S. Dix, Tesco Stores plc, Welwyn Garden City
3.4 Non-routine auditing
quality auditing systems such as customer complaints records or random quality control tastings. The results of tests by outside sources such as the Department of Health or the Consumers Association, anonymous tip-offs or adverse media reports might also lead to an audit. These audits may be carried out unannounced, particularly if there are grounds for suspicion or a whole industry review is under way.
3.4.1 Quality audits
Retailers must have systems for checking the quality of the products sold as their own brand if they are to comply with food safety legislation. A useful first line check is often made at central distribution depots. Random opening of cases and packs by trained auditors with checks against key quality parameters might indicate that products were being delivered out of specification, e.g. tomatoes of the wrong size or degree of ripeness. Store staff occasionally report to head office that quality has deteriorated. An example of this could be poor evisceration or excessive feathers on chickens supplied for rotisseries in store.
Regular head office tastings on a rota basis might detect varying viscosity of cream, sauces or other liquid products.
These variances may be dealt with initially by a telephone call to the supplier followed by more retailer checks. However, if quality fails to return to the tolerances agreed within the specification then it may be necessary to carry out a quality audit. This will usually follow a different format from the routine variety. If the product has a long shelf-life then the auditor should ask for samples from each production still in stock to be brought out for the audit. There may also be retained shelf-life samples from each production. The records for the last ten productions should be obtained and may need to be asked for in advance of the visit as they may be stored off-site. Finally, a store visit before the audit to collect samples currently on sale will allow the retailer and supplier to assess products together and identify where and why deviations have taken place.
Audits in these circumstances might concentrate on incoming raw material checks if poor quality ingredients are evident, e.g. gristle in meat pies would lead to checks on incoming meat inspection records whereas variations in the gravy viscosity would require checks on yield, cooking time and the weight of the thickener. If the product was not holding up for its full shelf-life, then the check would concentrate on looking for unacceptable delays in processing and might require a detailed traceability exercise to identify the cause. In all of these circumstances auditors should ensure that they are fully familiar with the process specification and finished product quality checks before they visit so that they can concentrate on the areas most likely to have caused the problems. Finally, it is essential that during this audit the monitoring frequencies are reviewed to ensure that potential problems are spotted and dealt with in the future and that staff are retrained where necessary on the standards that are required for the product.
3.4.2 Customer complaints
As part of their own due diligence systems retailers are obliged to analyse complaints data and act as soon as a problem is perceived. Stores will record details of the type of complaint and the codings on packs brought to the customer service desk. They will report either to a customer service centre or to the buyer or technical manager at head office. If there is a sudden spate of glass, metal or other foreign body contaminants or sickness reports from one batch of the product then these will be followed up immediately by telephone calls to inform the supplier, a decision to withdraw a batch from sale and a visit to the supplier to check procedures and records. Visits might also be carried out if complaints data collected over a period of weeks indicated that the level of complaints had increased. This trend analysis uses sales data collected from check-out scanning of long-life products or production figures from short-life products to calculate the number of complaints per million products sold. A level of ten complaints per million sold is often the target. It is essential to check the sales figures, as very successful promotions might lead to an increase in actual numbers of complaints, although when viewed against sales data the rate of complaint may be downwards.
Complaints are grouped into type, e.g. glass, metal, extraneous vegetable matter, bone, gristle, low meat content; then, if there is cause for concern because a specific type of complaint has increased, an audit will be necessary.
When complaints are caused specifically by poor raw material quality, poor process control, unacceptable foreign bodies or poor hygiene, then the audit should be specifically targeted. An increase in a variety of foreign body complaints might suggest an untidy factory allowing extraneous matter to enter production areas. In this case a walk around the site collecting any small unnecessary items into a plastic bag might have the desired impact on line management. If there is an increase in extraneous vegetable matter in vegetarian products or bone complaints in meat, fish or poultry products, then extensive sampling of any bought raw materials or examination of butchering and filleting standards in-house should be carried out to identify the source of complaint. If traceability records indicate that one raw material supplier is implicated, then specific action must be agreed to reduce the level of complaint. In all cases the visit, checks carried out, and action taken must be carefully documented and records retained in the retailer’s files as evidence that the auditor has carried out all reasonable checks as part of the retailer’s duty to preserve product integrity.
3.4.3 Adverse microbiological trends
For many types of products there will be a microbiological specification. The retailer and supplier will have agreed the number of samples of each product to be analysed on the day of or day following production and throughout the shelf-life. The standards applied are usually based on legislation or good manufacturing practice (GMP). The organisms tested for will vary depending upon the nature of the product but will usually include a total viable count of
organisms per gram. This will give a measure of the effectiveness of any heat treatment or processing procedures, an indication of expected shelf-life and possibly a measure of the quality of ingredients used. There will be a check for pathogenic micro-organisms of the type or types most likely to be found in that product group depending upon the raw materials used and the degree of handling by staff. The specification usually has three levels – a target based on GMP, a higher level at which the retailer should be informed on the day the result is obtained, and a withdrawal level at which the product will be deemed to be unsafe, unacceptable on the day of production or unlikely to be sound at the agreed end of shelf-life. If any product figures in this last category the supplier must immediately telephone the retailer and arrangements will proceed to withdraw stocks from sale. However, if results of microbiological checks fall within the first two categories they will be reported to the retailer using some form of graphical trend analysis. If these results show rising total viable colony counts on the first day after manufacture, then it is possible that eventually some would not be acceptable at the end of life giving rise to customer complaint. The retailer and supplier therefore have a duty to monitor these trends and take action if deterioration in quality is predicted. An audit in these circumstances should concentrate on the microbiological quality of incoming raw materials to ensure that they are sound, and should check on any variation in processing or storage times to ensure that micro-organism levels are being reduced to a minimum and that there is effective control of the chill chain if this is relevant.
Again, action must always be agreed and documented at the end of the audit and immediate re-checks agreed. In addition the frequency of checks should be reviewed to ensure that the problem can be prevented from recurring.
If cleaning procedures within a factory have been inadequate, then this can usually be detected by monitoring coliform or Enterobacteriaceae counts in products on the first day of life and a level at which the retailer is informed will often be agreed within the specification. When trend analysis shows levels are rising, or several results above the reportable specification limits are received in one month, then a hygiene audit should be carried out. This should concentrate on the cleaning methods, frequencies and materials in use. A check on the dosage level and residence time is essential as new or inadequately trained staff could occasionally be the cause of the problem. These audits should therefore be carried out during the cleaning shift and the supplier’s hygiene manager should be present. Swabs or ATP kits can be used to measure residual contamination and dead spots must be identified so that cleaning methods can be improved to achieve the desired results.
3.4.4 Adverse media reports
In the past ten years there have been several reports in the Consumers Association magazine, Which, and surveys carried out by local authority trading standards officers on behalf of the Ministry of Agriculture, Fisheries and Food, the Food Standards Agency and the Department of Health on all types of
products. The results of these studies are frequently reported in the mainstream press. The studies usually select specific groups of products which are then analysed and the results compared to current legislation or specific quality standards. Examples of this type have been meat content of sausages and water content of hams. When retailers are identified as selling products below acceptable quality standards then of course they will wish to protect their reputation by carrying out a thorough investigation. The analytical results may be affected by many factors, so in addition to checking processing methods and records the auditor should if necessary be accompanied by a company analyst or consultant with specific expertise in this area. There have also been reports on pesticide residues in fruit juices where the input from a horticulturalist during the audit would be invaluable. The report on Listeria sps in cooked chicken and paˆte´s caused a flurry of activity and many retail technical managers and suppliers were ill-informed. This was therefore an occasion when an audit by a food technologist accompanied by a microbiologist would have been most helpful. On these types of occasions a delayed audit would enable the best informed people to be assembled by both the retailer and supplier so that the audit can examine all contributory factors thoroughly and ensure that more complex control methods are put in place for the future if this is found necessary. However, unannounced visits should also be considered if spot checks on current activities are deemed necessary.
Most retailers occasionally receive anonymous telephone calls from people who describe totally unacceptable conditions or practices within premises producing own brand products. The calls are usually related to poor quality ingredients, dirty equipment, abuse of agreed quality parameters or even the use of child labour. An auditor who knows the supply base well will have spotted indications of this during their routine work monitoring quality, shelf-life and customer complaints. However, in these cases an unannounced visit may be the only way to elicit the truth. Before carrying out a visit in these circumstances the auditor should carefully consider where and how they are most likely to find the evidence to substantiate the allegations and prepare a check sheet so that they are thorough in their investigation and cannot be diverted from their task by a determined supplier. If the auditor does not know the supplier, premises or processes well, then this pre-preparation is essential and, if deemed necessary, two people should carry out the visit. The audit must be carried out at the most appropriate time of day, night or weekend, i.e. when non-conformances to agreed procedure are most likely to occur. However, the auditor should bear in mind that occasionally complaints are made by disgruntled employees and could be malicious; therefore it is important to keep an open mind.
3.4.5 After product withdrawals
Rarely, mistakes occur and products must be withdrawn from sale for either safety reasons or because of unacceptable quality defects. There is then a need to audit suppliers to ensure that control systems are in place to prevent that type of incident
from recurring. The timing of this audit will depend upon the seriousness of the incident, the past history of the supplier and the auditor’s knowledge of and confidence in the management. If there is a serious safety or quality issue then all further production will be halted until an audit is carried out. In this case an immediate audit is necessary unless an alternative source of supply is available. If the retailer has another supplier who can pick up the required volume immediately, then the audit can be delayed for 48 hours or up to a week.
Rejection of a product from a small factory with limited resources would require a rapid visit to ensure that the retailer has confidence that corrective action has been taken. Indeed, if the problem has been caused by an ingredient, then the retailer might have more knowledge of alternative sources of supply than a small manufacturer and their intervention would be appreciated.
However, if the same type of incident occurred in a product from a large company with extensive technical resources, they might be able to solve the problem themselves and the audit could be delayed until alternative ingredients have been sourced. The audit would focus upon why the defect was not spotted before withdrawal became necessary and discussion would centre on raw material inspection, handling policy and records.
When incidents have serious safety implications such as the undercooking of a meat product, then an immediate audit is called for as there must have been failure to control a critical point in the process. The retailer will need to be reassured that this cannot happen again before production can resume.
Overcooking of meat, however, could be discussed on the telephone and the visit planned for a later date. The retailer would then require process control records for several production cycles and retained samples to be made available and the audit would focus on the effect of varying cooking times on eating quality. Finally, if the auditor has confidence in the management and the problem is complex, then a delay in carrying out an audit would allow the supplier to spend several days investigating the incident and the audit would then concentrate on reviewing systems and frequency of checks. Agreement would then be reached and documented showing a course of action to be followed in future.