Is the increasing usage of unannounced audits driving food safety teams to a position where they have to focus limited resources on the minimisation of audit non-conformances? With growing skills shortages technical teams are no longer able to focus on their primary objectives and are instead evolving into compliance teams. Getting out of this trap and driving step change improvement in food safety and brand protection is deemed to be too high risk. This article aims to explore these themes in more detail and asks if the industry can afford this trend to continue.
Non-Conformance Minimisation Is Increasing In Significance
As I visit food businesses and speak with experienced Technical Directors & Technical Managers a common theme of discussion is audit non-conformances and pride at sites reducing non-conformances and receiving good audit grades. Good audits and low levels of non-conformances are definitely are preferred to the alternative of failed audits and substantial non-conformances.
Has it always been like this?
In my opinion the focus on non-conformance minimisation is higher now than it has ever been.
Are Increasing Numbers Of Unannounced Audits To Blame
There was a time not so long ago when most manufacturing sites had a scheduled GFSI audit which they could plan their year around. The typical cycle started with the audit and then the month after the audit focussed on clearing up non-conformances. Once the audit non-conformances were closed the technical team could look 11 months ahead knowing when the next audit was due. This cycle provided a very useful window to proceed with getting important stuff done, such as:
- Reviewing and updating parts of the quality management system which were no longer fit for purpose.
- Getting into detailed root cause analysis behind quality problems and customer complaint levels and initiating actions that delivered step change improvements.
- Spending time with teams working on personal development and coaching.
- Getting into detailed review of micro testing programs to identify improvements.
- Getting out and about to the infrequently visited parts of the plant to identify emerging risks before they blew up in your face.
- Auditing suppliers.
I could go on and on, and I am sure that experienced readers could continue to add things that they used to do but no longer have time to do. The point being that the defined window between audits enabled proactive technical teams to get out and make a difference, to drive improvements in food safety and brand protection.
My theory, for what it’s worth, attributes much responsibility for the changes to the rapid increase in unannounced audits which are perceived to increase brand protection for retailers and brand owners. There are many explanations for the increase in unannounced audits which it is outside the scope of this article to discuss.
What Is The Primary Objective Of Food Safety Teams
This question is a potential banana skin for me as a non technical person, so to avoid stepping on it I have used the job adverts from a recent Food Manufacture Magazine to clarify the job descriptions for vacant Technical Manager roles:
- Bringing safe and consistently high quality products to markets
- Managing food safety, quality and legality
- Ensure internal and customer standards are adhered to
- Championing TQM, GHP, GMP, HACCP, traceability, allergens risk management & food safety risk reduction programs
- Customer communication
- Involvement with BRC management
- Maintaining the QMS
- Conducting supplier reviews
- Managing Technical & QA Teams
Nowhere in any of the job descriptions I reviewed was the minimisation of audit non-conformances mentioned. Are these job descriptions all incorrect or is the requirement to ensure internal and customer standards are adhered to of much higher importance than the other role requirements?
Risk That Food Safety Teams are Evolving Into Compliance Teams
Through a combination of factors I worry that food safety teams are evolving into compliance teams. In this scenario there is a quality management system in place and the teams are so stretched that they are constantly juggling multiple priorities such as:
- Clearing non-conformances from the most recent audit.
- Juggling conflicts between different retailer requirements.
- Fighting with production to get commitment to adhering with the quality management system.
- Creating KPI reports in different formats for different customers.
- Battling with suppliers to get all supplier approval management and product specification information up to date.
- Coming to terms with the latest new requirements such as vulnerability assessments.
- Putting out frequent fires when things go wrong.
- Finding cost savings for the accountants.
- Defending the undefendable issues picked up by auditors when someone in the factory has done something stupid.
Yet again I could go on and on, and no doubt readers of this piece can think of many more activities that are filling their days which they never signed up to and definitely do nothing to improve food safety and brand protection.
In this situation it is not surprising when teams are relieved to get a good audit and few non-conformances, it is the best that they can hope for.
It feels like a survival……until the next audit!
Is It Now Too High Risk to Aim To Drive Step Change Improvement In Food Safety & Brand Protection
This is more than a rhetorical question for us here at QADEX, our mission statement is:
“Enabling Step Change Improvement In Food Safety And Brand Protection”
Taking account of the environment facing food safety teams which is characterised by:
- Increasing prevalence of unannounced audits
- Skills shortages
- Budgets being cut
- Conflicting retailer requirements
- Uncooperative supply chains
- Demanding Customers and increase in Customer Complaints
Is it now too high risk for technical teams to drive step change improvement in food safety and brand protection? The answer is a possible Yes, as change brings risk. Changing systems and processes to enable improvements leaves the business exposed to an increase in non-conformances during the changeover process. The consequences of a poor audit or high number of non-conformances can now include commercial implications for the food business.
The result is a state of paralysis. Those who want to change lack the resources and are taking a large risk, resulting in status quo prevailing.
How long is this status quo sustainable for?
The circumstances that food safety teams find themselves operating under today are driving them towards becoming compliance teams. This leaves little space for driving step change improvements in food safety and brand protection, in fact the risks for the team and the food business may now be too high due to the significance placed on audit results.
If this trend continues to its logical conclusion we could reach a state of high compliance across the industry against various standards, but still experience major food safety incidents which cause significant brand damage to the food business or retailer implicated.