The difference between audits and inspections
As fresh produce growers learn about the Food Safety Modernization Act, many are confused by the difference between a food safety audit and an on-farm produce safety inspection.
Many fresh produce growers are just now beginning to get to know the details of the Food Safety Modernization Act. Passed in 2011, the rules have evolved with public and industry input while in draft form. With the publication of the final rule at the end of 2015, the areas the Food Safety Modernization Act is concerned about are clear.
One of the issues that caused a lot of confusion is the difference between a food safety audit and our current understanding of an on-farm produce safety inspection. To be clear, the nature of an on-farm produce safety inspection is still unknown. The differences between an inspection and an audit can still be understood by looking at how a compliance inspection in other food industry sectors is carried out. Given what we know about compliance inspections in food processing plants, it will likely take a similar form.
Many produce growers are familiar with food safety audits. They usually follow a checklist with the relative risks of different food safety hazards weighted by a number of points. In some cases, growers only need to achieve a percentage of the total score to pass an audit. This allows growers to choose certain low risk practices to ignore or not implement and just “take the hit” on the audit. These audits are annual, and sometimes several may be conducted in the same year. In the case of several brands of audits, they only cover one crop per audit.
Inspections are not based on points. All key components to a law where an inspection is required need to be considered. Inspections are usually not annual, allowing for a facility to adopt changes gradually. An inspection also would cover the entire farming operation, looking at how the whole farm handles the whole range of growing and harvest activities across different crops.
The most important difference with an inspection is in the area of noncompliance. With current food industry compliance inspections, a business is issued a list of corrective actions, or things that need to be fixed, after an inspection. A follow-up inspection sometime in the future is scheduled, and the business is allowed to address the things that need to be fixed. The expectation is that all things on the list will be addressed. If they are not addressed in the follow-up inspection, usually some citation is given to the business. Depending on how severe the issues are that were not addressed, it can range from a verbal warning to fines.
If an imminent food safety risk, or what regulators call an egregious condition, is present at any point in the inspection process, the product can be seized. An example of an egregious condition would be if dead animals were found to be floating in dump tank water.