In 1862, President Abraham Lincoln established the U.S. Department of Agriculture. This was the first federal agency concerned with food regulation in the United States. Several reforms to food safety protection promulgated over the next century, including the Federal Food, Drug, and Cosmetic Act of 1938. Yet nothing so drastically changed the regulation of the food industry as the Food Safety Modernization Act (FSMA) when it was signed into law in 2011.
However, certain portions of FSMA cannot be properly implemented without qualified food safety professionals, including food safety auditors. In fact, FSMA requires trained food safety professionals and auditors to carry out some of the most critical and impactful components of the law. Food safety auditors will help implement FSMA’s foreign supplier verification and voluntary qualified importer programs, and certification of high-risk imported foods. Competent, qualified auditors are needed to carry out the functions described in the regulations. Auditors will become one of the last lines of defense in the complex global food supply chain. The food safety auditing profession typically requires years of experience in various roles, but this creates a conundrum for the industry as FSMA deadlines are fast approaching.
Lack of a Career Path
A direct pathway for food safety experts to gain the required audit experience and technical knowledge necessary to achieve the high status of food safety auditor has traditionally not existed. “In fact, the absence of a realistic career path is one of the largest challenges facing the auditing industry,” explains Patricia Wester, president of PA Wester Consulting and an experienced veteran in food safety. “The lack of a career path is the heart of the problem, and it has been an ongoing issue for over a decade.” Wester has worked closely with the National Environmental Health Association (NEHA) developing food safety curriculum and educational materials.
Addressing the challenges that the food industry faces regarding the training of auditors is an urgent matter. FSMA exponentially increases the level to which second- or third-party audits must occur, both domestically and internationally, and the demand for these audits is rapidly rising. Unfortunately, the lack of a pathway to the auditing profession is not the only obstacle that the food industry must resolve. Although the need for food safety auditors is clear, the number of trained, qualified auditors available to meet the current demand is already inadequate. The compliance deadlines do not provide ample time to prepare for FSMA under traditional methods.
NEHA Credential for Food Safety Auditors
After dedicating several years to crafting a plan for a credential and a pathway for professional food safety auditors, NEHA has outlined a strategy that can mitigate the challenges the nation faces when it comes to ensuring safe food for consumers. The association recently introduced its food safety auditor training, established a curriculum and created a progressive credentialing program. The program will allow food safety professionals to enter the field of auditing and build on their experience. Finally, there is a solution to auditor capacity-building within the complex international food supply chain.
NEHA has been responding to the nation’s public and environmental health concerns for almost 80 years and is looking forward to offering the food safety auditor credential. “I consider this credential to require a very high level of food safety knowledge,” says Rance Baker, program administrator for the Entrepreneurial Zone at NEHA. Baker oversees the development of food safety education training and projects at the association. He has more than 30 years of experience communicating knowledge to food safety professionals and has worked with numerous stakeholders to bring this credential to fruition. “I am excited that the training, assessment, career track and credential are finally available for the food safety auditing community,” he says. Receiving a credential from NEHA means that candidates have mastered a body of knowledge and have sufficient experience to perform in their discipline.
One of the unique elements of the food safety auditor credential is that it has two career path levels: level one and level two. Part of the purpose of a tiered system is to build third-party capacity so there are more auditors actively practicing in the field. A tiered system also provides an opportunity for individuals who might have less experience to cultivate their knowledge, skills and abilities. The tiered system also allows them to pass an exam to enter the field as an auditor and gain the work experience and knowledge they need to qualify for a credential.
In fact, one of the first steps NEHA took in developing this credential was partnering with a professional testing firm to conduct a job task analysis for food safety auditors. In this analysis, 500 food safety auditors and inspectors from nearly all 50 states and from several other countries participated in a survey that asked them about their roles, the training they received and what a food safety auditor’s curriculum and knowledge ought to entail. The results were enlightening and prove how vital the credential and training are for the future of the profession. Of the auditors that responded, 16 percent had never received specific training to become an auditor. Many illustrated that their training was informal or occurred haphazardly. Assuming that the respondents are a representative sample of the workforce (which is not an accessible number, as no official registry of professional food safety auditors exists) implies that nearly one of every six people responsible for ensuring safe food practices might not have received adequate training to be a food safety auditor.
“Essentially, where do you go to learn how to become an auditor?” asks Wester. “The current options require a substantial time investment in one industry. Options requiring less time do not exist. The demands on an auditor should not be underestimated.” says Wester. “Assessing a facility’s food systems in a limited amount of time is a huge responsibility, and the industry needs to shorten the learning curve and provide resources to help auditors succeed.” NEHA worked with Wester to develop a study guide, student participant guide and learning materials to support the food safety auditor courses and training that underpin the credential.
Kimberly Onett, a credentialing and training expert, is also excited about the tiered system. “Having a pathway to a career as an auditor is important because it’s all about experience,” says Onett. “The knowledge, training and in-plant experience of different products and processes are hard to obtain. This is why it’s typically a second career for folks after years of inspecting.” She echoes the concerns of all experts in the discipline. “It’s a difficult field to enter, and we need to have a way to bring younger people with food safety knowledge into the field,” she explains.
NEHA Credentialing Program
“NEHA is very well positioned to provide a respected credential, and we take great pride in the credentialing program,” TJay Gerber, credentialing coordinator at NEHA, says. His dedication to the new food safety auditor credential is readily apparent, and he describes in great detail the processes that are in place that ensure high standards. “Food safety is an important frontier, and it is an international frontier. We need to make sure food and food manufacturing processes are safe across the globe,” Gerber explains. Gerber manages the credentialing department projects, which include continued education, development processes and department functionality and basic operations. “How do we know if a facility in another country is following the proper sanitation procedures that are required in the U.S.?” he asks.
Checklist and Requirements
To become credentialed at either level, candidates must check off certain items from a checklist designed by many of the stakeholders involved in the development of the credential. A detailed checklist illustrates what candidates must achieve to be recognized as either level. The checklist has specific requirements that must be met for an individual to be eligible to apply or qualify for the credential. Some of the items on the checklist include proper training, witness audits, an exam, prerequisites and adequate years of experience. To maintain the credential, individuals must be actively auditing and also accumulate the appropriate number of continuing education contact hours.
“Now, whatever level they are in, they will have a solid understanding of what it takes to be an auditor,” says Onett. “A progressive credentialing system for auditors is essential. Credentialed auditors will know how to write a report, engage in critical-thinking skills, take in information, perform an analysis and make a solid assessment.”
One expectation is that candidates must achieve a passing score on the food safety auditor exam. With the level one credential from NEHA, an auditor can attest that she or he passed the exam and begin a career track that might start in a food manufacturing facility or an auditing firm. The candidates can then build their years of experience in the other areas and complete other items on the checklist needed for the level two credential. This innovative function is what will build capacity to meet the long-term needs of FSMA.
“A level one auditor might be capable of inspecting and verifying a facility’s food safety plan, be a food safety manager in a facility or handle supply-chain verifications,” Baker says. “They must pass the exam but might not have enough experience for the level two credential.” The exam has not been released yet, but NEHA expects candidates to have an opportunity to sit for the examination before the end of 2016.
The witness audit is an opportunity for candidates to demonstrate their ability to conduct an effective audit. “A witness audit will confirm that the candidate has the necessary technical knowledge to produce a product safely and knows how and where to gather information about what a site is doing,” Wester says, adding that this part of the job can be challenging. “For auditors to give a correct risk ranking, and use the soft skills needed, they must interview staff to confirm their comprehensive training and job performance, or potentially deliver the bad news of a poor or failing audit score. Sounds like fun, right?”
The process of creating this highly coveted credential took place over a number of years and brought together experts and food safety professionals from a variety of industries. NEHA involved regulatory agencies, governmental entities, nonprofit agencies, organizations and academia in the development of this credential. The development process was initiated with a team of subject-matter experts who collected data from respondents and then developed a blueprint of the tasks, skills and knowledge necessary to carry out the auditor job. The data collected were also used to structure the exam and the required passing score. The analysis resulted in a job task analysis that describes the knowledge, skills and abilities of food safety auditors.
Dr. Cynthia Woodley, psychometrician and credentialing professional, has developed personnel certification programs for more than 20 years and describes the credential with great regard: “The program that has been developed for NEHA is a really solid program. It not only is a knowledge-based program, but they are also measuring skills.” She elaborates, “What NEHA will end up with is a credential that is probably the most robust of all the food auditing credentials out there.” Dr. Woodley says she believes that auditors who get this credential will be able to say that they have a quality credential. NEHA has involved psychometrics in development of the credential and exam so it is valid, reliable and legally defensible.
The credential validates an individual’s capabilities to do food facility audits and consultations as required by FSMA. NEHA has restructured the auditor training and updated the credential as FSMA’s final rules and guidance were published to include the new requirements. The association will revisit the credential every year to analyze whether there are areas that can be improved.
NEHA has had the opportunity to share long and productive partnerships over the years with numerous organizations that promote public health. The stakeholder group involved in the development and creation of the food safety auditor job task analysis and exam included subject-matter experts from the U.S. Food and Drug Administration, Safe Quality Food International, SGS, Steritech Inc., Silliker Inc., Professional Testing Inc., NSF International, ConAgra Foods, the American Frozen Food Institute, Food Safety Net Services, Eagle Registration, Sysco and UL.
Auditor Job Description
There is a consensus among industry professionals on the importance of having a universally agreed-upon job description for food safety auditors. When asked what a food safety auditor’s official job description might be, Wester responded, “Auditor job descriptions are literally written as ‘a little industry experience, a little quality control, some hard sciences such as chemistry or microbiology, and some audit training or experience.’” She reiterates that there is not just one way to audit and that each industry has unique needs.
Some auditors may come from an industry with only a narrow skill set based solely on a particular product. Others may have higher levels of quality assurance and quality control training or management experience. Many auditors have shifted their careers from regulatory inspection and are often retired.
Although auditors exist in many professional fields, the role of auditors in the world of food safety is unique. In general terms, food safety auditors are charged with the responsibility of ensuring a safe food supply for consumers.
The food safety auditor’s day begins in the facility’s corporate office, reviewing the food safety plan and a huge stack of books and files, evaluating the Hazard Analysis and Critical Control Points (HACCP) monitoring plan and assessing the violations found and corrected at a site. An audit can take a full week or longer. When the process is complete, the auditor must write a report and explain what is being done properly and what needs to be changed. Without proper training, it can be challenging for an auditor to complete this comprehensive work successfully.
Food safety auditors are responsible for conducting food facility audits, reviewing food safety plans and communicating nonconformances to facility managers so managers can correct or improve production processes. Auditors must confirm that a facility assesses potential hazards, develops control measures and consistently follows all measures that are in place. Basically, the job of a food safety auditor is to verify that an establishment practices what it preaches.
NEHA’s food safety auditor credential is being developed to be compliant with ISO/IEC 17024. Recognition of this standard means that a body providing accreditation maintains high standards of ethics, professionalism and integrity. ISO compliance would allow for the credential to be internationally recognized so food safety professionals can practice around the globe. This will help NEHA bring the food safety auditor credential into places where it is needed and ensure that the credential is not just U.S.-centric. The food safety auditor credential demonstrates NEHA’s commitment to global food safety protection.
Currently, 15 percent of U.S. food is imported, and imports are generally responsible for half of foodborne illness outbreaks. FSMA mandates that food coming into the U.S. be verified and meet the same standards as foods that are produced in the United States. International acceptance of the food safety auditor credential will prove to be extremely valuable.
More than 60 people attended NEHA’s food safety auditor pilot course that was offered at the Food Safety Summit in May of 2016. This training is designed to strengthen and enhance the skills, knowledge and critical-thinking behaviors attributed to a qualified food safety auditor. It provides the participants with a comprehensive review of good auditing practices, written and verbal communication skills, and technical knowledge of preventive controls. The use of classroom exercises, case studies and other interactive learning techniques mimics an actual third-party audit. Participants who successfully finish the course receive a certificate of completion from NEHA. Many of the attendees at the pilot training came to learn about the different rules, regulations and requirements of the new law and how FSMA might affect their business or profession in the future.
NEHA already provides public and environmental health professionals with numerous certificates, credentials and educational materials, which range from beginner to advanced levels. NEHA also develops distinguished-merit markers for public and environmental health, and more than 6,100 professionals in the field hold one of its credentials.
The credentials NEHA currently offers include:
• Registered Environmental Health Specialist/Registered Sanitarian (REHS/RS)
• Certified Professional – Food Safety (CP-FS)
• Certified in Comprehensive Food Safety (CCFS)
• Healthy Homes Specialist (HHS)
• Certified Installers of Onsite Wastewater Treatment Systems, Basic (CIOWTS-B)
• Certified Installers of Onsite Wastewater Treatment Systems, Advanced (CIOWTS-A)
For more information about NEHA’s training, professional credentialing and food safety auditor credential, please visit neha.org or email email@example.com.
The author would like to thank Patricia Wester, Dr. Cynthia Woodley, Dr. Adrienne Cadle, Kim Onett, Rance Baker and TJay Gerber for their invaluable contributions.
Nancy A. Finney, M.P.A., is technical editor at the National Environmental Health Association.