Tips and Traps for SQF 7.1: Understanding Top 10 Non-conformances

Tips and Traps for SQF 7.1: Understanding Tips and Traps for SQF 7.1: Understanding Tips and Traps for SQF 7.1: Understanding Tips and Traps for SQF 7.1: Understanding Top 10 NonTop 10 NonTop 10 NonTop 10 Non----conformances conformances conformances conformances

Bill McBride13 November, 2013

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Introductions

3

• Based in Sydney, Australia

• Asia Pacific Representative for SQF

program

• Chairman of the GFSI Auditor Competence

Scheme Committee

• CEO of Foodlink Management Services

since 1998

• Forty years experience in food and

beverage manufacturing, quality

management, food safety systems.

Agenda

• Welcome and Introductions

• The relationship between SQFI and GFSI

• The difference between the SQF Code, edition 7 and

earlier versions

• Top Non-conformances (NCRs), module 2 and module 11

• Common themes in NCRs:• Management Responsibility

• Business Continuity Planning

• Food Safety Plan

• Internal Audits

• Corrective and Preventative Action

• Tips for Compliance

• Q & A

GFSI Mission and Objectives

Provide continuous improvement in food safety

management systems to ensure confidence in the

delivery of safe food to consumers worldwide

ReduceReduceReduceReduce Food Food Food Food SafetySafetySafetySafetyRisksRisksRisksRisks

Manage Manage Manage Manage CostCostCostCost in the in the in the in the SupplySupplySupplySupply ChainChainChainChain

DevelopDevelopDevelopDevelopCompetenciesCompetenciesCompetenciesCompetencies and and and and CapacityCapacityCapacityCapacity BuildingBuildingBuildingBuilding

KnowledgeKnowledgeKnowledgeKnowledgeExchange and Exchange and Exchange and Exchange and NetworkingNetworkingNetworkingNetworking

GFSI - A Collaborative Approach

Retailers Suppliers

Food Service

Certification Bodies

Accreditation Bodies

International Organisations

Academia

Government

Scheme Owners

Service Providers

A multiA multiA multiA multi----stakeholder document that:stakeholder document that:stakeholder document that:stakeholder document that:

› Sets out the requirements for food

safety management schemes and the

key elements for the production of

food, feed, packaging, etc

› Provides guidance to schemes seeking

compliance with the GFSI Guidance

Document and recognition by the GFSI

› Defines the requirements for the

effective management and control of

conforming schemes

› Puts in place transparent procedures

for the GFSI benchmarking process

The GFSI Guidance Document

SQF Code Revision

The publication of edition

6 of the GFSI Guidance

Documented presented

SQFI with a challenge,

and an opportunity to

review the SQF 2000 and

SQF 1000 Codes and

revise as necessary

before resubmission

Revised SQF Code - Format

Part A: Implementing and Maintaining the SQF Code

1. Preparing for SQF certification

2. The Certification Process

3. The Certification Decision

4. Surveillance and Re-certification

5. Obligations of Suppliers and Certification Bodies

Part B: The SQF Code

Module 1: Scope, References, and Definitions

Module 2: SQF System Elements

Modules 3 – 15: Food Safety Fundamentals (GAP/GMP)

Module 16: Multi-site Program

Appendix 1: Food Sector Categories

Appendix 2: Glossary

Appendix 3: SQF Quality Shield and Logo

Module 2: Module 2: Module 2: Module 2: SQF System Elements (applies to all Suppliers) SQF System Elements (applies to all Suppliers) SQF System Elements (applies to all Suppliers) SQF System Elements (applies to all Suppliers)

Module 3: GAP for Single Feed Production (TBD)

Module 4: GAP for Compound Feed Production (TBD)

Module 5: Farming of Animals (FSC: 1)

Module 6: Farming of Fish (FSC: 6)

Module 7: Farming of Plants (FSC: 3)

Module 8: Farming of Grains and Pulses (FSC: 5)

Module 9: Animal Conversion (FSC: 7)

Module 10: Pre Processing Handling of Plant Products (FSC: 4)

Module 11: Processing of Animal Perishable Products (FSC: 8,9,10,11, 12)

Module 11: Processing of Plant Perishable Products (FSC: 14, 22)

Module 11: Processing of Animal and Plant Perishable Products (FSC: 20, 21)

Module 11: Processing of Ambient Stable Products (FSC: 13, 15, 16, 17, 18)

Module 12: Provision of Transport and Storage Services (FSC 25, 26)

Module 11: Production of (Bio) Chemicals (FSC: 19, 31)

Module 13: Production of Food Packaging (FSC: 27)

� Approved

� Approved

� Approved

� Approved

� Approved

� Approved

� Approved

� Approved

� Approved

� Approved

not benchmarked; need 10 certificates

not benchmarked; need 10 certificates

The SQF Code, edition 7Implemented July 2012

� Approved

not benchmarked

The SQF Code, edition 7.1Implemented July 2013

Key Changes:

� Approximately 50 changes

� Addition of the feed, pet food and Harmonized

produce module

� Realignment of FSCs 32, 33 and 34

� Added requirement for the auditor to review the

entire facility, regardless of the scope of

certification

� The addition of requiring facilities to report all

regulatory warning letters to SQF (of public nature)

� An additional element that requires the facility to

follow the requirements of the Quality Shield

� Added an element on air and water quality to

comply with GFSI distribution Guidance Document

Module 2: SQF System Elements (applies to all Suppliers)

Module 3: Module 3: Module 3: Module 3: GMP for Animal Feed Production(FSC: 34) GMP for Animal Feed Production(FSC: 34) GMP for Animal Feed Production(FSC: 34) GMP for Animal Feed Production(FSC: 34)

Module 4: Module 4: Module 4: Module 4: GMP for Processing of Pet Food (FSC: 32) GMP for Processing of Pet Food (FSC: 32) GMP for Processing of Pet Food (FSC: 32) GMP for Processing of Pet Food (FSC: 32)

Module 5: Farming of Animals (FSC: 1)

Module 6: Farming of Fish (FSC: 6)

Module 7: Farming of Plants (FSC: 3)

Module 7H: Farming of Plants (FSC: 3)Module 7H: Farming of Plants (FSC: 3)Module 7H: Farming of Plants (FSC: 3)Module 7H: Farming of Plants (FSC: 3)

Module 8: Farming of Grains and Pulses (FSC: 5)

Module 9: Animal Conversion (FSC: 7)

Module 10: Pre Processing Handling of Plant Products (FSC: 4)

Module 11: Processing of Animal Perishable Products (FSC: 8,9,10,11, 12)

Module 11: Processing of Plant Perishable Products (FSC: 14, 22)

Module 11: Processing of Animal and Plant Perishable Products (FSC: 20, 21)

Module 11: Processing of Ambient Stable Products (FSC: 13, 15, 16, 17, 18)

Module 12: Provision of Transport and Storage Services (FSC 25, 26) Module 12: Provision of Transport and Storage Services (FSC 25, 26) Module 12: Provision of Transport and Storage Services (FSC 25, 26) Module 12: Provision of Transport and Storage Services (FSC 25, 26)

Module 11: Production of (Bio) Chemicals (FSC: 19, 31)

Module 13: Production of Food Packaging (FSC: 27)

The SQF Code, edition 7.1Implemented July 2013

Preparing to submit to GFSI

Preparing to submit to GFSI

Submitted to GFSI for benchmarking

Submitted to GFSI for benchmarking

Modules in Development

• Module 14 GMP for Food Brokers (FSC 35)*

• Module 15 GMP for Retail (FSC 24)*

• * GFSI recognition will only apply once GFSI Guidance is

available for these sectors, and SQFI has requested an

extension

Top Non-ConformancesCertification Audits

Module 2Module 2Module 2Module 2

2.1.6.1 Business Continuity Planning

2.3.2.1 Raw and Packaging

Materials

2.1.2.1 Management Responsibility

2.3.3.1 Contract Service Providers

2.5.7.1 Internal Audits

2.5.2.1 Validation and Effectiveness

2.3.1.4 Specification and Product

Development

2.8.2.1 Allergen Management

2.1.2.5 SQF Practitioner

2.4.5.4 Incoming Goods and Service

15


11.2.13 Cleaning and sanitation

11.7.5. Control of Foreign Matter

Contamination

11.2.3 Walls, Partitions, Doors and

Ceilings

11.2.12 Equipment, Utensils and

Protective Clothing

11.2.9 Premises and Equipment

Maintenance

11.6.1. Cold Storage, Freezing and

Chilling of Foods



2.1.2.8 Management Responsibility

2.4.5.4 Incoming Goods and Services

2.1.4.5 Management Review

2.3.2.5 Raw and Packaging Materials

2.4.2.3 Food Safety Fundamentals

2.5.5.1 Corrective and Preventative

Action

16

Top Non-ConformancesRe-certification Audits


11.7.5.4 Control of Foreign Matter

Contamination

11.2.13.1 Cleaning and Sanitation

11.2.12.1 Equipment, Utensils and

Protective Clothing

11.2.3.1 Walls, Partitions, Doors and

Ceilings

11.2.13.1 Cleaning and Sanitation

11.2.10.4 Calibration

11.2.9.2 Premises and Equipment

Maintenance


2.9.1.1 Training Requirements


2.1.6.3 Business Continuity Planning


Action

2.3.3.1 Contract Service Providers

2.2.2.3 Records


Action

2.4.5.1 Incoming Goods and Services

17

Top Non-ConformancesSurveillance Audits


11.2.13 Cleaning and Sanitation

11.7.5.4 Control of Foreign Matter

Contamination

11.2.11.2 Management of Pests

and Vermin


Protective Clothing

11.2.7.1 Dust, Fly and Vermin

Proofing

11.2.3.1 Walls, Partitions, Doors

and Ceilings


Protective Clothing

Common Themes– All Audit Types


• Management Responsibility

• Business Continuity Planning

• Food Safety Plan

• Internal Audits

• Corrective and Preventative

Action

18


• Cleaning and Sanitation

• Control of Foreign Matter

Contamination

• Equipment, Utensils and

Protective Clothing

• Walls, Partitions, Doors and

Ceilings

Management Responsibility and SQF

Certification

Culture

Systems

Technology

• the difference between an effective,

workable food safety management system

and an ineffective system is the level of

management commitment, and how that

influences the attitudes and behaviour

within the business.

• Food safety culture is an integral part of an

effective food safety management system.

The two are not mutually exclusive. One is

not an extension of the other.

• A positive culture is necessary for the

system to work – the system is necessary

to underpin the culture.

• Management must drive the positive

culture

• ……. organisational structure describing those with

responsibility for food safety ……..

• ……. ensure fundamental food safety practices are adopted

and maintained ……

• ……. ensure adequate resources are available ……

• ……. designate an SQF Practitioner ……..

• ……. establish (food safety) training needs …….

• ……. continuous improvement …….

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2.1.2 Management Responsibility

2.1.6.1 A business continuity plan based on the

understanding of known threats to a business shall be

prepared by senior management outlining the methods and

responsibility the organization will implement to cope with a

business crisis that may impact on the ability of the supplier to

deliver safe, quality food.

2.1.6 Business Continuity Planning

2.4.1 Food Legislation

• The organization shall ensure that, at the time of delivery to its customer,

the food supplied shall comply with the legislation that applies to the food

and its production in the country of its origin and destination……

2.4.2 Food Safety Fundamentals

• The supplier shall ensure the food safety fundamentals described in the

relevant subsequent modules of this Code (eg module 11) are applied, or

excluded according to a detailed risk analysis outlining the justification

for exclusion or evidence of the effectiveness of alternative control

measures to ensure that food safety is not compromised.

2.4.3 Food Safety Plan (Level 2)

• A food safety plan shall be developed, effectively implemented, and

maintained and outline the means by which the organization controls and

assures food safety.

2.4.4 Food Quality Plan (Level 3)

• A food quality plan shall be developed, effectively implemented, and

maintained in accordance with the HACCP method.

2.4 Attaining Food Safety

2.5.7 Internal Audits

• Methods and responsibilities for scheduling and conducting

internal audits to verify the effectiveness of the SQF system

including facility and equipment inspections, PRPs, food

safety plans, food quality plans, and regulation controls shall

be documented and implemented

o An internal audit schedule with scope and frequency

o Corrections and corrective actions of deficiencies

o Audit results are communicated to relevant management and staff

o Records of internal audits and corrective actions

• Staff conducting internal audits shall be trained in internal

audit procedures

Benefits of a Strong Internal Audit Program

• Drives continuous

improvement

• Promotes ownership of the

entire SQF system

• Promotes a food safety

culture within your

organization

• Adds credibility to the audit

results

• Improves the audit score!

Challenges to an Internal Audit Program

• Management commitment – if leaders do

not take your results seriously, no one else

will

• Time management- letting issues pull you

away from audit schedule or issuance of

report

• Conflict resolution – you and the plant

manager can never seem to see eye to

eye…

• Bias – who audits you? Who can review the

quality programs?

• Ignoring previous issues for information –

findings should be what is found during the

audit only, not what was observed earlier

5 Keys to Successful Internal Audit Programs

1. Define objectives of the Internal Audit Program

with management to facilitate management

commitment

2. Formalize the audit process

3. Communicate well

4. Manage Internal Audits as its own program

5. Use correction action management program

(2.5.5) to manage and resolve internal audit

findings

�

Tips for Compliance

• How can a facility improve their audit performance?

– Implement effective training programs

– Know the standard and any updates

– Conduct validation activities

– Review facility condition

– Maintain records

– Conduct internal audits

Summary

� Ensure you have knowledge of the SQF Code. Edition 7.1,

and how to implement it.

� Keep it simple. Don’t drown in paperwork.

� Have a strong internal audit program. Take it seriously.

� System implementation and maintenance must be a team

approach.

� Success can be achieved through diligence, awareness

and commitment from all levels of the organization.

SQF Technical Contacts

North America

LeAnn Chuboff

Senior Technical Director

[email protected]

Kristie A. Grzywinski

Technical Manager

[email protected]

Melody Ge

Compliance Specialist

[email protected]

Australia, Asia

Bill McBride

Asia Pacific Representative

[email protected]

General [email protected]

Questions and discussion

Upcoming “SQF Implementation” dates

2013Melbourne - 25 & 26 November

2014Parramatta – 10 & 11 MarchMelbourne – 24 & 25 March

Call 1300 727 444 for further information

Thank you for attending

A recording of this webinar and unanswered questions will be available on the SAI Global ‘MyTutor’ portal

• Visit saiglobal-mytutor.com

• Call 1300 727 444

• Email [email protected]

Tips and Traps for SQF 7.1: Understanding Top 10 Non-conformances

Technology

sqf code module

benchmarked module

suppliers module

certificates module

definitions module

approvedapproved module

sqf certification

processing of pet food