What is the real value of audits?
Recall questions validity of inspections
The recent recall of eggs, representing approximately 2% of national production involving Wright County Eggs and Hillandale of Iowa functioning as an integral unit, has raised the question of the value of audits. Phillip Brasher writing in the Des Moines Register cites concern at Costco Wholesale Corp. since its auditors failed to detect the apparent deficiencies in the facilities operated by its egg supplier. It is presumed that the SQF Institute certified the plants in question.
From personal experience, audits conducted on behalf of stores and chains including the suppliers complying with the SQF program involve reviews of documentation in addition to an examination of facilities by auditors with varied experience and training in recognizing defects which have potential significance to the health of consumers.
The glaring deficiency in the SQF system is that the standards and procedures commence at the point at which eggs enter the plant. When considering a disease where the pathogens is within the shell, it is inexplicable why SQF requirements do not mandate that eggs entering a plant to be packed either on- or off-line should be derived from flocks certified free of SE infection.
The USDA-Agricultural Marketing Service is more concerned with egg grade and organoleptic aspects of shell and internal quality than with hygienic production and the potential for infection. Its entire approach is focused on physical quality and their program effectively reflects the realities of the egg industry in the mid-1960s.
The basic defect in our system is that until the introduction of the FDA Final Rule no single agency was responsible for ensuring safety of eggs and specifically SE. The industry has most certainly evaded its responsibility by adhering to the voluntary UEP program which can best be characterized as “don’t look until it’s too late” which has been self-serving and ultimately detrimental in terms of consumer confidence.
The inadequate non-monitored program has ultimately affected all stakeholders with the potential of elevating SE to the status of the “new cholesterol” in terms of consumer image. The lack of concern for prevention of SE has reflected unfairly on producers adhering to more stringent state egg quality assurance programs such as those introduced in Pennsylvania and California in addition to the producers of the leading nationally-distributed branded specialty egg.
Brasher notes that the USDA-AMS audited Wright County packing plants in 2009 assigning grades above 90%. Had the officials responsible for drawing up the audit documents included a review of SE environmental assays, recent events may have been averted. Unfortunately many government officials including those responsible for implementing the new FDA Final Rule have limited experience, demonstrate bureaucratic compartmentalization and their approach to the challenges which they face obviously lack imagination, initiative and a sense of urgency.
Unfortunately the same approach used to develop and implement SQF and similar auditing programs have been applied by both private and public sector auditors. It would be unfortunate if necessary changes create more demand for paperwork. The current auditing of “safety and quality” with an emphasis on documentation can best be characterized as an expensive pantomime with the end objective of obtaining a piece of paper to appease the members of the FMI and the NCCR.
What our industry requires is effective leadership based on sound scientific principles and common sense. Inappropriate standards and untrained auditors coupled with a disinclination to make appropriate financial commitments to safety and quality will merely perpetuate the current situation to our lasting detriment.