The practice of evaluating food safety systems has become a vital part of doing business in the food and beverage industry. While governmental inspections have been a regular occurrence for over a century, third-party and customer second-party audits have become increasingly common in the past three decades. Only recently have options emerged for these types of audits to be performed remotely.
Traditionally, virtual auditing has taken a backseat to onsite evaluations, and remote governmental inspections were almost nonexistent. This drastically changed in 2020, when social distancing mandates and employee protection measures, triggered by the COVID-19 pandemic, barred visitors (including auditors and inspectors) from manufacturing facilities. This scenario became the catalyst for the widespread use of remote alternatives, and third-party auditing companies, customers, and governmental regulators quickly took up this challenge and found ways to continue within these limitations. Plato famously wrote, "Our need will be the real creator," which evolved into the proverb, "Necessity is the mother of invention." The urgent need for alternatives to in-person audits has escalated innovation in the processes and tools used to bridge the gap between virtual and onsite evaluations.
Recently, advances in Information and Communication Technology (ICT) and novel approaches to auditing have enabled positive strides in the field of remote audits. The larger question remains: Will these advances serve as sustainable solutions to help virtual audits and inspections gain equivalency to traditional onsite formats? To answer that question, it is imperative to understand the technological advances that are being developed and the positive and negative ramifications for continuing with a remote format.
By Wendy White, M.Sc.
Technological Developments for Remote Inspections
At present, much focus is being placed on perfecting ICT tools to facilitate and drive the effectiveness of remote audits and inspections. These tools are vital to maintaining the integrity, efficacy, and efficiency of virtual formats. This concept encompasses both hardware and software, often working together. It can include traditional technologies such as laptop computers, file-sharing programs, teleconference platforms, closed-circuit television (CCTV) cameras, and smartphones, and it can also include novel uses of drones, wearable technology, and artificial intelligence. Although not all ICT falls into these two categories, tools that enable document evaluation and visual observation and communication are mandatory to conduct virtual assessments.
The review of documentation, from food safety plan procedures to completed monitoring records, is one of the cornerstones of an effective audit. This is perhaps the easiest facet of a remote assessment. Hybrid "desk audits" or remote evaluation of documents, prior to the onsite audit, were commonplace even before the pandemic. Different means of exchanging this information may include shared storage sites, such as Dropbox and OneDrive, where documents are pushed to a location and retrieved by the evaluator. Real-time evaluation may also be possible by using video conferencing or through programs like Team Viewer, in which the documents remain in their original location but are temporarily available for viewing by another party. Automated programs can also scan documents and extract specific information, which is then compared against a standard.
These solutions have unique challenges, such as properly securing confidential information and ease of use. Increased demand has accelerated the development of online platforms, designed specifically for sharing and remote viewing of documents. Some auditing companies are developing their own, proprietary platforms. This is also being done by various governmental agencies, which are developing platforms that are being used to evaluate foreign suppliers of imported foods.
Another cornerstone of audits and inspections is the ability for an individual to conduct visual observations of the facility and speak with employees. This process helps verify that the activities occurring on the shop floor are accurately reflecting what is written in the food safety program and that employees are performing and documenting these activities correctly. Vision ICT, with or without augmented reality, has become a vital tool for any remote auditor. It can take the form of accessing the facility's video camera system, video chatting via smartphone or tablet, or viewing operations via wearable video systems. This video/audio can be either pre-recorded or viewed live by a remote party.
The wearable technology can be as simple as a body camera (like those used by police officers) that attaches to the lapel. A more sophisticated cousin is self-contained, hands-free, wearable technology with cameras, speakers, and computer screens. Wearable tech (usually worn as a pair of glasses or a facemask) was originally intended to be the next "must-have" accessory. A series of accidents by first adopters stalled the widespread adoption by the public, but wearable tech has been repurposed for other, innovative uses.
Wearable video communication systems can be worn by the plant representative that is facilitating the audit and gives the remote auditor real-time video and audio via live streaming. The remote auditor can then issue instructions on what they would like to observe and even conduct employee interviews on the shop floor. Several auditing companies are taking advantage of this technology. NSF International is utilizing Google Glass, while Ecolab has opted to use Microsoft HoloLens. These technologies give a remote auditor the opportunity to see what the onsite facility representative is seeing. In addition, if needed, the remote auditor can visually direct the onsite representative to take a closer look at an object in the background or turn in a specific direction.
Both the remote auditor and the onsite wearer of this technology must consider a number of factors. The wearer must consider the visual and auditory impact of enabling the technology, as the obstruction of their normal vision and hearing could easily become a serious hazard.
When deciding if this technology should be used, the onsite representative should consider:
- Can they hear the remote instructor's voice, despite plant background noise?
- Is it easy to communicate?
- Can they also wear required personal protective equipment (PPE) such as safety glasses and/or ear plugs?
- How comfortable is this technology? Can it easily be worn for hours at a time? Is it heavy?
- Does it have the necessary battery life to last a few hours on the shop floor and be continuously operational throughout the audit?
- Does wearing this ICT tool distract the auditor or wearer at the facility?
The remote assessor should take into consideration:
- Is it easy to communicate with the onsite wearer?
- Is the communication in real time, or is there a lag?
- Can others be clearly seen and heard?
- Is it difficult to see objects in the background?
- Do the lenses fog, or are objects blurry?
- Is translation possible using this technology?
- What are the limits to observation? Is there good visual flexibility?
The decision to conduct remote auditing or inspection involves evaluating many variables and must be carefully planned. However, despite possible challenges, use of these systems may lead to unexpected benefits.
Benefits of a Virtual Format
Even though pandemic restrictions on travel and visitor access are being relaxed, the demand for virtual inspections and audits is likely to remain elevated. Many of the benefits of virtual audits and inspections revolve around a reduction in the resources necessary to perform these assessments. Increasingly specific and stringent global standards have boosted demand for auditors with appropriate backgrounds and experience. Remote desk audits allow for remote auditors or multiple reviewers to easily access the information needed for document evaluations. This could go a long way toward easing the industry's growing demand for competent and specialized food safety auditors.
A supply chain manager for a large, global company recently spoke of the unexpected benefits their company discovered when forced to switch to remote auditing in 2020. By pivoting to a virtual supplier evaluation program, they were able to conduct five times as many assessments on foreign suppliers. The new process was so successful, the manager decided to conduct all low- and medium-risk supplier audits in this manner going forward, to allow for more frequent evaluations. It is thought that having more frequent communication with suppliers will serve to balance the potential nonconformities that could be missed utilizing a virtual format, especially as the manager's company also requires an onsite third-party food safety audit.
Remote evaluations will also make it possible to evaluate facilities in areas of the world with security issues, access limitations, or travel restrictions. Sites with elevated security requirements (for example, prisons or secure governmental facilities) or that require assessors with specific skills, backgrounds, or security clearances could also be more easily evaluated. In talking with an executive from a global beverage company, she admitted that the company's processing plant on the Gaza Strip had not been visited by a corporate representative in 20 years. Utilizing ICT, auditing foreign facilities could be just as easy as visiting one down the road, and while not perfect, they are much better than no audit.
Unannounced access to stationary CCTV cameras can allow greater access, which enables the remote auditor to make unannounced observations without interrupting operations and ensures that authentic conditions are being evaluated. This model has been successfully employed by third-party companies for years to evaluate the effectiveness of animal welfare systems at processing facilities or to monitor sanitation practices at hospitals. In these situations, typically the third-party evaluator is contracted by the company to access the facility's cameras, observe employee practices and facility conditions, and report any nonconformances or areas of interest to management.
As mentioned earlier, remote evaluations might serve as a solution to the increasing issue of auditor and inspector capacity. The frequency of third-party food safety audits and governmental inspections has greatly increased in the past three decades, while auditor qualification standards have become increasingly stringent. This has caused both industry and government agencies to report a deficit in experienced auditors and inspectors. Travel to and from facilities takes a great deal of an assessor's time. If this was reduced or eliminated, it would enable these individuals to conduct more audits over the year or allow multiple evaluators to participate. An auditing company (or certification body) would also have the benefit of streamlining auditor schedules to optimize assignments, based on auditor background, experience, and knowledge base. This would also appeal to situations where an assessor with a specialized background, certification, or security clearance is needed.
Another consideration is how remote access would streamline the practice of shadow audits for new auditors to use for training purposes. This could also aid in conducting peer evaluations to verify the effectiveness of the auditor or certification body (auditing company) for a certification scheme or assess the effectiveness of contractors. Advances in processes and technology continue to enhance these remote evaluations and solve long-existing problems, but some inevitable challenges have arisen with this format (Figure 1).
Figure 1: Technology Advances in ICT Continue to Enhance Remote Evaluations, but the Format Must Also Overcome Challenges
Challenges of a Virtual Format
In addition to the equivalency concerns of virtual versus onsite audits, virtual evaluations must also overcome some serious concerns. The privacy of employees, who might be observed or recorded without knowledge or permission, is at the top of this list. The protection of proprietary company information and confidentiality is also a strong concern. How will the auditing company or government agency protect confidential information, and are validated cybersecurity measures in place? These security and privacy concerns should be addressed prior to the assessment with validated ICT and a well-defined auditing plan that discusses safeguards and contingency plans.
Many of the benefits revolve around streamlining resources, but while remote formats reduce the time taken for travel, they can also lead to unnecessary complications that could increase the total audit timeframe. Remote audit planning and preparation take more time than a traditional audit. It is vital that sufficient time is given to logistical planning, shipping/testing of ICT tools, and ensuring that everyone is comfortable with the audit plan. Contingency plans should also be agreed upon beforehand to ensure that interruptions are handled quickly. As auditors and facilities become more familiar with ICT tools and processes are streamlined to optimize the audit flow, technology glitches should become less frequent.
Another concern might seem less serious but is vital to any real-time virtual assessment: Live streaming both audio and video to enable real-time auditing and communication requires the ability to connect to high-speed internet. Anyone that has worked in a processing facility knows that concrete walls, conflicting signals, and masses of equipment can make obtaining sufficient Wi-Fi for an audit challenging. Even if a facility has sufficient Wi-Fi in some parts of the plant, it may be difficult to access it in all of the areas that need to be covered for the assessment.
Another challenge that is often cited when discussing the equivalency of remote versus onsite audits is the missing aspect of organoleptic evaluation. Those who are familiar with food processing are aware that the nose is vital to identifying areas of concern. At present, there is no good way to incorporate smell into remote evaluations, but sensor technology could one day be used to fill this gap by detecting specific volatile gases that are emitted by microorganisms and decaying food.
Validating Virtual Formats
Unfortunately, limited validation and verification data exist for this topic. Not many peer-reviewed studies have been performed to assess the effectiveness of virtual audits for manufacturing or to gauge their equivalency to traditional, onsite activities. However, extensive studies and peer-reviewed literature are available on the effectiveness of virtual observations and audits of hospital operating rooms, which is somewhat analogous to food safety audits. These virtual assessments have proven to have a positive effect on sanitation standards and conformity to hospital procedures. Many pilot programs and studies are being undertaken for virtual audits that will help better assess the effectiveness of virtual formats for food facilities.
The "Je Ne Sais Quoi" Factor
The final consideration when determining the effectiveness of virtual audits and inspections is not as easily defined. A few years ago, the author was discussing one of the numerous "undercover video animal welfare scandals" with a group of colleagues. We were shocked by the news because the company had just scored high marks on a legitimate animal welfare third-party audit. One of our colleagues had recently toured the facility to perform a customer audit, and we asked his thoughts. He told us that while the news shocked him, it did not surprise him. We were puzzled at that response and urged him to expand. He told us that while the company was doing absolutely everything required by the audit checklist, he had an inexplicable feeling when visiting the facility that told him the company was not fully invested in animal welfare. Management wanted to be compliant, and everything looked correct on paper, but the company was simply "going through the motions" and was not fully committed.
Everyone in that room of experienced auditors instantly knew what he meant—what the author refers to as the "Je ne sais quoi" factor. This French phrase translates to, "I do not know what," but it has come to mean an indefinable, elusive quality. This is exactly what virtual auditing lacks over onsite visits. Being immersed in a situation gives an indescribable feeling that can only be experienced directly—that "sixth sense" that something is not quite right. We debated this for a while and concluded an informal customer visit with no checklist might be more effective than a formal, second-party audit for facilities that already have a reputable, third-party food safety annual audit. Making the time for good conversation with people and walking the floor with no real focus can help an auditor pick up on the undefinable aspects that often point to a problem.
Future of Virtual Assessments
The pandemic forced many companies to pivot to virtual food safety audits and government agencies to utilize virtual inspections, but there has been reluctance to sustain this model of remote assessment for the long term. The debate over whether technology will one day allow virtual auditing to reach equivalency with onsite auditing still rages. There are some undeniable benefits to virtual audits, such as freeing up resources to increase the frequency of audits and auditor capacity building. Significant investment into auditing technologies, such as document-sharing portals, vision technology, etc., is also working to close this gap.
ICT is still being developed and tested. New technologies such as sensors, DNA testing, artificial intelligence, drones, and satellite imagery could be used in the future to improve remote audits. Many of these technologies will work in sync, such as sensors collecting data (visual images, odors, gases, and other measurements) that will be fed into digital platforms that perform predictive analytics and machine learning to automatically verify food safety systems.
For now, the best means of deciding on an audit format will be to assess several factors including the audit's scope, the risk of the product being produced, the history of the facility and company, the availability of competent auditors and auditing resources available, the travel or site restrictions/security concerns in place, and the ICTs that can be utilized. The key to success will be diligent audit planning, ensuring that all parties are familiar and comfortable with the ICT(s) used, and allowing time to conduct a test run to ensure that the communication system is working correctly.
In the end, the benefits of remote interaction will need to be measured against the shortcomings of not being physically present. Each audit and inspection is conducted in a unique situation, and while virtual audits may not ever reach true equivalency with traditional in-person assessments, they might actually be more appropriate given the circumstances and factors involved.
Wendy White, M.Sc., is the Food and Beverage Industry Manager for the Georgia Manufacturing Extension Partnership (GaMEP) at Georgia Tech, a state, and federally funded program that helps manufacturing companies increase top-line growth and reduce bottom-line costs through onsite projects, training, and connections to other resources. Ms. White leads GaMEP's food industry services, which include regulatory compliance, HACCP food safety plans, and third-party audit certification preparation. She holds a B.S. degree in Biology and an M.Sc. degree in Food Microbiology from the University of Georgia and is an FSPCA PCQI Human Foods Lead Instructor, an International HACCP Alliance Lead Instructor, and an ASQ Certified Quality Auditor.