Is it possible to pass a GFSI audit with a poor food safety culture?
At last weeks webinar Tips to measure food safety culture and food safety behavior we had some great comments and questions one of which is the focus of our latest poll.
Please vote and let us know what you think?
Regards,
Simon
This happens all the time. A company ignores food safety for 9 or 10 months and then there is a big push to get everything in line prior to the audit. Once the audit results are in, back to business as usual. It's sad, but true - in many cases management simply sees a certification as a marketing tool.
It's possible to be constantly audit ready because employees are made to be ready rather than want to be ready. You will pass the audit but what dangers lurk below the surface? No one is thinking about food safety and does not notice a problem they encounter that was not part of their "training." Or worse, a disgruntled person with a tendency for bad behavior becomes a saboteur.
More common than not. I agree with ganderson64, there is intense focus on getting records and other paperwork in order the month or 2 prior to the audit. This "busy work" does not create or contribute to a food safety culture. In my opinion, the fact that there is this mad scramble to pull everything together specifically for the GFSI audit is evidence for the lack of a food safety culture. In a perfect world, with perfect companies that have an established food safety culture, facilities would be audit ready 24/7 and there would be no need for an intense preparation period. We all know of facilities, either firsthand or through news stories, that have received a very high score on their GFSI audit, only to be disapproved by your company's audit or worse, be the source of a foodborne illness outbreak. Consequently, the GFSI status of a facility does not carry the weight with a customer as was intended, many customers are conducting their own audits in addition to the GFSI audit. Those facilities with a multitude of customers end up going through a multitude of different audits, at a frequency of one or more a month. One might think it would be good to have this much scrutiny....but we all know the time required for each audit adds up and that is time not spent on "real" food safety activities such as developing, implementing and measuring food safety behavior. My company, like most/all, is a supplier and a customer, the audit situation is quite the burdensome paradox.
To tail onto VickieLew - What I have experienced is disregard for what we quality professionals call the cost of quality. These costs are split between prevention, inspection, and failure (internal & external). Quality activities do nothing but subtract from the bottom line and every dollar reduced from the overall cost of quality goes directly to the pre-tax profits of the company. What we are attempting to do in creating a positive food safety culture is spend more dollars on prevention which in turn reduces the dollars spent in the other cost of quality areas. Companies that embrace a food safety culture and a general quality culture can often see their overall cost of quality decrease by 50-70% while simultaneously increasing market share. It is truly a proven methodology.
It is frustrating to experience the push to get things in line prior to an audit only to see those cost swept away with zero return on investment as things return to the status quo.
As quality professionals it is our responsibility to keep fighting the good fight.
I found ganderson's statement "Quality activities do nothing but subtract from the bottom line and every dollar reduced from the overall cost of quality goes directly to the pre-tax profits of the company. What we are attempting to do in creating a positive food safety culture is spend more dollars on prevention which in turn reduces the dollars spent in the other cost of quality areas. Companies that embrace a food safety culture and a general quality culture can often see their overall cost of quality decrease by 50-70% while simultaneously increasing market share. It is truly a proven methodology" spot on.
It's probably true that most Production Management (and some Top Management) agree that "Cost of Quality" means that investing in Food Safety and Quality systems are a financial burden that simply cost the company money and are just a necessary evil. The challenge is to provide to them solid evidence that what a positive food safety culture actually means is that the company does realize financial benefit through these efforts. We, as food safety and quality professionals, have it on our shoulders to show through sound metrics (trending, cost benefit analyses, etc.) that ultimately the company embracing these concepts does become more successful than if they ignore them.
"My company, like most/all, is a supplier and a customer, the audit situation is quite the burdensome paradox." -VickieLew
The answer to this, of course, is more resources. However, at what point does more resources begin to price products out of the consumer market?
Is GFSI proving to not be the promised, "One Audit For All?" Is GFSI just a step in the direction we need to go? Do we need a new paradigm for verifying food safety compliance? Or will the requirements become ever more so burdening that our core food safety elements do not our full attention? Is that a false choice?
Btw, brilliantly stated post, VickieLew.
"My company, like most/all, is a supplier and a customer, the audit situation is quite the burdensome paradox." -VickieLew
The answer to this, of course, is more resources. However, at what point does more resources begin to price products out of the consumer market?
Is GFSI proving to not be the promised, "One Audit For All?" Is GFSI just a step in the direction we need to go? Do we need a new paradigm for verifying food safety compliance? Or will the requirements become ever more so burdening that our core food safety elements do not our full attention? Is that a false choice?
Btw, brilliantly stated post, VickieLew.
Is GFSI proving to not be the promised "Once Certified, Accepted Everywhere?" as is STILL on the GFSI site?
Oh hell no.
I can tell you how many people have called me and said "Gee! You've got a GFSI Certification! that means you have all your ducks in a row and I don't need to have you fill in a 35 page self-audit, send in hundreds of documents, and re-type your existing information every damn time you want to send us a new item!"
That has happened exactly zero times.
So, what's happening is NOT "You're certified? AWESOME! You've got must have a working program because you've demonstrated it by passing your audits!"
What is happening is "Oh, you've got a (insert GFSI cert here)?, GREAT! Send me the certification. And send me the audit. And send me the corrective action items along with root cause analysis! And show me some trend tracking to show that your root cause analysis actually mitigated the issue.
Now, how about you fill out this huge self audit, fill in my allergen form for me rather than sending your already vetted form, send me copies of (huge list) of policies, your HACCP plan, your flow diagrams, and about 90 other certificates and forms."
it's one more thing to have to keep track of and have on hand to be able to fire off to customers in an email at the expense of actually getting on the floor and seeing how things are running and working on improving the process.
I'd say it is possible to pass GFSI with poor food safety culture. As much as I would like that not to be the case, it really is. I have audited companies before and thought "there's no way they are going to pass", and then they do. GFSI unfortunately seems to be getting watered down (it doesn't look great for certifying bodies to fail 50% of their clients) by marginal companies that can talk their way out of situations. As other posters have said, the audit is just a snapshot of what the company looks like for 2-3 days. It's usually not too hard to put on a good face for a few days and then get back to normal once the audit is over.
The challenge, I would say, is to remain GFSI certified with poor food safety culture. A good auditor, if they have been to the site before, or has looked at trends can usually spot the flaws over time. The first time through, the auditor may be doing more of a general overview, in which they may not notice some of the issues. After the first year, the auditor is likely to start digging far below the surface to see what the company is really doing, and that's where poor food safety culture can really come back to haunt (especially for those unannounced audits).
QAGB
Is it possible to pass a GFSI audit and have a poor food safety culture? Yes, just like it was possible to get a good AIB score but have problems such as the Peanut Corporation of America had.
Putting lipstick on the pig - waiting until the last minute to fill in all the gaps for your upcoming audit.
Perception trumps Reality - getting certified is more important than the actual food safety program.
Not My Job - employees, including management, who don't want to support or get involved in food safety activities.
Least Important - everything else is more important than food safety. Profit, People Safety, Production Numbers, etc.
Wastes Money - easy and quick to show the cost of implementing a food safety program but difficult or impossible to show how much money it will save, so resource allocation is determined by program cost and not by the requirements of the program.
Is it possible to pass a GFSI audit and have a poor food safety culture? Yes, just like it was possible to get a good AIB score but have problems such as the Peanut Corporation of America had.
Putting lipstick on the pig - waiting until the last minute to fill in all the gaps for your upcoming audit.
Perception trumps Reality - getting certified is more important than the actual food safety program.
Not My Job - employees, including management, who don't want to support or get involved in food safety activities.
Least Important - everything else is more important than food safety. Profit, People Safety, Production Numbers, etc.
Wastes Money - easy and quick to show the cost of implementing a food safety program but difficult or impossible to show how much money it will save, so resource allocation is determined by program cost and not by the requirements of the program.
This above. :clap:
I believe as unannounced audits become mandatory business will have to up it's game to be 2/7/365 ready...whilst at the same time schemes like BRC raise the bar by reducing the maximum number of minor NC's you can get to achieve an A grade. Not to mention new regulations such as FSMA. In addition GFSI have started a working group on food safety culture and no doubt in the future requirements related to food safety culture will start to be introduced into GFSI standards and become auditable. It's a slow process and everyone knows food safety certification is not perfect, but it is a baseline for continual improvement.
At the moment you can achieve GFSI Certification with a very poor food safety culture.
Thanks for all of the great comments.
Regards,
Simon
Is GFSI proving to not be the promised "Once Certified, Accepted Everywhere?" as is STILL on the GFSI site?
Oh hell no.
I can tell you how many people have called me and said "Gee! You've got a GFSI Certification! that means you have all your ducks in a row and I don't need to have you fill in a 35 page self-audit, send in hundreds of documents, and re-type your existing information every damn time you want to send us a new item!"
That has happened exactly zero times.
So, what's happening is NOT "You're certified? AWESOME! You've got must have a working program because you've demonstrated it by passing your audits!"
What is happening is "Oh, you've got a (insert GFSI cert here)?, GREAT! Send me the certification. And send me the audit. And send me the corrective action items along with root cause analysis! And show me some trend tracking to show that your root cause analysis actually mitigated the issue.
Now, how about you fill out this huge self audit, fill in my allergen form for me rather than sending your already vetted form, send me copies of (huge list) of policies, your HACCP plan, your flow diagrams, and about 90 other certificates and forms."
it's one more thing to have to keep track of and have on hand to be able to fire off to customers in an email at the expense of actually getting on the floor and seeing how things are running and working on improving the process.
...and is how it is actually happening; because you still have to ensure that the raw ingredients you receive are safe and you still have to prove that the process will ensure a safe finished product.
I cringe knowing that this happens every day. I have seen it in slaughter facilities, flour mills and packagin companies. Yes, it is possible. Is it right? Absolutly not. I dispise it when a company stops production for 2 days to "get audit ready" Run your facility right EVERY DAY and you are doing golden!
I cringe knowing that this happens every day. I have seen it in slaughter facilities, flour mills and packagin companies. Yes, it is possible. Is it right? Absolutly not. I dispise it when a company stops production for 2 days to "get audit ready" Run your facility right EVERY DAY and you are doing golden!
This kind of thing cheats their competitors who do it right.
I cringe knowing that this happens every day. I have seen it in slaughter facilities, flour mills and packagin companies. Yes, it is possible. Is it right? Absolutly not. I dispise it when a company stops production for 2 days to "get audit ready" Run your facility right EVERY DAY and you are doing golden!
+1
Everyone knows it happens and I do believe that there is a recognition of this from all parties including standards owners, GFSI etc. I believe the policies and procedures they have brought / will bring in, along with changes to their standards and the way audits are conducted will over time improve the situation.
Regards,
Simon
The unfortunate reality of culture in a large manufacturing environment with multiple languages, some in several dialects, is that there may be an appearance to upper management that the culture and expectations have been pushed down to the hundreds or thousands of team members, but that truly is not the case. Those employees who are performing the monitoring and creating the documents can give a very rosy pictures to anyone (including the management team) performing audits regarding food safety. By the same token, managers can absolutely have faulty ethics when it comes to production. I have, though, had more experience with managers who are afraid of being the next Peanut Corporate of America (since they have already been mentioned) and usually choose to "do the right thing". The biggest aspect of food safety culture missing in most production managers (from my experience) is being proactive, as opposed to reactive.
Additionally, when a manager realizes part of their food safety program is lacking during audit prep time (which, by its mere existence is another sad reality), creating patches through paperwork is all too easy in most systems. The ability to "fluff", as it's been called, is a highly regarded skill in some companies.
The simple answer is - yes. Companies can and will receive a passing grade, become certified, and even glide through gevernment food safety assessments with a poor safety culture,
the audits do not go deep enough into GMP's etc. For FSSC22000 the auditor does not climb ladders, have a flashlight etc. It is such a quick look unless there is an audit train. It is so paper based!!! It is also announced so you have time to clean everything up before the audit itself.
Sarah
the audits do not go deep enough into GMP's etc. For FSSC22000 the auditor does not climb ladders, have a flashlight etc. It is such a quick look unless there is an audit train. It is so paper based!!! It is also announced so you have time to clean everything up before the audit itself.
Sarah
I agree! Especially for announced audits. There have been times where I WANTED auditors to find NC's in certain areas so management would actually do something about it long term..!
Yes, it's possible in multiple places I've worked in, I've proven this. Easier as well in small sites where, to an extent you can "police" the culture and activities quite closely. It's bloody hard though and harder still if you're on the unannounced scheme. Life is so much easier with senior management commitment and a good quality culture but I'd say places which have a great culture are sadly few and far between at the moment.
I must say i agree with allthe answers.Yes is the main answer and its is right.
Its good to have the same auditor for 3 years in a row(BRC) and if you ewant to change you must say why.
A good auditor can come across a bad practice that was well hidden after the first audit.
A non announced is good because the practical part should always be in "shape" and the paper part is announced and that helps when you can miss the people that are responsible for it.
No
No
You are the first to leave a comment that it is not possible, and I am shocked there are at least 17 other people here who think they can not pass. I guess I would like to know why!? If a company has a lacking food safety culture, then they can and will put customers at risk, period. So therefore it doesn't really matter if the culture is only sort of bad or extremely bad, they are both dangerous, and right now they can both pass a GFSI audit quite easily.
You are the first to leave a comment that it is not possible, and I am shocked there are at least 17 other people here who think they can not pass. I guess I would like to know why!? If a company has a lacking food safety culture, then they can and will put customers at risk, period. So therefore it doesn't really matter if the culture is only sort of bad or extremely bad, they are both dangerous, and right now they can both pass a GFSI audit quite easily.
Yep. One company I helped them get an A with 4 minors (before the AA scheme) and a month later, I was asked to lie to a customer about a corrective action for a contamination issue and told we'd continue sending out contaminated product. I left. It's definitely possible to "stage manage" audits. The only place I've not seen it is where I now work because I refuse to accept that any more.
the audits do not go deep enough into GMP's etc. For FSSC22000 the auditor does not climb ladders, have a flashlight etc. It is such a quick look unless there is an audit train. It is so paper based!!! It is also announced so you have time to clean everything up before the audit itself.
Sarah
Agreed, I'm only into my second year of being audited and I was shocked at how quickly the auditors were ticking boxes going 'yep, yep, yep, yep' etc.. Basically as long as the previous week's paperwork is in place and correct that'll do. Sometimes I actually try and prompt the auditors to look a little further back but they aren't interested. Ticking boxes doesn't make food safe to eat but apparently that's all it takes to satisfy people that all is well
Agreed, I'm only into my second year of being audited and I was shocked at how quickly the auditors were ticking boxes going 'yep, yep, yep, yep' etc.. Basically as long as the previous week's paperwork is in place and correct that'll do. Sometimes I actually try and prompt the auditors to look a little further back but they aren't interested. Ticking boxes doesn't make food safe to eat but apparently that's all it takes to satisfy people that all is well
I think that is the reason why some customers not only need the company they buy product from to have a GFSI certification, but they also require themselves to do the audit also. The issue is that the compnay has too many expenses having certification(depending on the country you export to, you must have BRC AND IFS), you also need to have audits from customers and pay them as well.Its quite complicated...