Does the GFSI System Allow for a Thorough Audit?

By Cameron Prince and Rich Simmons

There is distinct value to having global standards, such as the certification programs benchmarked to the Consumer Goods Forum (CGF) with Global Food Safety Initiative (GFSI), for which the bar has been set quite high. While all certification programs can be of some benefit, those that have more detailed requirements are easier to develop and implement and they lend themselves to greater audit consistency. With one of the greatest challenges being that of consistency between auditors, the more prescriptive the standard, the more consistent the audits will be.

However, it is a significant challenge for any one auditor to get through all the clauses and subclauses of a standard in the typical two days that GFSI has allocated for a facility. The two-day application was derived at the beginning, when cost to industry was a big concern. Not only would multi-day audits cost more, they would disrupt production for a longer period of time, adding further to the cost. Therefore the duration was set at two days, but the standards to be reviewed have grown significantly since then.

For example, a typical GFSI audit includes more than 350 subclause requirements to be investigated and 50% of the auditor’s time is required to be on the plant floor. Of the 350, about 150 can be done on the plant floor, which leaves 200 to be done in one day. Assuming an eight-hour day, that provides only about two minutes per subclause. While a cursory review can be done in that time, it would be difficult to really get into the details of any particular clause – unless time were sacrificed elsewhere. This means that if an auditor sees general compliance in an area, they will move on to the next one, without drilling down. This can provide an acceptable audit, but not as thorough as possible. That said, auditors have adapted, with training including audit time management and new auditors being coached through their first audits.

Assuming an eight-hour day, that provides only about two minutes per subclause.

As a whole, the auditors do an excellent job inspecting and auditing for the core issues and critical aspects needed for food safety. But just as some individuals are naturally good at digging into the details, others are more big-picture oriented; and the same is true of auditors, which can cause variation between audits. To help alleviate this, there has been a drive to bring together auditors to discuss the interpretation of various clauses and “calibrate” the audits – and auditors themselves. It also is for this reason that GFSI specifies that an auditor can audit a specific facility only three times in a row, after which a change must be made. In this way, the individuals’ differences can actually become strengths as different sets of eyes can notice different things.

Additionally, over the last two years, GFSI has addressed auditor competency to ensure each has a thorough understanding of the industry segment (e.g., dairy) of the facilities they will be inspecting. BRC requires exams; SQF requires a mandatory 15 hours of technical training and required attendance on SQF updated webinars; FSSC provides technical training. Therefore, competence is now being addressed fairly well, but there will always be those who are better than others, as well as those who could use improvement.

Currently, the demand for auditors exceeds the supply – and 2020’s COVID-19 pandemic has increased this demand. The industry is seeing both positive and negatives impacts on auditing during Covid, one area that has changed is the restriction of auditors to travel. Now that auditors are not expected (or sometimes even able) to fly coast to coast, many are seeing increased opportunity in their local areas, as there is less “competition” with others coming in from afar. Less travel means less time on the road, less stress, and more time for overall GFSI standards activity.

Although the GFSI standards are inherently global in nature, they also strive to consider and integrate with national regulations, such as FSMA. While adherence to a GFSI standard does not mean a business is in complete compliance with FSMA, as some of the requirements do vary, it can help a company be well on its way toward that compliance. Additionally, while some may see GFSI as “the only game in town,” i.e., the only choice as far as global standards are concerned, this is not accurate, as GFSI is not, itself, a standard. Rather there are distinct differences between the various standards benchmarked to GFSI, giving food facilities a choice as to that which best fits their business.

About the Author:

Cameron Prince is Vice President of Regulatory Affairs for The Acheson Group (TAG).  Cameron is a highly experienced food safety and management consultant with over 35 years of experience in food regulatory programs and the food industry in both the US and Canada. He also has extensive international experience having been active in Codex Alimentarius, WTO and SPS committees