Third party audits of produce are relatively new phenomena. Fueled primarily by the retail sector’s demands for safe year-round supplies of fresh fruits and vegetables, there is a serious industry-led effort underway to evaluate primary production and the resulting supply chain.
While the third party audit model has some similarities with regulatory inspections, there are major differences; Third party audits are buyer driven and may contain some unscientific provisions (one insect in a package, even an intermittent mosquito or ant) fails the audit. Another automatic failure often found in third party assessments is the provision for a blood and body fluid policy. It is universally agreed that the risk of HIV transmission is zero through food, and other bloodborne risks are very remote. Yet, the failure to have a policy on bloodborne pathogens is totally unacceptable to buyers.
There is no sound scientific reasoning behind provisions like these, yet since it is a buyer-driven risk assessment, these “hazards” to the retailer and his “business” are very real.
The standards set by retailers are mostly reasonable, but are often defined in minutia. There may be numerous questions that are so closely related that details become burdensome. For example, there are often a half dozen questions or more on rodent traps alone that must be evaluated independently, such as; are they positioned correctly, numbered, secured, clean, marked as monitored, kept on a schematic, with wall markings, in sufficient number, in sound condition, etc., etc. The intention is to cover every possible threat that a rodent will enter a building without being trapped or poisoned.
The detailed nature of audits sometimes lasting several days, with up to 500 individual questions, and often occurring multiple times in a year can be vexing, counterproductive and exhausting to all involved. Add to this that third parties often demand scientific programs and science-based risk assessments from operators unprepared through education or experience to provide such reasoning, and you have a problematic and sometimes dysfunctional system.
A huge gap emerges between the food safety expert-auditor and his “bible of standards”, and those just now becoming familiar with basic food safety concepts.
Auditors are often the first and primary source of scientific information for produce-facility operators unfamiliar with concepts such as Free Chlorine, Oxidation-Reduction Potential, microbial sampling plans, and interpretation of microbial testing results, ATP bioluminescence technology and other sanitation assessments and controls. Auditors often find themselves as much educating the operator as evaluating their performance. The auditor on the other hand often finds the produce-production manager assigned to food safety educating him on what things really work.
There is a notable lack of food safety knowledge at the primary producer level but there may also be a lack of traditional agricultural knowledge on the part of the auditor. Few auditors have the wide range of experience in public health protection, food safety, environmental health, water, chemistry, vector control, and the life sciences to truly provide an expert evaluation of safety in the agricultural world. Furthermore, it takes years of experience in the field for even qualified auditors to begin to understand the wide range agricultural and facility environments they must work in.
While food safety experts, production managers, and business owners struggle with these issues in produce safety, we should keep in mind that the findings of audits will not necessarily always be indicative of risks, and food safety programs no matter how well intentioned will not always prove effective given the robust exposures often encountered in farming environments. We are yet to stop the harvesting of foods where migratory birds have zeroed in, controlled floods, shot every wild pig, or figured out how to keep deer from jumping 8 foot fences to get to crops.
In light of all the obstacles, it’s encouraging to see contamination events caught quickly, and exposures kept small. More and more the contaminated produce that comes to light is recalled and/or production is stopped before a wide-scale outbreak occurs. This speaks to the food safety efforts of industry as we try to limit the inevitable exposures through testing and intensive traceability systems. Re-call systems are developed with computerized tracking of lot code information, and they recently have proven effective at preventing grand exposures through contaminated produce common just 2 or 3 years ago.
The produce sector is unique perhaps in its willingness to accept strict third party oversight, government regulation, and also to adopt and embrace food safety systems. Given enough time, the safety of produce will be assured. In the meantime, many of us have a lot of work to do.