How do we build an adequate cadre of qualified auditors with the wide diversity of operations that comprise the global food system?
We also must address and be constantly vigilant regarding the independence and objectivity of private certification bodies and auditors. A credible audit asks the hard questions and analyzes the data from a neutral perspective, with one purpose: to objectively assess compliance.
What incentives and controls are needed to achieve this goal?
How do we avoid the perception or reality of conflicts of interest?
What role should accrediting bodies play in monitoring and assuring the objectivity of certification bodies and auditors?
We think the transparency feature of FSMA’s accredited third party program can contribute significantly to the credibility of private audits, but:
What information from audits should be provided to FDA?
How can FDA best use this information to verify the integrity of the audit system, inform the industry of emerging issues and trends, and improve the targeting and effectiveness of FDA’s food safety efforts?
And, what information should be made public?
Finally, how should FDA structure its relationship with recognized accrediting bodies? These organizations will play a crucial role in an accredited third party certification system, but:
What attributes must they have to be successful?
Are there thresholds of expertise, experience and capacity that must be reached to be recognized by FDA as an accrediting body?
Once recognized, how should accrediting bodies be overseen by FDA and held accountable for the rigor of their accrediting activity?
These are just some of the difficult challenges and issues we must tackle together. The next big opportunity for engagement on these issues will come in the spring, when we hope to publish and invite comment on the proposed rule establishing the framework for FDA’s accredited third party certification program. I know we can count on GFSI’s close scrutiny and detailed comments on this rule.
But our collaboration will have to go well beyond the rule. Many of the challenges involve institution and capacity building. They go beyond anything FDA can address in a regulation. They are about constructing the basis for a new, global food safety system that works better for both consumers and the food industry.