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Pundit’s Mailbag — Prevention Should Be Higher Priority Than Testing/Auditing

Our piece, No Quick Fix With 12-Hour Test, which followed Hold The Train… 12-Hour Test May Not Be Best Answer, is continuing to bring in feedback regarding both specific concerns with this test and broader concerns over the way the industry may be over-relying on testing and auditing in its effort to obtain food safety.

This letter from a recognized food safety expert makes the point:

The current issue with ginger is a classic example of the limits of any testing program. After spending literally millions of dollars testing for microbes, which is what is being spent by one firm, the industry is once again blind-sided by a pesticide issue. And all of the microbial testing in the world wouldn’t have addressed the ginger issue.

The industry, including the buyers, needs to stay true to the basic concepts of hazard analysis and make prevention from physical, chemical and microbial contamination their highest priority.

Neglecting or ignoring any of these points in order to deal with the crisis of the day is short-sighted.

A few comments regarding the “12-hour test”:

  1. Virtually everything you wrote regarding testing applies to auditing as well. Testing and auditing are verification tools for confirming practices or the effectiveness of practices. We believe that the lion’s share of money should be spent on prevention. The food safety principle that has often been mentioned is that “you cannot test your way out of a problem.” We need to amend that by adding… “and by the same token you cannot audit your way out of a problem”.

  2. At this time last year, and for years prior to that, a number of individuals who controlled considerable resources within major fresh produce processors believed that field-level contamination was insignificant or that their plants would correct problems originating in the fields. Most of those folks are no longer working in the fresh produce industry. Major processors who prior to Fall of 2006 had field programs that were “paper tigers” are now taking field sanitation and hygiene seriously. Not enough time has passed to know if those efforts are paying off.

  3. Some of this push for testing is a buyer response in atonement for past sins of omission. In the first half of 2006, certain buyers were pushing auditing for sustainability and social responsibility. The two buyers that today have become nouveau advocates for finished product testing were the two most vocal pushing for sustainability and social responsibility auditing. We’ve been around a long time, and attempting to address the safety issue for most of that time, yet neither of these buyers has been an aggressive advocate for food safety. Each has historically taken the position that it was their suppliers’ responsibility.

Last year’s crisis, while perhaps leading to a commendable refocusing, did nothing to permanently focus the suppliers’ attention on the important principles of hazard analysis. It certainly ought to give suppliers pause when attempting to allocate resources to address which issue(s) they are serious about. However, the suppliers often respond to buyer incentives. This lack of focus, etc., certainly has not helped over the years.

While my note here is focused on the negative, I should add that last year, long prior to the spinach outbreak, a number of buyers who have long been supportive of efforts to enhance food safety were urging the trade to keep our focus on safety. There are responsible buyers out there.

The search for a “fix” is so palpable that it leads to over-reliance on testing and auditing. The danger here is two-fold: first, in a world of limited resources, millions upon millions are now being spent on audits and tests — money that is not available to be spent on actually improving food safety.

The second danger is that the temptation is strong to promote the test or the audit as “proof’ of safety. The problem, of course, is that the very first time there is an outbreak and the public learns that the test or the audit is not, in fact, proof of anything, the industry credibility is lost and it will be very difficult to get it back.

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