Scope of food safety auditing
An audit is a planned and documented activity performed in accordance with written procedures to verify, by investigation of objective evidence, that a food safety management system has been developed, documented and effectively implemented. There are three main types of audits for food safety managements systems:
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first party, where an internal audit which involves the food business relying on its own staff to verify its own system;
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second party, where food safety auditing required by a government agency is undertaken by employees of the agency; and
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third party, where an audit is carried out by an independent, external individual or organisation.
The compliance audit can be a second or third party and is a focussed, in-depth inspection of the food business against the requirements of the food hygiene regulations. The compliance audit would either determine the effectiveness of the implemented food safety system or verify that non-conformities identified in a previous audit have been rectified as agreed.
An important consideration for food safety auditors relates to the issue of conflict of interest in relation to audit activities. To avoid the possibility of conflict of interest, auditors, where possible, should not be involved in the design or implementation of food safety programs they audit. In general, auditors must avoid any activities that conflict with their independence of judgement and integrity in relation to their audit activities.
To achieve cost efficiency governments may choose to provide a choice for food businesses between second and third party compliance auditors. It will be necessary for regulatory agencies to ensure that there are appropriate management systems in place to support both second and third party auditors. Auditors must be certified and possess the key competencies relevant to the food operations they audit.
Both EHOs and third party compliance auditors will have to meet nationally agreed competencies for particular types of food businesses to audit those types of businesses. Health departments may seek to be accredited by a recognised accreditation body as a certification body in their own right for third party food safety compliance auditors or seek to rely on other accredited certification bodies for certification of auditors (relying on nationally agreed auditor competencies for particular types of food businesses to audit those types of businesses).
As the HACCP system is increasingly accepted as the preferred food safety management system individual food businesses are experiencing costly multiple audits both by a range of government agencies and food industry customers. There is a need for reciprocal recognition of food safety audits performed by second and third party auditors where these audits meet the requirements of the regulations.