challenging aspects of sqf implementation: a cb’s perspective
DESCRIPTION
by Kimberly CoffinTRANSCRIPT
Challenging Aspects of SQF Implementation: A
CB’s Perspective
Kimberly C Coffin
26 August 2010
What does ‘Challenging’ Mean?
• “To make demands, esp. stimulating demands upon” – The Concise Macquarie Dictionary
• Those aspects of the SQF implementation process that suppliers:
– Find difficult to understand the intent of the standard
– Are unsure how it applies to their operation
– Just plain don’t get- Kimberly C Coffin
How were the “challenging aspects” identified?
• Internal survey for feedback / input – auditors / administrators
• Routine technical review of documents submitted for certification decisions
• Analysis of non conformances raised – period July 2009 to June 2010
Two distinct types of “challenges” identified
• Administrative Challenges
• System development / operational implementation challenges
– Top 10 Non Conformances
– Auditor Survey Feedback
Administrative Challenges
Administrative Challenges
• Registration / re-registration essential for scheduling of audit
• Limited window of use, e.g. annually, need to re-learn functionality / requirements
• Selection of food sector category and associated products from a limited list of approved products
Administrative Challenges
• Relationship between audit grade and frequency– Grading scale/weighting result in most audits
with an “E” rating
– Modified grading system will assist in making this clearer moving forward
– Frequency still determined by the type and number of NCs identified in the certification/re-certification audit.
– Audit grade does not change as a result of the six monthly surveillance audit
System Development / Operational Implementation Challenges
Top Ten Non conformances – July 2009 – June 2010
GMP – Housekeeping/Facility Conditions
Intent of the Standard• Buildings, equipment
and infrastructure maintained to defined sanitary standards – Section 5
GMP – Housekeeping/Facility Conditions
• Challenges for Compliance– Lack of $$
– Demands for production time override time necessary for correction
– Identification / reporting of deficiencies
• Strategies for Improvement– Robust GMP inspection practices
– Food safety/GMP prioritisation by maintenance staff
– Effective corrective action review processes, including senior management
Food Safety/Quality Plans
Intent of the Standard• Documented plan that
outlines how food safety / quality of products will be controlled/assured.
• Based on the results of a hazard analysis
• Controls validated / verified.
Food Safety/Quality Plans
• Challenges for Compliance– Familiarity with process and focus on expected
hazards
– Identification of “quality” hazards and application of risk assessment principles
– Timely identification of changes to product / process and assessment of the impact on controls in place
– Lack of technical expertise required for the establishment of sound validation of controls
Food Safety/Quality Plans
• Strategies for Improvement– Identification of all process inputs
– Detailed hazard analysis that is specific to products and processes
– Consider customer requirements for “quality” attributes as part of the hazard analysis process
– Establish prompts within the system to ensure that changes are evaluated
– Detailed validation studies, including evidence of both theoretical and process capability
Foreign Object Control
Intent of the Standard• Methods used to
prevent foreign matter contamination established
• Includes glass, wood, metal, etc.
• Audit outcomes demonstrate increasing number of deficiencies identified
Foreign Object Control
• Challenges for Compliance– Introduction by staff difficult to control
– Enforcement of policies difficult / time consuming
– Identification / reporting of deficiencies
• Strategies for Improvement– Elimination of clutter / sources of contamination
– Provide adequate / designated areas for storage of tools, change parts, staff’s personal items
– Encourage staff identification through active participation in identification, e.g. bag and tag
Premises / Equipment Maintenance
Intent of the Standard• Methods for
maintenance of plant / equipment planned and completed to minimise risk to product
• Specific area of concern related to: Section 6.6.2 - Instructions to Maintenance Personnel
Premises / Equipment Maintenance
• Challenges for Compliance– Maintenance personnel / departments not commonly
considered part of operations or contracted out– Breakdown maintenance presents urgent need for
intervention– Risks to product inherent in the nature of work
• Strategies for Improvement– Fully integrate maintenance personnel, practices and
areas into controls – Formalise post maintenance handover process with
shared responsibility– Establish defined toolbox controls and actively monitor
compliance
Business Continuity Planning
Intent of the Standard• Assessment of threats
to business and development of a plan that outlines methods to ensure continued delivery of safe / quality product
• Specific area of concern related to annual testing / verification of plan
Business Continuity Planning
• Challenges for Compliance– Lack of understanding regarding application to
business and breadth of requirements
– Source templates from websites and try to adapt
– Availability / cost of formal training
– Belief that mock recall or test of emergency evacuation systems will demonstrate compliance for annual test
Business Continuity Planning
• Strategies for Improvement– Senior management input/development essential– Clear definition of the types of crisis:
• internal – sabotage/fire • external – product tampering threat• acts of nature
– Detailed risk assessment for each crisis type, incl. impact on products, controls, contingencies in place
– Involvement of external resources, incl. legal, insurers, technical experts
Auditor Feedback
• Two additional aspects of the standard highlighted as not clearly understood
– Food Defense– Identity
Preserved Product
Food Defense
• Need often questioned – “it won’t happen here” • Addressed by several existing/current measures,
but not commonly formalised into a single protocol
Strategies for Improvement:– Adequacy of security controls better determined if
viewed holistically– Conduct a risk assessment to proactively identify
improvements to current security measures – Opportunities exist for links to Business Continuity
Plans
Identity Preserved Foods
Question:
When is compliance with Section 4.8.1
required?
Identity Preserved Foods
Answer:• When handling/process controls are required for:
Ingredients containing allergen and sensitising agents
• When any of the following product claims are made:
Organic, Kosher, HALAL, Gluten Free, Product of...
Auditor Feedback
• Requirements of SQF Practitioner not well understood– Employee– HACCP Training– Understanding of SQF code
• Use of a consultant does not preclude the need for a SQF Practitioner
• Although not required for compliance, audit findings demonstrate greater understanding / better audit outcome if formal SQF training completed
Auditor Feedback
• Suppliers focused on meeting the prescriptive requirements of the standard
– Don’t often look beyond what is required for improvements, e.g. customer focus
– Justification for exclusions often lacking in detail / evidence of risk assessment
Path to Successful SQF Implementation
• Competent SQF Practitioner to lead the way...with active involvement of the senior management.
• Take advantage of training offerings and guidance documents...these help with understanding intent.
• Make it real...the system should reflect how and what you do.
• Take the time...to develop, review and verify.• Keep it current...make certain prompts are in place
to continuously improve procedures and methods of working.
Thank you
Kimberly CoffinTechnical Manager
Email: [email protected]: 0403 047 651
Questions??
Therese GendersBusiness Development Manager
Email:[email protected]: 0413 208 954