15 replies to this topic

[Simon]

As part of our ongoing discussion on food safety and certification practices, we’d like to know your thoughts on the effectiveness of unannounced audits in upholding GFSI standards. Also would be interesting to know how you are involved with GFSI standards: auditee, auditor, consultant etc.

[Brothbro]

Always an interesting discussion. Can we also assume part of the deeper meaning here is to compare unannounced audits vs announced audits? As in, do unannounced audits result in a facility doing a better job in upholding GFSI standards when compared to facilities following an announced audit system?

 

I'm a QA Manager at a facility with mostly announced audits, our only unannounced visits are FDA inspections. My experience with unannounced audit schemes comes from working in facilities where "unannounced" means you have an audit window period of a few months where inspectors can arrive during that time. Personally I don't feel there is a significant improvement in compliance between unannounced vs announced. My view is that the best audit system is one that takes the long-term approach and reviews the facility on a year-to-year basis with a focus on ensuring improvements stick. I've noticed that with some audit systems I interact with, auditors don't even mention our previous year's NCs to check up on how we've improved. This mindset can encourage those band-aid fixes, because you may think to just do a quick fix to satisfy response requirements and then forget about it. Focusing on year-to-year improvements means you don't really need to worry about catching a facility with it's pants down (ie unannounced audits). From this perspective, unannounced audits don't provide much a benefit over announced ones. It just becomes an inconvenience for the staff.

Edited by Brothbro, 06 August 2024 - 05:41 PM.

[SQFconsultant]

Former SQF Auditor, Present SQF Consultant, soon to be an owner of a food company...

 

I do not see any value in doing no notice inspections.

 

I did these when I worked as a hotel inspector for Ramada and Howard Johnson - I find them to be very confrontational regardless of whether they were a good operator or a bad operator - the only good purpose was if they were a borderline operation the no notice inspects would normally result in failures and getting these hotels booted out of the system.

 

I find many parallel's between the hotel/restaurant and food industry - while the food sectors have to adhere to GFSI scheme codes the hotels/restaurants that I inspected had to adhere to franchise codes -  the major difference is the hotels were compliance audits, where there are many grey areas with SQF, BRC, FSSC, etc - and are in effect compliance, but not like the hotel chains.

 

No matter how you look at it, an operator knows when the inspection is coming and with a no notice they still know there anniversary is coming up and it might be 30 days this way or 30 days that way - so the borderline operations are kept on their toes only when they get into the window, while the good operations are humming along all year long and see a no notice inspection as another set of eyes and actually enjoy the process.

 

Lately however as a consultant we are getting lots an lots of feedback from our clients of extremely confrontational episodes and its not coming from the company side employees but from the Auditors.

 

Mostly an inspection is not exactly an enjoyable time and having spoken with a number of Auditors they hate doing unannounced inspections as well - I remember doing inspections in hotels on no notice and had to sit in my room (we would stay on property the night before - we'd do the guest impact part first before announcing ourselves at the front desk in the morning) and build up strength to get thru the audit.

 

Seriously, low courage Auditors, or Auditors that get intimidated easily crumble with many an unannounced audit.

 

Here's an interesting story, my boss in the hotel franchise company had been a Manager at a Holiday Inn. At the time Holiday Inn had a fleet of cars for the QA inspectors with their logo's all over the cars - there was a toll plaza about 5 miles from his hotel, he had talked to all the toll takers and would give them 2 nights with all meals, etc at his resort property if they would call him as soon as they saw a Holiday Inn corporate car come thru - he was a good operator but it gave him about 15 minutes for all department heads and exterior grounds personnel to touch things up quickly, or excuse certain employees to go home that could cause issues.

 

With the quality of the auditors out there today, I find the opportunities for problematic confrontations has gone up greatly because of these unannounced audits.

 

Rambling done, back to reviewing 3 unannounced audits!

[kconf]

That is a funny story, Glenn! 

Just curious - when you were inspecting hotels, was it mainly building fabrication, franchise regulations, etc? 

[SQFconsultant]

That is a funny story, Glenn! 

Just curious - when you were inspecting hotels, was it mainly building fabrication, franchise regulations, etc? 

 

No, it was everything, it was extremely comprehensive and actually started on the plane as we flipped thru the inflight magazines looking for advertisements for the hotels were going to inspect to check for logo violations, text, correct colors, trademarks, then quick inspection on the car rental (if associated with a promotion for the hotel), then before checking in an entire exterior night time security audit, grounds checks, signage and billboards on way in to the property, exit signs, lighting, everything, then sitting in the lobby watching people get checked - professionalism of front desk, security measures, etc. We'd have dinner or breakfast in the restaurant, have a ginger ale sitting at the bar - it was one very big inspection and that was all on top of the 350 documented franchise regulations that we looked it - total 1,250 for Howard Johnson and 1,200 for Ramada. Those were the days!!!

[kconf]

wow! It sounds intense yet fun! Must have been 20+ years ago, as now they have all gone downhill....

[TimG]

I will circle back and vote on this one later this year, after my unannounced audit. Interested to see what others think, though.

[G M]

The presumption of the unannounced audit is that sites are gaming the system and only up to standard when they know the audit is coming, and the auditor is potentially going to catch them with their hand in the cookie jar.  It seems inherently antagonistic.

 

Do I think there are sites engaging in this behavior?  Yes.

 

Do I think the unannounced audit with a known audit window is an effective method of "catching" them? No.

[Tflex]

The presumption of the unannounced audit is that sites are gaming the system and only up to standard when they know the audit is coming, and the auditor is potentially going to catch them with their hand in the cookie jar.  It seems inherently antagonistic.

 

Do I think there are sites engaging in this behavior?  Yes.

 

Do I think the unannounced audit with a known audit window is an effective method of "catching" them? No.

What would be an effective method to stop companies from engaging in this behaviour?

[MDaleDDF]

I don't think they're more or less effective.   I honestly don't care if they're unannounced or not, but the bigger thing to me is this:   is the scheme really improving food safety?   These folks come in once a year and spend 90% of their time looking at paperwork and signoff bs.   Then their new version updates are things like a risk analysis for my path plan that's been in place for 20 years.   (Nothing like needing to justify something you've been doing for 20 years successfullly, lol.)   Heap on top of that climate change, and the other idiotic additions, and the whole thing smaks of a money grab and an attempt to make themselves relevant in the business.

 

So you want to come in unannounced?   Meh, whatevs....

[Brothbro]

What would be an effective method to stop companies from engaging in this behaviour?

 

Truly unannounced audits would be the only way, where auditors can show up without any prior notice at all. Auditing schemes as a business are caught in the middle of the desires of suppliers and vendors though. The vendors would probably be on board with suppliers being audited with no notice, but of course suppliers would not be. For an auditing system to see widespread adoption, it needs to be reasonable for both sides of the equation. The compromise has become "unannounced" audits where you're told a window where a visit is possible.

 

For the record, I don't see benefit in a "no-notice" audit system either. Instead, auditing systems should review facilities in a way that looks past what is immediately visible on the date of inspection. When you watch a team clean a piece of equipment or an area of the facility, an auditor should be experienced enough to see if any parts of it would be especially difficult to clean. They should ask questions like "how do you make sure this area is cleaned every time?" or "How often does this difficult area of the facility get cleaned?" Just because that section looks great on the day of the audit, you can still ask the question and get an answer that may tell you if it was simply spot cleaned for the day of inspection.

[G M]

What would be an effective method to stop companies from engaging in this behaviour?

 

A truly blind and unannounced audit where the auditee had no idea when it would happen, and might have it happen more than once in a cycle. 

 

A lot of sites would consider that a terrible solution though, especially with the ridiculous multi day long slog through paperwork.  If it was a one day event with a focus on operational inspection that would certainly make it more tolerable.

[Ryan H.]

If you really want to make an impact, make every audit unannounced with a larger audit window. This approach punishes the food plants that perform well all the time but would likely have a different impact on those plants that have poor practices. They may see lower scores. I think the bigger question is the consistency/ knowledge levels of auditors themselves. Overall, no, I do not think the unannounced audits have a big impact. - Auditee 

[wbourg]

I don't think they're more or less effective.   I honestly don't care if they're unannounced or not, but the bigger thing to me is this:   is the scheme really improving food safety?   These folks come in once a year and spend 90% of their time looking at paperwork and signoff bs.   Then their new version updates are things like a risk analysis for my path plan that's been in place for 20 years.   (Nothing like needing to justify something you've been doing for 20 years successfullly, lol.)   Heap on top of that climate change, and the other idiotic additions, and the whole thing smaks of a money grab and an attempt to make themselves relevant in the business.

 

So you want to come in unannounced?   Meh, whatevs...

The last company I worked for I did a tour with the COO before being offered a letter. I walked into their "cooler" which was a picnic area concrete pad with a wooden awning structure and refrigerated shipping containers. There was mold all over the wood and light coming in every which way. They received a 98 the last month from a GFSI scheme. I think GFSI had good intentions when initially incorporated, but now is a pay to play for industry to slap a sticker on their building to look better than the others. Anyways, I think they all should be unannounced similar to FDA audits. The window really just says. "I need everything to be perfect by this date.", like a high school project. 

[Bo16]

Window for unannounced audits is really difficult for small business. I know we have backups for our managers and supervisors, but backups take a lot longer to get/find all the information for the auditor.  Yes they are trained, but if you are apart of GFSI you know how much documentation is required and if you do not work with those files all the time, it just takes a lot longer.  It is unreasonable to expect QA Manager to be at the plant everyday during the "window" (BRC 4 months and the showed up the very last 2 days! So how was that unannounced?).  

Even the FDA will come back if the QA Manager is out of the office if they are just doing an audit without cause.  Our QA Manager before me did exactly that.  I was on vacation and the auditor was happy to come back the following week.  We had all programs in place and showed them our Food safety plan/FSVP... but for individual documents they realized how long it would take and came back the next week.

[ChristinaK]

I think that UA audits can be conducted in a much more effective manner.

 

I also agree that unannounced audits can be a burden on small businesses that may not have a lot of trained staff; I know from experience that QA will get locked out of vacation/sick time during those unannounced windows. Not saying it's a correct practice, as sites are required to have a backup in place for that reason, but it is in practice (just maybe not a stated policy). Because of that, I think auditors should be more critical of sites where it seems they are talking to one person or department the entirety of the desktop portion of the audit and really push site senior management.

 

Personally, I would put more effort into inspecting the practices and condition of the site during an UA audit rather than focus on documentation, especially if I'd been to the site in the previous year or two of the audit cycle. Unless there was a change to the code or a major event, policy is unlikely to change. What does change is how well they are implemented and adhered to across the site from senior management to production workers. Was there a real improvement on a NC from the previous year? Those are the sorts of things I'd be more concerned about. However, I'm unsure if that approach is taught to auditors.

 

It may also be worth looking into the possibility that UA schemes are put in place for high-risk operations and/or operations that have large distribution chains, as those are likely to cause the most havoc in the event of a class 1-3 recall. Just because the site is owned by a large company doesn't mean that time is given to properly maintain sanitary conditions and operations. I'd be even more harsh on companies that report to investors, as they care more about profit than anything. Look at PepsiCo: They failed to invest in infrastructure updates for their Danville IL Quaker Oats facility and then had a huge recall related to a years-long resident salmonella strain. Then they just decide to shut the building down. Even the FDA warning letter said that they still need to evaluate their other facilities because they doubt those are in sanitary condition...