About time: FDA halts company’s peanut butter operations

Once again, audits, inspections and the buyers at some of the biggest retail chains in the U.S. (and globally) have imperiled consumers by allowing shoddy product on the shelves.

According to AP, the U.S. Food and Drug Administration has halted operations of the country’s largest organic peanut butter processor, cracking down on salmonella poisoning for the first time with a new enforcement authority the agency gained in a 2011 food safety law.

But I keep getting told the Food Safety Modernization Act is about prevention?

FDA officials found salmonella all over Sunland Inc.’s New Mexico processing plant after 41 people in 20 states, most of them children, were sickened by peanut butter manufactured at the plant and sold at Trader Joe’s. The suspension will prevent the company from distributing any food.

Sunland sold hundreds of products to many of the nation’s largest grocery chains.

Nothing will change until retailers get their collective heads out of ______ and start marketing microbial food safety so consumers have some semblance of choice.

GAO: FDA can better oversee food imports by assessing and leveraging other countries’ oversight resources

Audits and inspections have problems – so the feds should leverage resources in other countries to monitor the safety of U.S. food imports.

I see problems there as well.

A new report by the U.S. Government Accountability Office concludes the U.S. Food and Drug Administration should use comparability assessments that can enable the agency to leverage other countries’ oversight capacity and enforcement authority. This could result in some of the same advantages as the equivalence approach used by the U.S. Department of Agriculture’s Food Safety Inspection Service (FSIS) and the European Union (EU) before specific food products can be imported.

Unless, like USDA, they just stop doing the equivalency audits.

Or, as argued by FDA-types, the agency expects few countries to seek comparability with the United States because, in part, most countries will not meet the FDA requirement that a foreign government’s domestic and export food safety systems be comparable to the U.S. system for food products under FDA’s jurisdiction. According to FDA documents, some countries have robust export certification programs for a specific food product, but their overall food safety systems, including domestic production systems, may not be comparable with those of the United States. Consequently, FDA would be unable to leverage the resources of countries with comparable systems for just one food product, such as seafood, which FDA has experience in assessing through its foreign country assessments. 

Show us the data, forget the faith; food sickens millions as company-paid checks find it safe

William Beach loved cantaloupe — so much so that starting in June last year he ate it almost every day. By August, the 87-year-old retired tractor mechanic from Mustang, Oklahoma, was complaining to his family that he was fatigued, with pain everywhere in his body.

On Sept. 1, 2011, Beach got out of bed in the middle of the night, put his clothes on and walked into the living room. His wife, Monette, found him collapsed on the floor in the morning. At the hospital, blood poured from his mouth and nose, splattering sheets, bed rails and physicians.

He died that night, a victim of Listeria monocytogenes. Beach was one of 33 people killed by listeria that was later traced by the U.S. Food and Drug Administration and state officials to contaminated cantaloupes from one Colorado farm. It was the deadliest outbreak of foodborne disease in the U.S. in almost 100 years.

“He died in terror and pain,” says his daughter Debbie Frederick.

That’s how Stephanie Armour, John Lippert and Michael Smith begin their food safety and aduits and inspections opus for Bloomberg. The Today Show may run a version this morning, because I taped a bit for it at Brisbane’s Channel 7 studios last week.

About seven weeks after Beach started eating cantaloupes, a private, for-profit inspection company awarded a top safety rating to Jensen Farms, the Granada, Colorado, grower of his toxic fruit. The approval meant retailers such as Wal-Mart Stores Inc. (WMT) and Wegmans Food Markets Inc. could sell Jensen melons.

The FDA, a federal agency nominally responsible for overseeing most food safety, had never inspected Jensen.

During the past two decades, the food industry has taken over much of the FDA’s role in ensuring that what Americans eat is safe. The agency can’t come close to vetting its jurisdiction of $1.2 trillion in annual food sales.

In 2011, the FDA inspected 6 percent of domestic food producers and just 0.4 percent of importers. The FDA has had no rules for how often food producers must be inspected.

The food industry hires for-profit inspection companies — known as third-party auditors — who aren’t required by law to meet any federal standards and have no government supervision. Some of these monitors choose to follow guidelines from trade groups that include ConAgra Foods Inc. (CAG), Kraft Foods Inc. and Wal-Mart.

The private inspectors that companies select often check only those areas their clients ask them to review. That means they can miss deadly pathogens lurking in places they never examined.

What for-hire auditors do is cloaked in secrecy; they don’t have to make their findings public. Bloomberg Markets obtained four audit reports and three audit certificates through court cases, congressional investigations and company websites.

Six audits gave sterling marks to the cantaloupe farm, an egg producer, a peanut processor and a ground-turkey plant — either before or right after they supplied toxic food.

Collectively, these growers and processors were responsible for tainted food that sickened 2,936 people and killed 43 in 50 states.

“The outbreaks we’re seeing are endless,” says Doug Powell, lead author of an Aug. 30, 2012, study on third-party monitors called “Audits and Inspections Are Never Enough.” Powell, a professor of food safety at Kansas State University, says Americans are at risk whenever they go to a supermarket.

“You need to be in a culture that takes food safety seriously,” Powell says. “Right now, what we have is hidden. The third-party auditor stickers and certificates are meaningless.”

In some cases, for-hire auditors have financial ties to executives at companies they’re reviewing. AIB International Inc., a Manhattan, Kansas, auditor that awarded top marks to producers that sold toxic food, has had board members who are top managers at companies that are clients.

Executives of Flowers Foods Inc. (FLO), which makes Tastykake, and Grupo Bimbo SAB in Mexico City, which makes Entenmann’s pastries, Sara Lee baked goods and Wonder Bread, serve or have served on AIB’s board.

“There’s a fundamental conflict,” says David Kessler, a lawyer and physician who was FDA commissioner from 1990 to 1997. “We all know about third-party audit conflicts. We’ve seen it play out in the financial world. You can’t be tied to your auditors. There has to be independence.”

As flawed as the inspection system is in the U.S., it’s more problematic with imported food, especially coming from countries with lower sanitary standards, says Michael Doyle, director of the University of Georgia’s Center for Food Safety. In some emerging markets, farms growing food for export to the U.S. aren’t inspected at all.

The U.S. will import half of its food by 2030, up from 20 percent today, Doyle says. Bloomberg Markets visited growers in China, Mexico and Vietnam and found unsanitary conditions for produce, fruit and fish exported to the U.S.

Auditors evaluate their clients using standards selected by the companies that pay them, says Mansour Samadpour, owner of IEH Laboratories & Consulting Group in Lake Forest Park, Washington, which does testing for the FDA. The auditors sometimes follow a checklist that the company they’re inspecting has helped write.

“If you have a program for adding rat poison to a food, the auditor will ask, ‘Did you add as much as you intended?”’ Samadpour says. “Most won’t ask, ‘Why the hell are we adding poison?”’

Not only has the government outsourced auditing to the food industry; the auditors themselves often outsource their vetting to independent contractors — people over whom they don’t have direct management control.

While Primus Labs declined to comment directly for this story, it did supply a response from its law firm, Kaufman Borgeest & Ryan LLP in New York. Auditors, the statement says, serve at the pleasure of their clients and cannot go beyond what they are asked to do.

“Third-party auditing will continue to be as effective as those requiring the audits (buyers/suppliers) and the audited suppliers make them,” the law firm writes. James Markus, a lawyer representing Jensen, didn’t return calls seeking comment.

From the outset, the FDA lacked the resources to inspect all of the country’s food producers.

The food industry moved to fill that vacuum with private auditors in the 1990s. Danone SA (BN), Kraft, Wal-Mart and other companies created the Paris-based Global Food Safety Initiative in 2000 to write guidelines for third-party auditors.

The program, whose vice chairman is Frank Yiannas, Wal- Mart’s vice president for safety, requires companies to be audited once a year. It doesn’t mandate testing for pathogens. In 60 manufacturing plants, Wal-Mart suppliers reported a third fewer recalls in the two years after adopting GFSI standards, Yiannas says.

In some cases, companies use their own auditors to check suppliers. In 2002 and 2006, Nestle USA, a subsidiary of Vevey, Switzerland-based Nestle SA (NESN), refused to use Peanut Corp. of America as a supplier. Nestle inspectors found rodent carcasses and pigeons in Peanut Corp.’s Plainview, Texas, plant.

Nestle’s rejection didn’t stop Lynchburg, Virginia-based Peanut Corp. from doing business with other customers or seeking approval from third-party auditors. In 2008, AIB International auditor Eugene Hatfield gave Peanut Corp.’s Blakely, Georgia, plant a “superior” rating.

And there’s a whole lot more. Our take on all this is below:

 

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.

Food safety culture is key for XL; but these comments are great

I don’t know Alex Stanoprud but he writes in the Montreal Gazette this morning as someone who has worked for the Canadian Food Inspection Agency his entire career,

“I wanted to set the record straight on the recall of contaminated beef from the XL Foods plant in Alberta.

“Readers should know that E. coli contamination comes from excrement. When animals are slaughtered, there is excrement on their hides. (Go to any farm and you will see animals with some excrement on them.) If precautions are not taken during the removal of the hide in the slaughtering process, the excrement can be spread from the hide to the meat carcass.

“The article “Butchers troubled by recall” (Gazette, Oct. 2) quotes a Montreal restaurateur who says that because the beef he serves is kosher, it is less likely to have E. coli contamination. But kosher practices for slaughtering animals have nothing to do with how the hide of the animal is taken off. The same abattoir, same personnel, and same way of removing the hides and the intestinal tract, are involved.

“Comments by the head of the union that represents federal meat inspectors, suggesting more inspectors are needed to prevent such outbreaks, are misleading. Of course the union wants the government to hire more inspectors; that will put more revenue into the union coffers. But an increase in the number of inspectors does not mean more contamination will be discovered.

“Can an inspector identify a steak that has been contaminated? Absolutely not. Can the inspector take samples? Yes, but in all likelihood that one contaminated steak will be missed in his or her sample-taking. There is no way that even an army of inspectors can detect bacteria on a product once it gets there. Testing will give a snapshot of bacterial conditions, but it will not prevent food-borne illness unless you test every piece — and that’s impossible.

“The U.S. and Canadian inspection agencies are aware of this fact. That is why they have introduced a system called Hazard Analysis Critical Control Points for meat plants. Under HACCP, inspectors use a document that contains a checklist of items that need to be evaluated in order to determine whether companies have, and use, all the necessary recourses to prevent food contamination. In the case of the XL Foods contamination, we can only assume that this system failed. Why? We can only speculate that neither the company nor the inspectors did their job.

So let me set the record straight. The problem has nothing to do with whether meat is fresh or frozen, whether it is organic, or whether it is kosher. And it not merely through more testing — and definitely not through the hiring of more inspectors — that we will prevent foodborne illness. The solution is for Ottawa to send qualified auditors into the plants on a regular basis, to see if the companies, and the inspectors, are doing their job.

All of a sudden there is an outbreak and a team of experts from the Canadian Food Inspection Agency is being sent to find the culprit. Maybe, instead of adding more inspectors and spending taxpayers’ dollars to no avail, this team should have a permanent place in the industry.”

Our version on this is available here: http://www.sciencedirect.com/science/article/pii/S0956713512004409?v=s5

Food Control

D.A. Powell, S. Erdozain, C. Dodd, R. Costa, K. Morley, B.J. Chapman

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.

Food safety ultimately producers responsibility

The ultimate responsibility for food safety lies with producers and not auditors, inspectors or government agencies, according to Doug Powell from Kansas State University.

In a paper published in Food Control, Doug Powell et al. critiqued the limits food safety audits and inspections and provided recommendations for strengthening the system.

In the “Audits and inspections are never enough: A critique to enhance food safety” paper, they noted 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.  

They identified audit reports as useful if the purchaser who requires them reviews the results, understands the risks addressed by the standards and makes risk-reduction decisions based on the results.

“From past examples, there appears to be a disconnect between what auditors provide (a snapshot) and what buyers believe they are doing (a full verification of product and process).”

Powell, a professor of food safety at Kansas State University, told FoodProductionDaily.com that everyone talks a good food safety game but it is the companies who are ultimately responsible for ensuring food is safe.

“Any inspection is only a snapshot but it can still provide valuable information.

“Take restaurant inspections, they are made public and are subject to public accountability but that doesn’t happen in food processing plants.”

Powell added that the industry needs to get ahead of and stop reacting to food safety
concerns.

“Outbreaks culminate in a bunch of mistakes, they are not a random act of god.

“With most food we can’t be sure if it is luck or if firms are doing the right things but they label if it is healthy, organic, sustainable so why not, here’s what we do to ensure food safety.”

“Audits and inspections are not enough, when there is an outbreak the public response is huge and it gets them thinking about it.”

When asked if a lack of resources was the problem, he said: “Economics always play a role with low margins and needing to maximise turnover but you are only as good as your frontline employees.

“USDA and FDA are doing all they can with their resources, the onus is on food producers who make the food, as an outbreak can take you down.”

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.

They concluded: “A common thread in all of the outbreaks described is a clear lack of food safety culture among the implicated companies. Companies who blame the auditor or inspector for outbreaks of foodborne illness should also blame themselves.” 

NC cantaloupe grower lacked audits, traceability; all melons recalled

Food safety needs to be marketed at retail, otherwise consumers have no idea what they are buying.

Hucksters and posers can gas on about how their food is natural, sustainable, local and comes from a farmer I can look in the eye, but I’d rather know the food safety program behind the fruit and veg, along with the data to verify things are working.

Few hawkers, at a market or a supermarket, can answer those questions.

Consumers are left with faith-based food safety.

That faith usually rests with buyers at supermarkets and retailers.

So when it was revealed that Burch Farms had to recall the entire season’s worth of rock and honeydew melon because listeria was found and then it was discovered they had never had a food safety audit — a standard but inadequate minimal requirement to secure retail space — I wondered, who buys this stuff?

“The cantaloupes and honeydew melons involved in this expanded recall were sold to distributors between June 23rd and July 27th, in the following states: FL, GA, IL, KY, MA, MD, ME, MI, NC, NH, NJ, NY, OH, PA, SC, and VA, VT and WV. The melons may have further been distributed to retail stores, restaurants and food service facilities in other states."

Complete distribution details on the melons are not available, according to the U.S. Food and Drug Administration.

Everyone buys it.

The Packer reports today that Listeria contamination at the Burch Farms melon packing facility in Faison, N.C., was confirmed on Aug. 13.

Company spokeswoman Teresa Burch said it has not had its cantaloupe operation audited by a third party for food safety practices, and although the company has traceability programs for other items, there is none in place for its melons.

Burch Equipment LLC, doing business as Burch Farms, originally recalled about 5,200 cantaloupes July 28 after the U.S. Department of Agriculture’s Microbiological Data Program found listeria on one melon at retail during a random sampling.

The grower expanded the recall to include 188,900 cantaloupes Aug. 3 and corrected the variety from athena to caribbean golds. That expansion came after the FDA revealed it had found “unsanitary conditions” at the Burch packing shed.

Owner Jimmy Burch Sr. said he uses the sanitizer SaniDate in his packing facility’s water. According to the Burch Farms website, the operations are audited by PrimusLabs.

PrimusLabs in-house counsel Ryan Fothergill confirmed that the company has audited the leafy greens processing and field operations at Burch Farms but not the cantaloupe operation. Fothergill said Primus records show its staff was last at the Burch operation in March.

Burch said he planted only about 10 acres of honeydews for this season. The entire crop went to wholesalers. He said his farm has not had food safety issues in the past.

Of course not. Ignorance is bliss. And that’s the way growers and sellers prefer it. Market food safety at retail.

Learning from strawberries, spinach and melons: promote safe food practice before the next outbreak

In 1996, California strawberry growers were wrongly fingered as the source of a cyclospora outbreak that sickened over 1,000 people across North America; the culprit was Guatemalan raspberries.

After losing $15-20 million in reduced strawberry sales, the California strawberry growers decided the best way to minimize the effects of an outbreak – real or alleged – was to make sure all their growers knew some food safety basics and there was some verification mechanism. The next time someone said, “I got sick and it was your strawberries,” the growers could at least say, “We don’t think it was us, and here’s everything we do to produce the safest product we can.”

In Sept. 2006, an outbreak of E. coli O157:H7 killed four and sickened at least 200 across the U.S. This was documented outbreak 29 linked to leafy greens, but apparently the tipping point for growers to finally get religion about commodity-wide food safety, following the way of their farmer friends in California, 10 years later.

In 2011, Jensen Farms, an eastern Colorado cantaloupe grower produced melons that killed 32 and sickened at least 146 with listeria in 28 states. One grower trashed the reputation of the revered Rocky Ford Melon: plantings this year are expected to be down 75 per cent.

Now the Rocky Ford Growers Association has turned to government-delivered food safety audits rather than third-party audits, and committed to emboss a QR code on every melon it slates for retail sale. This QR code will tell consumers where the melon was grown, harvested, and prepared.

Location doesn’t mean safety. Include the production details.

In Aug. 2011, Oregon health officials confirmed that deer droppings caused an E. coli O157:H7 outbreak traced to strawberries, many sold at roadsides, that sickened 14 people and killed one.

So when NPR asks, Are local salad greens safer than packaged salad greens, it’s the wrong question.

It’s not whether large is safer than local, conventional safer than organic: it’s about the poop, and what any grower is doing to manage the poop. Or risks.

Any farm, processor, retailer or restaurant can be held accountable for food production – and increasingly so with smartphones, facebook and new toys down the road. Whether it’s a real or imaginary outbreak of foodborne illness, consumers will rightly react based on the information available.

Rather than adopt a defensive tone, any food provider should proudly proclaim – brag – about everything they do to enhance food safety. Explanations after the discovery of some mystery ingredient, some nasty sanitation, sorta suck.

Microbial food safety should be marketed at retail so consumers actually have a choice and hold producers and processors – conventional, organic or otherwise – to a standard of honesty. Be honest with consumers and disclose what’s in any food; if restaurant inspection results can be displayed on a placard via a QR code read by smartphones when someone goes out for a meal, why not at the grocery store? Or the school lunch? For any food, link to web sites detailing how the food was produced, processed and safely handled. Manage the poop, manage the risk, brag about the brand.

Berry, greenhouse growers work on food safety

The California Strawberry Commission is in the midst of its second food safety risk assessment.

The Packer reports the commission itself — not third-party auditors — is doing the assessment, following the harvest gradually from south to north. The work began in late 2011, and should be completed sometime this year.

Groups like Ontario greenhouse veggie growers require that all members must pass an annual third-party food safety audit.

Third-party audits alone can be a useful tool but not enough. Some individual greenhouse operations participate in additional auditing and traceability schemes, but not everyone; and any commodity is only as good as its worst grower.

The California strawberry types are focusing on field issues such as water, wildlife, compost and labor because there are the major potential sources of foodborne illness singled out by the U.S. Department of Agriculture and others.

Carolyn O’Donnell, communications director for the Watsonville-based commission, said, “We have a hand-harvested crop, so we’re dependent on making sure farm workers who are the last people to touch strawberries before consumers do are aware they have a real important step in the food safety process.”

The same group of commission representatives is doing the assessment in every region of the state.

On its website, the commission recently expanded its food safety section at www.calstrawberry.com/members/fsp.asp.

The commission is also working with berry growers in Oregon and Washington to support their efforts in food safety education.

Following a deadly E. coli outbreak in July 2011 that was the result of a deer incursion in an Oregon strawberry field, growers in the state decided to take preventive measures in preparation for the 2012 season.

Laura Barton, trade development manager with the Oregon Department of Agriculture said, “It doesn’t matter what size grower is involved. It only takes one berry to impact the entire industry. One of the challenges we identified when we started talking about this was how to find all of the smaller growers. It’s not like there is a list.”

‘If there’s a cow within the next galaxy, they’re not going to buy;’ tomato growers frustrated with audit fatigue, ‘shower science’

Doug Ohlemeier of The Packer revisits an early Feb. 2012 meeting of tomato growers, shippers, repackers, buyers, regulators and auditors in Florida to pull out a few golden quotes.

Billy Heller, chief executive officer of Pacific Tomato Growers Ltd., Palmetto, Fla., expressed disappointment with what he calls “shower science,” the protocols auditors and customers come up with that may not be practical.

“The differentiation is that someone as a customer says they’re going to be different and will say if there’s a cow within the next galaxy, they’re not going to buy. I can live with almost all of it, but not the ‘shower thoughts.’ It shouldn’t be in there if they’re not supported by science. Opinions don’t work.”

In a discussion about birds roosting on electric poles near tomato field bins, Heller said Florida growers must deal with a variety of wildlife, including lizards and alligators.

If auditors regulate how close wildlife can be to fields, it should be a science-based rule, he said.

Drew McDonald, Salinas, Calif.-based vice president of quality and food safety for Danaco Solutions LLC, Highland Park, Ill., said each circumstance is different.

“What we don’t want to do is throw the baby out with the bath water and remove all poles and eliminate all birds. I’m not exaggerating when I say we had a customer saying there’s too much dirt (in the field). We can get a little crazy here but these are common-sense things. People agree they don’t want bird droppings on fresh produce, but what they disagree on is ways to prevent that.”

Third-party audits are one component of food safety; just one

The former big cheese at CFIA says the most significant food safety development in the last decade has occurred outside public law — the extraordinary growth in the role of private-sector traceability systems characterized by third-party audits.

Ron Doering, a past president of the Canadian Food Inspection Agency who practices food law in the Ottawa offices of Gowling Lafleur Henderson, LLP, writes in his monthly column for Food in Canada that large processors and retailers are requiring their suppliers to undergo regular inspections by third-party auditors. Producers, ingredient suppliers and processors must no longer simply have their own quality systems and meet government regulations; now they have to sign onerous supplier warranty agreements and open up their businesses to multiple audits. But these systems and their audit schemes have gone through some significant growing pains that have served to seriously undermine their credibility.

Doering says part of the problem seems to be confusion about the role of the auditor.

David Rideout, Canadian food safety expert, SQF auditor and trainer, says,
“Third-party auditors have to identify objective evidence of compliance or non-compliance and understand that they are not doing second-party audits. My job is not to provide guidance and advice to the company; if I do, my manager rejects my audit, as SQF auditors must draw a clear line between third-party (non-consultative) audits and providing advice to the company, which is the role of second-party audits.”

The largest international effort to bring greater rigor and standardization to third-party audit systems is the Global Food Safety Initiative (GFSI), started 10 years ago, but only with improved training, more rigorous certification and systems that audit the auditors can third-party audits regain the public’s confidence.

And, as food safety expert Doug Powell of Kansas State has said, “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.”