipped, fell or disembarked without incident. If more than three slip and one falls, a failing score is recorded. After the butcher plunges a long knife into the animal’s chest cavity to end life, the carcasses move along a bleed rail, where workers make cuts between the hide and the epidermis, to prepare the carcass for the mechanical hide-removal machine. The inspector again observes 100 carcasses, watching for any signs of life. If any signs of a return to sensibility are detected, procedures such as skinning the head must cease until the animal is re-stunned. Otherwise, the plant fails the audit.

Instead of monitoring 100 consecutive animals, Arrowsight’s technicians observe them in increments of 10, then aggregate to 100. And although the technicians are limited by the camera’s field of vision, they have the ability to zoom in to evaluate individual workers’ performance.

When live audits were performed in Souderton, “there were some applications that were perfect” under the AMI scoring system, according to Adam Aronson, CEO of Mount Kisco, NY-based Arrowsight. When video monitoring was performed, scores as low as 85 percent were recorded for the same procedures, and “some workers were below 40 percent compliance.” Based on Arrowsight’s work in health care, the discrepancy was hardly surprising: Presurgical procedures include scrubdown, and the assumption is that 60 percent compliance occurs. When video monitoring was done, proper handwashing only occurred 10 percent of the time.

For JBS, video auditors not only look for signs of life on the bleed rail, they zoom in to observe individual workers’ compliance with glove and knife sanitation and the depth of incisions they make to facilitate hide removal. Huskey calls this auditing for cuts, folds or flaps: An accidental or deeper than necessary incision creates a contamination point. By zooming in, the monitors can evaluate details of the carcass dressing and give JBS supervisors a tool for improving workmanship. “As a result of that, their microbial counts were reduced by about 70 percent” in the pilot, says Aronson.

Given meat and poultry plants’ previous experiences with video, remote monitoring requires a slight leap of faith. In 2004, a PETA investigator, embedded in a Heflon, AL Tyson plant, recorded abusive chicken-slaughter activities with a hidden camera. Public dissemination proved a lightning rod for animal-welfare advocates and ushered in a series of similar undercover videos. Bills banning unauthorized photographs and videos are pending in the state legislatures of Iowa, Florida and Minnesota.

A Smithfield farm in Waverly, VA was the subject of a 2007 undercover video by HSUS, which criticized the company’s animal-handling practices and took the company to task for the cramped gestation stalls. “We ended up firing three people,” Treacy recalls, and almost a third of sows have since been converted to group housing. The firm also commissioned an independent review of its animal welfare practices by Grandin and her colleague, Jennifer Woods. The report is posted at www.smithfieldfoodstoday.com, a site devoted to highlighting the company’s reformed practices.

The company also is using video to tell its story. Seven videos in the series, “Taking the mystery out of pork production,” are posted on the site of Murphy-Brown LLC, Smithfield’s livestock production subsidiary. “It’s the ultimate in transparency,” Treacy declares.

Actually, that distinction might belong to JS West, which features a live stream with six camera angles of hens in enhanced colony housing. “It’s mostly for education and outreach,” explains Benson. The hens live in a computer-controlled environment, and workers walk the barns daily as a failsafe measure. The camera’s purpose is to build public trust, not to guide animal-welfare practices. “With our live cam, we felt this was a great way to be completely transparent to everyone,” she says.

Don't fear the auditor

Audits often are anticipated with fear and loathing, regardless of whether it is an internal review, a regulatory inspection or part of a comprehensive management assessment. “It’s a vague term, but it wakes you up, and you don’t want to fail an audit,” points out Zia Siddiqi, director of quality systems for Atlanta-based Orkin LLC pest management. Proper training and clearly defined responsibilities help reduce stress levels, but the key to taming the audit beast is a well-defined management system. “You’re allowed to make mistakes, but don’t make that mistake twice,” he advises. “Be prepared to document not only corrective actions but preventive actions,” as well.

Siddiqi, who instituted an ISO 9000 quality management system at Orkin 17 years ago, sees the growth in certified standards programs as a consequence of the growth in global trade, with both ISO and GFSI migrating from Europe to North America and now taking root in other regions. Donna Garren, president and general manager of NSF Agriculture, Watsonville, CA, seconds that view, adding the growth of outcomes-oriented standards is a positive trend. “Compliance to a standard is secondary,” she adds. The real value of GFSI and FSMA is development of a plan that identifies and recognizes risk and provides a structure for managing it and improving outcomes.

After serving as one of GFSI’s first US food-safety administrators, Garren joined NSF International, the Ann Arbor, MI standards-writing organization that also delivers audit services. Garren headed the firm’s NSF Davis Fresh unit, which recently expanded its scope beyond the produce industry to include animal welfare, environmental impact and sustainable practices assessments throughout the agricultural market. Animal welfare is not simply a matter of humane treatment, Garren points out. It includes risk assessment of animal diseases, a critical skill- set and an area of particular expertise for NSF’s CMI business unit. CMI’s staff, which will be advising NSF Agriculture, operates in the UK. In working with dairy herds and other UK livestock, CMI auditors are on the front lines of preventing outbreaks such as foot and mouth disease and mad cow disease, both of which devastated British agriculture a decade ago. In 2001, an estimated 7 million sheep and cattle were destroyed while fighting a foot and mouth outbreak. Instead of focusing on the audit du jour, Garren suggests food companies consider the financial costs of practices that can allow an Avian influenza outbreak or other event that results in destruction of a flock or rejection of a crop due to excessive pesticide application.

“The whole drive today is to third-party verification,” Willamette Egg’s Satrum observes. “We literally live from audit to audit: food safety audits, animal welfare audits, insurance audits, environmental audits. It just goes on and on.”

Just as companies are concluding effective quality programs have to be organization-wide efforts and not departmentalized activities, specialists are discovering positive outcomes from stiffer oversight of other activities. When JBS workers were shown the results of their video audits, “they were astonished and surprised,” says Huskey, “but with that feedback, we saw instant improvement.”

No one likes someone looking over their shoulder, whether it’s a customer, regulator or independent auditor. But accountability and transparency are required in today’s business environment. The challenge for food industry leaders is to turn that oversight into a tool for continuous improvement rather than a scenario for second guessing.


For more information:

Kathi Brock, American Humane Association, 303-639-1198, kathib@americanhumane.org
Adam Aronson, Arrowsight Inc., 866-261-5656, adam.aronson@arrowsight.com
Donna Garren, NSF Agriculture, 734-757-0330, dgarren@nsf.org
Zia Siddiqi, Orkin LLC, 770-220-6030
Mike Simpson, Professional Animal Auditor Certification Organization, 402-403-0104

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