Audits of commissaries, central kitchens and other off-site facilities that provide prepared foods and other value-added products to retail grocery stores are typically not as in-depth as audits of typical grocery suppliers, says Tyler Williams, vice president of operations for St. Louis-based ASI LLC.

But that doesn’t mean that commissaries and central kitchens don’t present their own unique challenges to third-party auditors like ASI, Williams says.

“The challenge with commissaries boils down to people and training,” Williams says. “It’s big with manufacturers as well, but at the commissary level, the kitchen training gets a little trickier.”

Cross-contamination is one of the main things ASI looks for when conducting food safety audits of commissaries, Williams says. “If they’re cutting raw chicken, are they using a separate board to cut vegetables? Or, if not, are they at least cleaning the utensils and board in between?” Pest management is another measure high on the to-do list of commissary audits, he adds.

One problem with food safety audits of commissaries is there aren’t enough of them, Williams adds.

“They’re a lot more rare than they should be,” he says. “If it’s a supplier, the grocery store will demand that you have an audit. With a commissary, you really don’t have that — even though the place where someone is most likely to get sick is at the commissary or kitchen level.”

And an “audit” by a governmental agency doesn’t likely cut it, Williams says. “A state or local government body may come in and do a vague, 2-hour inspection — it’s not even an audit.”

Another common, and equally insufficient, method is to have the grocery store use its own employees to audit or inspect the commissaries it partners with. This method can be rife with conflicts of interest, since the grocery inspector may have a longstanding relationship with people in the commissary and be inclined to give them a pass.


Establishing a baseline

Food safety audits play a key role for retailers to establish a baseline of potential suppliers and routinely assess current partners, says Jake Watts, vice president of food safety for Kieler, Wisconsin-based food safety and contract sanitation provider PSSI.

“With advancements in traceback and pathogen detection with growing regulatory scrutiny, and heightened consumer knowledge raising the bar on food safety, the importance of food safety audits has grown significantly in recent years,” he says.

A meaningful food safety audit, Watts says, takes a holistic approach when evaluating a food safety management system. That includes factors such as program design, compliance, documentation, training, and an integrated action plan tool.  In addition, direct observations by the auditor of the implementation of the food safety system is an important aspect of an effective audit.

The biggest change in food safety audits has been the collaboration amongst retailers and manufacturers to develop food safety standards, Watts says. In addition, audits have become more risk-based focused on the various food safety hazards, he says.  

PSSI, Watts says, has a standalone food safety department staffed with practitioners who have the experience, knowledge, and certifications to support each sector within the food and beverage industry. 

“Ultimately, it’s our commitment to be a leader in food safety combined with our capabilities to protect our partner’s brand while safeguarding consumer products” that sets the company apart, he says.

Looking specifically at commissaries, central kitchens and other third-party facilities that supply value-added and other foods to grocery stores, Watts says that while the environment is different from a typical supplier environment, the goals and even methods of achieving them are often the same.

“Although these types of facilities can include a multitude of complex processes with dual regulatory oversight, generally speaking, the food safety audits conducted within these facilities follow the same food safety standards.” 


An objective view

The clear advantage of employing a third-party auditor, Williams says, is having a third set of eyes that doesn’t have a dog in the fight. To make sure its audits are even more objective, ASI rotates the auditor of a given company every three years to prevent personal relationships from impeding the audit.

“We want to be objective and not have that conflict of interest,” he says.

The ultimate goal of a food safety audit, though, regardless of whether it’s a commissary or a traditional supplier that’s being audited, is the same, Williams says: having preventative measures in place (or establishing them, if they’re not in place) to eliminate risks and to strive toward a goal of continuous improvement.

ASI has three divisions: one each for auditing, consulting, training. Sometimes the same person might wear two of those three hats for the same client, but the result would be an unaccredited audit, and Williams does not recommend it.

“You don’t want to be grading your own work,” he says.

The food safety auditing business has changed a lot — for the better — in recent years, Williams says.

“Ten to 15 years ago, audits were really just inspections,” he says. “They didn’t look at a lot of documentation. They made sure things were clean, saw that employees were doing what they needed to be doing on a given day.”

The problem was, while a company might be doing everything right on that given day, what about all the other days. Without looking at the documentation, it was impossible to know.

“Now there’s a lot more record keeping,” he says. “We look at the food safety management system as whole, not just the site.”

The importance of what food safety inspectors do can’t be overstated, Williams says. “With new employees, one of the first things we highlight is that in food safety outbreaks, certification bodies have been named in lawsuits. Luckily we haven’t been. And we don’t want that on our conscience. That’s our core passion.”