Signed, Sealed, … Safe? How Over-reliance on CoCs and CoAs Creates Food Safety Blind Spots

As food safety professionals, we love a good document with a tidy little check box that says, “You’re good to go”. But here’s the uncomfortable truth: these certificates are only as strong as the processes and systems behind them. Don’t get me wrong, Certificates of Analysis and Certificates of Conformance (CoCs and CoAs) absolutely have value, but they are NOT a substitute for understanding your supplier’s processes, your ingredients, or the risks inherent to your product. When companies over-rely on paper documents purporting safety or quality related conformance, they unintentionally create blind spots – places where assumptions slip in and hazards slip through. 

In this post, let’s break down why that happens and how to use these documents to their fullest capacity. 

CoA or CoC – Aren’t We Talking About the Same Thing?

Let’s settle on terminology used for the purposes of this blog. I see industry members and food manufacturers often use the terms Certificate of Analysis (CoA) and Certificate of Conformance (CoC) interchangeably. Though there can be overlap, these two are not necessarily the same and may provide different information in your assessment. CoCs are often used to communicate a broader set of information that a product meets general standards or requirements, often without granular information like that which would be included in a CoA. A CoC might include quality, safety, or regulatory compliance information, providing assurance that the product is safe for its intended use as an input to the process or ingredient. On the other hand, a CoA should provide specific, batch-level results that a product meets specifications which is important information to have on hand in the event that there is a problem with your product or process. Think of a CoA as “here’s the exact data for this batch” and a CoC as “this product is compliant with the rules or standard”. 

Building a False Sense of Security

CoAs and CoCs must not be treated as standalone documents or checkboxes without further probing. For example, a CoA might list a negative pathogen test result, but it is less likely to tell you about the sampling plan, lab accreditation, method validation, or sample representation of the overall lot. Similarly, a CoC might confirm compliance with a spec, but not whether the supplier’s controls are robust or consistently applied/achieved. These often represent a snapshot and can mask variability. Without diving deeper and asking more detailed questions from your suppliers, you are missing out on critical information that would allow you to fully assess the product’s safety or quality. 

Trust But Verify

A document that lives in a folder that checks the box is great for audit purposes but will fall short on providing benefit to your overall risk reduction strategy. Companies should independently verify that the supplier or manufacturer is doing what they say they are doing. This might include your own periodic testing to confirm the same results are being received, inspection of ingredients or inputs, conducting an on-site visit, and routine auditing of the manufacturer or supplier’s performance. Verifying this information also means ensuring that the results align with your needs. Does the analyte used for testing actually help to inform and address your identified hazard? Do the lot numbers match your own records? Are the specs outdated to your company’s policy? These inconsistencies and misalignments happen more often than you would expect!

Leverage the Data

One benefit, especially with CoAs, is that you have more granular information at your fingertips to utilize - but only if you’ve created a system that facilitates the information to be leveraged easily! A document that lives in a folder or email inbox in PDF format isn’t nearly as valuable as data or information captured and organized in a way that can be used for analysis. Digital platforms (and even rudimentary data entry into Excel) which capture information from certificates can facilitate better supplier performance evaluation and trending. Don’t just let that data sit – do something with it. 

The Bottom Line

CoAs and CoCs are tools, not safety nets. They are pieces of information that are valuable but not complete on their own. A strong food safety program uses certificates as part of a broader, risk-based strategy: one that understands the product, the process, and the people behind every food and ingredient.