When examining the root causes of many incidents and recalls in the history of food safety, even the most recent ones, poor implementation of Prerequisite Programs (PRPs) often emerges as the primary reason. Despite the critical importance of PRPs, many organizations need help to implement these essential programs effectively.
As a food safety professional with ample experience in auditing, I find it equally surprising and concerning that many audits fail to identify issues with PRPs. The fundamental problem lies in the tendency of auditors to prioritize documentation over the observation of actual practices. This documentation-centric approach leads to significant areas for improvement. The mere existence of records is frequently taken as proof of compliance without thoroughly examining whether the procedures described in the documents are being effectively implemented. This superficial verification results in unnoticed PRP gaps, posing a potential risk to food safety.
Several challenges contribute to the failure of audits to identify practical issues with PRPs:
1. Time Constraints: Auditors often need more time to conduct comprehensive assessments. With a finite number of hours allocated for each audit and a long list of checks to complete, they tend to spend more time on easily accessible documentation than on more time-consuming observations and interviews.
2. Auditor Expertise: The effectiveness of an audit heavily depends on the expertise and experience of the auditor. Auditors who are less familiar with the specific nuances of a particular production environment are more likely to rely on documentation as a safe and straightforward assessment method.
3. Lack of Direct Observation: Direct observation of practices is crucial for assessing the implementation of PRPs. However, audits that focus predominantly on paperwork neglect this aspect, missing out on critical insights that can only be gained through on-the-ground inspection and interaction with staff.
When audits fail to identify issues with PRPs, food businesses continue to operate with fundamental flaws in their food safety systems. This increases the risk of contamination and foodborne illnesses, endangering public health and exposing companies to potential legal and financial repercussions. These failures undermine the entire purpose of food safety audits and the trust placed in them by consumers and regulatory bodies.
To enhance the effectiveness of food safety audits and ensure that PRPs are thoroughly evaluated, a few strategies could be employed:
1. Balanced Approach: Audits should strike a balance between documentation review and practical observation. While paperwork is necessary for verification, it should not overshadow the importance of directly inspecting facilities and practices. Allocating more time for audits will allow auditors to conduct a more thorough assessment, including spending adequate time observing operations, interviewing staff, and verifying that PRPs are correctly implemented.
2. Enhanced Auditor Training: Comprehensive auditor training on the specific requirements of different food production environments will improve auditors’ ability to identify practical issues. This includes understanding the nuances of various PRPs and recognizing potential red flags during inspections and their implications for food safety. Enhanced training ensures auditors are better equipped to make informed assessments beyond the surface level.
3. Use of Technology: Incorporating technology into the audit process will enhance accuracy and efficiency. For example, using mobile devices to record observations in real-time or employing digital checklists streamlines the process and ensures that no critical aspect is overlooked. Technology will also facilitate better tracking and analysis of audit findings, leading to more actionable insights while giving auditors the tools for a risk-based approach and more time for the shop-floor assessment.
It is important to note that audits alone are not a panacea for issues with PRP implementation. However, they should be instrumental in identifying poor practices and helping manufacturers address them. By adopting a more comprehensive approach to auditing, the food industry will improve the effectiveness of PRPs and, consequently, the overall safety of food production systems.
By Tülay Kahraman
June 23, 2024
