Recent research on third-party audits

Ronald Doering, the first president of the Canadian Food Inspection Agency and the only one I can remember, writes in his Food Law column:

ron.doeringUntil recently there has been little serious research on the most significant food safety advance in the last decade, a develop­ment that has been entirely outside the realm of public law — the extraordinary growth of third-party supplier audits. There are now over 500 food safety audit firms, many of which have global operations.

The Food Safety Service Providers, an industry association representing nine leading private food safety audit firms, asserts that its members alone conduct more than 200,000 audits and inspections in more than 100 countries each year. It has been estimated that in the U.S. the scale of private food law auditing activity is now 10 times larger than that of the federal government, more than all federal and state efforts combined. Two recently published academic studies provide inter­esting insights into several aspects of this important new area of food law.

Audits and Inspections Are Never Enough: A Critique to Enhance Food Safety (Food Control, vol. 30, issue 2) by Douglas Powell et al. identifies the many limitations of third-party audits and doc­uments several cases of major foodborne illness outbreaks linked to food proces­sors that have passed third-party audits. Audits need to be supplemented by other measures such as microbial testing, and companies must have in-house capacity to meaningfully assess the audit results. Third-party audits are part of “a shift in food safety governance away from government regulation and inspection towards the development of private food safety standards.” This study represents a cogent caution to the audit industry that they must improve their systems, and a warning to the food industry that audits are never enough.

doug.ron.2.jan.13In the latest Wisconsin Law Review American law professors Timothy D. Lytton and Lesley K. McAllister (Oversight in Private Food Safety Auditing: Addressing Auditor Conflict of Interest, 2014) provide the first comprehensive analysis of one of the most serious problems with private food safety auditing — auditor conflict of interest. Auditors are paid by the company being audited. Suppliers have an interest in finding the cheapest and least intrusive audit that will provide a certificate, and auditors have a financial incentive to reduce the cost and rigour of audits to get business in a very competitive environment. This study analyzes several oversight mechanisms that have been developed to mitigate the conflict problem, but concludes that at this time there are still too few financial incentives to assure more rigorous auditing.

Considering how few inspections are actually carried out by the Food and Drug Administration (FDA) relative to the number of businesses it is responsible for, it is ironic that the U.S. has been so reluctant to embrace more fully the advantages that third-party audits represent. Perhaps this is because President Obama is so beholden to consumer activist groups that do not trust the in­dustry, believe that only FDA inspectors can stop big bad food companies from poisoning consumers, and who refuse to recognize that it is private audits that are increasingly the drivers of enhanced food safety. Obama has declared that it is the state that has the primary responsibility for food safety, and the former FDA com­missioner dismissed audit schemes as being merely “a business strategy, not a public health strategy.”

In Canada we have always recognized that while it is a shared effort, practically and legally it is food producers that have the primary responsibility for food safety. Industry recognized some years ago that they couldn’t meet this responsibility adequately just by complying with gov­ernment regulations — that they could protect their brand from recalls, minimize foodborne illness law suits, source ingredi­ents widely and trade internationally only if, among other things, they insisted on warranty agreements from suppliers and that these were backed up by independent third-party audits. There are many legal and other problems with these relatively new instruments at this still early stage in their development, but they’ve come a long way in the last 10 years.

Finding ways to better integrate public law-based food safety regulations with private law-based certification systems may prove to be one of our more inter­esting challenges in the decade ahead.

Fine food: Salmon recalled because of potential botulism in Canada

Farquhar’s Orchards Fine Foods is recalling Farquhar’s Orchards Fine Foods brand salmon products from the marketplace because they may permit the growth of Clostridium botulinum. Consumers should not consume the recalled products described below.

salmon.cfia.botulismThe following products have been sold in Ontario.

Brand Name: Farquhar’s Orchards Fine Foods

Common Name: House Candied Salmon

Size: Variable weight

Code(s) on Product: All PACKED ON dates

UPC: Starts with 0 204109

Reason for Recall: Microbiological – Clostridium botulinum

Brand Name: Farquhar’s Orchards Fine Foods

Common Name: House Smoked Salmon

Size: Variable weight

Code(s) on Product: All PACKED ON dates

UPC: Starts with 0 204108

Reason for Recall: Microbiological – Clostridium botulinum

What You Should Do

Check to see if you have recalled products in your home. Recalled products should be thrown out or returned to the store where they were purchased.

Food contaminated with Clostridium botulinum toxin may not look or smell spoiled but can still make you sick. Symptoms can include nausea, vomiting, fatigue, dizziness, blurred or double vision, dry mouth, respiratory failure and paralysis. In severe cases of illness, people may die.

Background

This recall was triggered by the Canadian Food Inspection Agency’s (CFIA) inspection activities. The CFIA is conducting a food safety investigation, which may lead to the recall of other products. If other high-risk products are recalled the CFIA will notify the public through updated Food Recall Warnings.

The CFIA is verifying that industry is removing recalled product from the marketplace.

There have been no reported illnesses associated with the consumption of these products.

Canadian meat inspectors to inspect Canadian meat inspectors

If food safety audits and inspections couldn’t get worse, the Canadian Food Inspection Agency is bragging that it is creating Inspection Verification Teams to oversee the performance of Canada’s food safety system.

larry.health.inspectorI thought inspectors were supposed to do that?

Starting this month, six teams of three inspection verification officers will begin conducting targeted verifications at federally registered food establishments such as slaughter and meat production facilities. The verifications will focus on areas critical to the inspection and production of safe food, such as plant sanitation and the effectiveness of a company’s response to food recalls. An additional four teams will be operational by the fall.

As announced in June 2013, the Government of Canada has committed $16 million over three years to establish the Inspection Verification Teams. Their activities are over and above regular inspections conducted every day in facilities across Canada. Existing front-line CFIA inspectors will continue to conduct specified daily tasks to verify that food safety requirements are being met while the Inspection Verification Teams have a broader oversight role.

CFIA shuts down new PEI lobster plant

The first new lobster processing plant in 10 years in Prince Edward Island (that’s in Canada) has not had its registration renewed by the Canadian Food Inspection Agency (CFIA).

lobsterA CIFA spokesperson said Red Cove seafood processing was allowed to resume operations following an earlier suspension on April 14 under ongoing inspection by CFIA. On May 8, CFIA decided not to renew Red Cove’s registration.

“The CFIA has determined that adequate controls for safety were not reliably implemented in the facility on a regular basis, which is in violation of the fish inspection regulations,” the spokesperson said. “Specifically, (Red Cove Seafood Processing) was unable to consistently maintain minimum regulatory standards for construction, equipment sanitation and process controls.”

Selection brand rosemary leaves recalled due to Salmonella in Canada

Rosemary, you’re one of my favorite spices, but I always eat you cooked because of microbiological risk.

Nador Inc. is recalling Selection brand Rosemary Leaves from the marketplace due to possible Salmonella contamination. Consumers should not consume the recalled product described below.

salm.rosemary.may.14Size: 50 g

Code(s) on Product: 14014

UPC: 0 59749 88916 2

This recall was triggered by Canadian Food Inspection Agency (CFIA) test results. The CFIA is conducting a food safety investigation, which may lead to the recall of other products. If other high-risk products are recalled the CFIA will notify the public through updated Food Recall Warnings.

There have been no reported illnesses associated with the consumption of this product.

How to have fewer people barfing from food? Inspections and government are only one tool

It’s an easy story for beleaguered journalists: a belligerent government versus a belligerent union, with both making wild claims about food safety.

Lost in the rhetoric is any concern about the people who eat – pretty much all of us – and the people who barf.

The union representing federal food inspectors says Canada’s food safety system is being pushed beyond its limits.

restaurant.inspectionSome $35-million and 192 inspectors are on the food safety program’s chopping block over the next two years, according to online documents posted by the Canadian Food Inspection Agency.

The agency has also disbanded a team of inspectors dedicated to protecting consumers from food fraud throughout Metro Vancouver. The Consumer Protection Unit once boasted 11 inspectors, but that number dwindled to four due to attrition.

The federal health ministry referred questions to the CFIA, which responded to the union’s claims with a broad e-mail.

“The statements by the union are false. There have been no cuts to food safety. Canada has one of the safest and healthiest food systems in the world,” it said.

The agency acknowledged there have been recent changes to how it handles the Vancouver area.

Time to change the discussion and the approach to safe food. Time to lose the religion: audits and inspections are never enough.

• Food 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.

 

Audits 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.

21 sick, 1 dead from E. coli O157 linked to Gort’s cheese in Canada last year; source not known

Seven months after their world was shaken, the owners of Gort’s Gouda cheese farm are still working to get their business back on solid ground.

“It’s been a tough haul. We’re working hard at rebounding, it’s looking positive. It’s going to be a long haul, but that’s okay,” said Kathy Wikkerink, who owns the farm with her spouse Gary.

gorts.cheese.O157In February, the Canadian Food Inspection Agency issued a report on its food safety investigation at the farm. It was initiated on Sept. 14, 2013 following a cluster of E.coli 0157:H7 illnesses that were believed to be related to consumption of cheese products from Gort’s.

Twenty-one people were eventually reported with E.coli-related illness and recovered, while one woman died.

Pinpointing the contamination couldn’t be done.

“Despite extensive efforts, the CFIA concluded that there was no evidence available to confirm the source of the E. coli O157:H7 contamination,” states the report.

“The CFIA identified areas for improvements at the processing facility and requested Gort’s Gouda Cheese Farm to submit a corrective action plan. The company was requested to make enhancements in sanitation practices, equipment design and building maintenance.”

It adds that, “all food safety concerns identified during the investigation have been corrected. Gort’s Gouda Cheese Farm corrected other administrative and non-food safety related issues within accepted time frames.”

Kathy says the bulk of the requirements for the business involved paper work, “bigger paper trails.”

Under “root cause analysis,” the report points to raw milk cheese products.

“Overall evidence indicated that there were a number of opportunities for contamination to occur in the earlier stages of the raw milk cheese manufacturing process.

“The potential for contamination during cutting, handling and packaging was also found to be a possible risk factor.”

CFIA plays the 99 per cent numbers game

CFIA is getting into the 99 per cent game, usually reserved for hucksters on TV.

99.9 per cent sounds good, but that’s only a 3-log reduction. For food safety purposes, log-5 (99.999 per cent) to log-7 (99.99999 per cent) reductions in dangerous pathogens are often strived for.

Last week, the Canadian Food Inspection Agency announced that 99.8 per cent of whole cantaloupe samples tested negative for the presence of Salmonella (they didn’t test for Listeria, but should have).

cantaloupe.salmonellaPlaying the 99 per cent game is also terrible risk communication: it doesn’t matter how small the percentage of positive samples were if you were one of the 23 people that dies from Listeria in Maple Leaf cold-cuts in 2008.

Data and sampling are a necessary evil and I’m glad CFIA is making the results public. But testing is limited and fraught with caveats. It’s expensive, and industry has lots of data, so why not make it public, in the context of an overall approach to food safety for a specific food.

CFIA reports  a total of 499 whole cantaloupe samples were collected and tested for Salmonella bacteria, which can cause a serious illness with long-lasting effects. One sample was found to be unsatisfactory due to the presence of Salmonella.

A week later, CFIA said more than 99.9 per cent of leafy green vegetable samples had no detectable levels of bacterial pathogens and were safe to consume.

As part of a five-year microbiological plan that began in 2008/2009, the CFIA analyzed a total of 4,250 domestic and imported, whole and fresh-cut fresh leafy vegetable samples available in the Canadian market for Salmonella, E. coli O157:H7, E. coli O157:NM and generic E. coli. The fresh-cut samples were also tested for Listeria monocytogenes.

The 2009/2010 study deemed 12 samples to be “unsatisfactory” due to the presence of Salmonella, Listeria monocytogenes, and/or high levels of generic E. coli. None of the samples were found to be positive for E. coli O157:H7 or E. coli O157:NM.

Evans of CFIA gets honorary degree

Dr. Brian Evans, former chief vet at the Canadian Food Inspection Agency and the point-man on the first mad cow disease outbreak in 2003, is the first recipient of an honorary degree in veterinary medicine from the University of Calgary.

Evans is the retired executive vice-president of the Canadian Food Inspection Agency and was the country’s chief veterinary officer for 15 years.

Brian EvansHe graduated from the University of Guelph with a bachelor of science in agriculture in 1974 and a doctor of veterinary medicine in 1978.

While at CFIA, he was also Canada’s delegate to the World Organization for Animal Health (OIE) for 13 years. He was elected secretary general for the OIE regional commission for the Americas and to four consecutive three-year terms as the representative of the member countries of the Americas Region on the OIE’s executive council.

Most recently, he was appointed the international body’s deputy director general responsible for animal health, veterinary public health and international standards.

He is married to Laurianne and has four children.

And is a genuinely thoughtful dude.

Why are inspectors there? Ottawa wants power to fine meat plants for food-safety problems

The Canadian government is proposing to give itself the power to fine meat-processing plants that break hygiene and other operating rules meant to protect human health.

The Canadian Food Inspection Agency says the regulatory change would restaurant.inspectiongive it another enforcement tool to help protect consumers.

But meat industry representatives and a food safety expert are skeptical. “These proposed new fines demonstrate our commitment to ensuring that Canada’s stringent food safety requirements are being followed,” Lisa Murphy, a CFIA spokeswoman, wrote in an email from Ottawa.

Inspectors already have the power to issue written warnings to companies when problems at meat plants are found. In serious cases, the CFIA can suspend a plant’s licence and shut it down.

The CFIA said the proposed fines range from $2,000 to $15,000 for violations. They could be imposed on a company that was regularly identified for not following food safety rules.

The Canadian Meat Council represents federally inspected meat-packing and processing companies. Spokesman Ron Davidson said such fines are not needed.

“The meat industry does not believe there is a necessity for yet another enforcement tool,” he said.

Davidson wonders why the federal government isn’t seeking to apply such fines to the entire food-processing sector. He suggests Ottawa is larry.the.cable.guy.health.inspectorsingling out the meat industry.

Rick Holley, a University of Manitoba food-safety expert, said issuing fines won’t make the meat-processing sector any safer.

Holley said the main challenge the government needs to grapple with is ensuring that food-safety inspectors are rigorously trained to a uniform standard — and that the training is ongoing.

“I don’t think that this attempt is going to improve the safety of food in Canada by one iota,” Holley said.

“The real issue here is the performance of the inspectors in terms of appropriately identifying where problems are that are of significant health impact and then doing follow up.”