15 replies to this topic

[SpursGirl]

Hi all




I have just had my recertification audit at one of my plants - it is our first recertification audit as we only gained certification last year. Our certification audit only produced a few minor non conformances but the auditor we had was not particularly thorough and I knew that we had some work to do in order to get our recertification.

The auditor we had this time was far more on the ball and was very thorough which in itself I do not have an issue with however a number of non conformances were raised - both as major and minors - where I thought I had met the code but the auditor was insistant that I had not. Before I raise objections against the non conformances with the auditing body I thought I would seek some clarification from you experienced and seasoned SQF practitioners/auditors out there!


1. We had a major raised against refresher training - whilst I do annual refersher training on all CCP operations, GMP standards and HACCP the auditor stated that all procedures had to be re-trained on an annual basis. This was to include every procedure on site upto and including things like how to cut a cucumber!! I explained that these procedures would be re-trained out to previously trained employees should the procedure change, in the light of internal non conformances, customer complaints and audit findings and that this is all documented in both training policy and procedure. The auditor stated that it was a requirement of the code that all training must be refreshed annually but I cannot find this in the code anywhere (I am talking about the 6th edition here). Can someone help me with this as it would be impossible for us to retrain every procedure in the 14 days required to close off a major non con. (just as a note - the auditor suggested that we do mass training for everyone over the course of 3 days on all procedures and all staff!! Whilst that would close off the non conformance I do not know how effective that would be and how I could demonstrate competence afterwards!)

2. Inbound reciept of goods - a non conformance was raised by the auditor relating to the security of delivery trucks. The statement was made that all trucks must be secured by seals to be deemed acceptable. I explained that several of our suppliers deliver to multiple drop ponits in the local area as part of their delivery route and so there is no seal on these vehicles and it would be inpractical to have one in place. The auditor stated that a padlock must be in place and be locked at time of delivery for the 'security of the materials to be assured' - we have been asked to get our suppliers to adopt this proactice and document the check on padlocks. Again going back to the code the code only states that proper securing of the shipment is in place (we ensure the doors are closed (LOL) and that the load isnt flying all over the place) and that where used seal numbers are recorded (we do this where seals are used). Where does it state that the load must be LOCKED??

We did pick up a number of other non conformances which I believe were not part of the code but I can get something in place to address justified but I am struggling to get actions in place for the above two particularly as I do not see where the code actually asks for these things.



All help gratefully recieved!


Thank you

Sarah

[esquef]

Hi Sarah,

I completely agree with you that the recert auditor was somewhat, um.... overzealous in issuing a major NC for the training issue. From what I can see thare's no hardfast 12 month re-training mandate. I think that it's a good idea to re-train all employees on subjects that involve food safety on an annual basis, but I see no wording in the code or V6 guidance. To score this a major is a bit crazy I think. I'd contend it if I was in your shoes.

On the 2nd NC (I'm assuming a minor) re. the lock policy with LTL truckloads: there's nothing specific about that in the pre-req for Transport and Delivery (6.11), but in element 4.7 (Site Security) if you look at 4.7.1.2 it does state that "A food defense protocall should be prepared and include; v. The measures implemented to ensure finished product is held under secure storage and transportation conditions." I quess that requirement is somewhat open to interpretation, but in Food Defense courses I've taken it's generally recognized that full trailers need seals and LTL's need padlocks (under supervision of the company's Shipping and Receiving personnel). So IMHO that might be a ligitimite minor NC.

Good luck and keep us informed.

Regards,
esquef

[SpursGirl]

Hi Esquef



Thank you for the support!



I am certainly going to challenge the annual refresher training requirement but will look at enforcing the padlock on delivery vehicles.


Whilst on the subject of training............. the auditor also asked for supervisor sign off for all training activities - i agree that this is actually stated this way in the code - however I did question whether a person other than the supervisor could sign off this part - ie could it be another manager or did it need to be the direct supervisor?? I asked this as I do some of the training verification (especially of CCP activities) by auditing and asking questions of the emplyees rather than the direct supervisor. I was given a absolute no on this - it has to be the direct supervisor. The auditor also said that all training had to assess competence by a written 'test' and that verbal answers by way of auditing or interview was not acceptable, neither was direct observation - currently our sign of is by auditing, interview or observation with the excpetion of general HACCP & GMP training. How I can write a test on the procedure for cutting a cucumber I do not know! All of these things were part of the major non con I recieved on training. Did I miss read the requirements of the code or was the auditor taking things too far?


By the way Esquef - good forum name!! At least I got that one quite quickly - it was actually only a few weeks ago that I realised Will I Am was actually William - DOH



Kind regards,



Sarah

[SQFconsultant]

Hi all




I have just had my recertification audit at one of my plants - it is our first recertification audit as we only gained certification last year. Our certification audit only produced a few minor non conformances but the auditor we had was not particularly thorough and I knew that we had some work to do in order to get our recertification.

The auditor we had this time was far more on the ball and was very thorough which in itself I do not have an issue with however a number of non conformances were raised - both as major and minors - where I thought I had met the code but the auditor was insistant that I had not. Before I raise objections against the non conformances with the auditing body I thought I would seek some clarification from you experienced and seasoned SQF practitioners/auditors out there!


1. We had a major raised against refresher training - whilst I do annual refersher training on all CCP operations, GMP standards and HACCP the auditor stated that all procedures had to be re-trained on an annual basis. This was to include every procedure on site upto and including things like how to cut a cucumber!! I explained that these procedures would be re-trained out to previously trained employees should the procedure change, in the light of internal non conformances, customer complaints and audit findings and that this is all documented in both training policy and procedure. The auditor stated that it was a requirement of the code that all training must be refreshed annually but I cannot find this in the code anywhere (I am talking about the 6th edition here). Can someone help me with this as it would be impossible for us to retrain every procedure in the 14 days required to close off a major non con. (just as a note - the auditor suggested that we do mass training for everyone over the course of 3 days on all procedures and all staff!! Whilst that would close off the non conformance I do not know how effective that would be and how I could demonstrate competence afterwards!)

2. Inbound reciept of goods - a non conformance was raised by the auditor relating to the security of delivery trucks. The statement was made that all trucks must be secured by seals to be deemed acceptable. I explained that several of our suppliers deliver to multiple drop ponits in the local area as part of their delivery route and so there is no seal on these vehicles and it would be inpractical to have one in place. The auditor stated that a padlock must be in place and be locked at time of delivery for the 'security of the materials to be assured' - we have been asked to get our suppliers to adopt this proactice and document the check on padlocks. Again going back to the code the code only states that proper securing of the shipment is in place (we ensure the doors are closed (LOL) and that the load isnt flying all over the place) and that where used seal numbers are recorded (we do this where seals are used). Where does it state that the load must be LOCKED??

We did pick up a number of other non conformances which I believe were not part of the code but I can get something in place to address justified but I am struggling to get actions in place for the above two particularly as I do not see where the code actually asks for these things.



All help gratefully recieved!


Thank you

Sarah

For #1 - look at the refresher training requirement in V6, if you don't agree with the MAJOR on this regardless of what the Auditor suggested you should immediately file a challenge.

For #2 - Same thing.

And, a general statement.... Auditors are NOT allowed to make recommendations/suggestions - they are at your facility to conduct an audit plain and simple, it is a direct violation of the SQF Code of Practice for Auditors to make suggestions/demands/recommendations.

If what you have stated is correct you need to review the SQF codes that are applicable, file challenges as needed, and file a complaint against the Auditor with the CB and SQFI for violation of the SQF Code of Practice for Auditors.

It will make the whole system better if you do.



Glenn

[gcse-fhp]

You see what we are being made to do to one another under the current policies and approaches to food safety and quality assessment? This is not good. It is not through raising complaints about auditors that the system will be made better. A complete paradigm shift is needed.

The whole process should be friendly with a steady and knowledgeable focus on real facts, real risks, real observations, real solutions, etc. Instead, the current model for auditing makes it possible for us to have auditors who appear to be overzealous and insisting on: “the rule book says”. We have stuffy auditing codes or policies that make auditing into an exasperating process. Current approaches foster an atmosphere where auditors and audited parties are suspicious of each other instead of collaborating. Fallow grounds are created that allow for arguments and counter-arguments with questions like "where does the standard say that?"

Meanwhile, the focus is shifted from the real task of ensuring consumer safety to vain argumentations about raised non-conformances and the often incorrect interpretations of the standards which are also inherently incomplete.

While it may seem to be a good solution to simply raise complaints against auditors, such quarrelsome notions are not the solution.

Even the standards against which audits are conducted are engaged in unhealthy competition that is leading to all kinds of ethical dilemmas and shadiness. This is not good.

While I agree that something needs to be done to resolve the immediate issues described above by SpursGirl, the real solution to all of these kinds of encounters must go far beyond.

It is time for another approach to food safety assurance and assessment.

Edited by gcse-fhp, 28 May 2012 - 11:25 AM.

[Tony-C]

And, a general statement.... Auditors are NOT allowed to make recommendations/suggestions - they are at your facility to conduct an audit plain and simple, it is a direct violation of the SQF Code of Practice for Auditors to make suggestions/demands/recommendations.

Glenn

Opportunity for Improvement (OIP)
An observation made by the auditor during a site audit that identifies an issue that is not a Non-conformance but recognizes that the practices conducted by the supplier are not industry best practice. It does not require a corrective action response by the supplier, but provides the supplier with an opportunity to improve their SQF System.

Regards,

Tony

[Tony-C]

Hi all




1. We had a major raised against refresher training

2. Inbound reciept of goods - a non conformance was raised by the auditor relating to the security of delivery trucks.

All help gratefully recieved!

Thank you

Sarah

Hi Sarah,

Largely agree with Esquef's posts.

1. Appeal against the major:
'6.3.6.1 The training program shall include provision for identifying and implementing the refresher training needs of the organization.'
I would suggest that the corrective action is to come up with a refresher training plan and make a start.

2. There is an emphasis on security of deliveries and so a padlock would seem like a quick, simple and adequate corrective action.

Regards,

Tony

[SpursGirl]

Dear all

Thank you all so much for the input and the sage words.

I may have some 'muddy' clarification (LOL) on the refresher training issue..................The actual SQF code does not mention a time frame for refresher training only that "The training program shall include provision for identifying and implementing the refresher training needs of the organization". I met this with my training policy which states that refresher training will be conducted on an annual basis for CCP procedures, GMP, HACCP and a couple of other things whilst refresher training would only be performed for other procedures should the procedure change, as a result of customer complaints, internal or external audits, observation and internal product rejections. This I believed met the code. On looking at the guidance notes for the code there is a statement that reads "Annual refresher training shall be conducted for Retained Employees". This is the statement I am assuming the auditor was refereing to but it is not actually stated in the code as a requirement. From this statement the rquirement is clear - annaul refresher training is required on all activities. I do not know how I will stand with challenging the non-conformance in the light of this.

The issue with the locked delivery vehicles I do understand that the food defence requires this and I can easily put this in place as a requirement and check - but I am wondering what to do where a delivery truck arrives without the padlock in place - something I am absolutely sure will happen. If I risk assess the safety of the 'unsecured' load how will I demonstrate that it is indeed safe? If the driver says that he did not lock the trailer and he had left the load unlocked whilst he went to complete paperwork at a delivery site how can I prove the load has not been comprimised?? After all how could I show that the material has not been doused with salmonella or arsenic (a bit dramatic I know but you get my drift). Most of my material is fresh veg and short shelf so positive release would not be an option. Do I have to reject the load? This would be really difficult in terms of our operation - we would end up with no maeterial and thus unable to produce finished product!

Very frustrating!


Kind regards,

Sarah

[Tony-C]

Dear all

Thank you all so much for the input and the sage words.

The issue with the locked delivery vehicles I do understand that the food defence requires this and I can easily put this in place as a requirement and check - but I am wondering what to do where a delivery truck arrives without the padlock in place - something I am absolutely sure will happen. If I risk assess the safety of the 'unsecured' load how will I demonstrate that it is indeed safe? If the driver says that he did not lock the trailer and he had left the load unlocked whilst he went to complete paperwork at a delivery site how can I prove the load has not been comprimised?? After all how could I show that the material has not been doused with salmonella or arsenic (a bit dramatic I know but you get my drift). Most of my material is fresh veg and short shelf so positive release would not be an option. Do I have to reject the load? This would be really difficult in terms of our operation - we would end up with no maeterial and thus unable to produce finished product!

Very frustrating!

Kind regards,

Sarah

Hi Sarah

Document your policy, communicate with suppliers, explain your expectations and the likely consequence of them failing to comply. Then deal with non-compliances as exceptions, warn suppliers who are non-compliant. In each case inspect and assess risk. I assume that you wash the fresh veg. & does it come in a form where tampering may be evident such as sealed bags?

If you are determined to implement I am sure you will see it through.

Kind regards,

Tony

Edited by Tony-C, 28 May 2012 - 04:03 PM.

[esquef]

Hi Sarah

Document your policy, communicate with suppliers, explain your expectations and the likely consequence of them failing to comply. Then deal with non-compliances as exceptions, warn suppliers who are non-compliant. In each case inspect and assess risk. I assume that you wash the fresh veg. & does it come in a form where tampering may be evident such as sealed bags?

If you are determined to implement I am sure you will see it through.

Kind regards,

Tony

Great reply. Also, as part of your Supplier Approval program (yes, carriers are included in this) you can "suggest" to carriers who pull up to your docks without padlocks on partial loads (or seals on full loads for that matter) that you've noted the policy violation in your system, and that decertification will occur upon further violations. Hopefully they'll get the message.

[retep]

I ran into the same problem when I spoke to my auditor about our practice of receiving. I was told that our practice was incorrect because I was having drivers check reefer unit temps on the trailers after the doors had been opened. So now my personnel must go all the way out to the yard and check them before they come into the dock area which lengthens the receiving time already. No where int he code did I ever see anything about checking trailer temps before the doors are opened. But he was very very insistent upon making this a ne wprocedure. Can anyone share their experiences with this sort of thing ?

[Tony-C]

I ran into the same problem when I spoke to my auditor about our practice of receiving. I was told that our practice was incorrect because I was having drivers check reefer unit temps on the trailers after the doors had been opened. So now my personnel must go all the way out to the yard and check them before they come into the dock area which lengthens the receiving time already. No where int he code did I ever see anything about checking trailer temps before the doors are opened. But he was very very insistent upon making this a ne wprocedure. Can anyone share their experiences with this sort of thing ?

Hi Retep,

Have a look at these sections:

Edition 6 - 6.11.4 Unloading
6.11.4.1 Prior to opening the doors the refrigeration unit’s storage temperature settings and operating temperature shall be checked and recorded

Edition 7 - 11.6.9 Unloading
11.6.9.1 Prior to opening the doors, the refrigeration unit’s storage temperature settings and operating temperature shall be checked and recorded.

Regards,

Tony

[MM1]

Hi Sarah,

1.Refresher Training CAR: The code does not specify the frequency of refresher training unless the training procedure you have developed states that annual training will be provided for all activities. You need to develop training matrix identifying which activity will need to be retrained and how often.

2. Inbound reciept of goods: As per the STD The supplier must demonstrate to SQF auditor how their specific controls address the intent of the SQF program requirements. If the incoming trauck are not pad locked it is upto the company to prove that the product/packaging is not compromised by the way of inspection. I had similar issue with delivery of certain goods. It is not easy with fresh produce, in such cases you use the approved supplier check for the goods.

MM

[SriramB]

Dear all

Thank you all so much for the input and the sage words.

..................The actual SQF code does not mention a time frame for refresher training only that "The training program shall include provision for identifying and implementing the refresher training needs of the organization". I met this with my training policy
This I believed met the code. On looking at the guidance notes for the code there is a statement that reads "Annual refresher training shall be conducted for Retained Employees". This is the statement I am assuming the auditor was refereing to but it is not actually stated in the code as a requirement.

I do not know how I will stand with challenging the non-conformance in the light of this.

The issue with the locked delivery vehicles I do understand I can easily put this in place as a requirement and check - but I am wondering what to do where a delivery truck arrives without the padlock in place


Very frustrating!


Kind regards,

Sarah

Hi Sarah,

Thank you for putting your doubts about the 'validity' and "value addition' aspects of your auditor's observations in a fair and objective manner.

Indeed, the reasons to challenge the same, is that they do not make any logical sense in preserving the quality or safety of your product.

Just wondering; if your research of the guidance notes , indicating 'annual refresher training to retained staff (irrespective of whether it is actually required)'; ---- rather than exonerate the audit finding, actually casts doubts on the reasonability of the standard....

[Katja]

Dear all

Thank you all so much for the input and the sage words.

I may have some 'muddy' clarification (LOL) on the refresher training issue..................The actual SQF code does not mention a time frame for refresher training only that "The training program shall include provision for identifying and implementing the refresher training needs of the organization". I met this with my training policy which states that refresher training will be conducted on an annual basis for CCP procedures, GMP, HACCP and a couple of other things whilst refresher training would only be performed for other procedures should the procedure change, as a result of customer complaints, internal or external audits, observation and internal product rejections. This I believed met the code. On looking at the guidance notes for the code there is a statement that reads "Annual refresher training shall be conducted for Retained Employees". This is the statement I am assuming the auditor was refereing to but it is not actually stated in the code as a requirement. From this statement the rquirement is clear - annaul refresher training is required on all activities. I do not know how I will stand with challenging the non-conformance in the light of this.

The issue with the locked delivery vehicles I do understand that the food defence requires this and I can easily put this in place as a requirement and check - but I am wondering what to do where a delivery truck arrives without the padlock in place - something I am absolutely sure will happen. If I risk assess the safety of the 'unsecured' load how will I demonstrate that it is indeed safe? If the driver says that he did not lock the trailer and he had left the load unlocked whilst he went to complete paperwork at a delivery site how can I prove the load has not been comprimised?? After all how could I show that the material has not been doused with salmonella or arsenic (a bit dramatic I know but you get my drift). Most of my material is fresh veg and short shelf so positive release would not be an option. Do I have to reject the load? This would be really difficult in terms of our operation - we would end up with no maeterial and thus unable to produce finished product!

Very frustrating!


Kind regards,

Sarah

I agree with your interpretation of the first major on training. Even before SQF with our GMP certification we had to enforce this annually, testing is up to you, you could simply have the supervisors verify that the training was well implemented by watching employees on the job cutting cucumbers, if they are doing it according to procedure, they can sign as a verification.

For the LTL load i understand that it is left a little to interpretation and it concerns me. Although the pad lock may seem simple actual implementation and control seem daunting. We inspect and sample every product coming in the door, most of our shipments are LTL and we know that our shippers would not respect it. As well many shipments are FOB our dock which means it is the vendor's responsibility to ensure their shipper uses a lock not ours. We can request all we want but we cannot force them to do it, we are not a big fish in the pond so to speak. During our initial certification audit, we relied on our LTL policy which says we do thorough inspections of shipments but I don't know if this will hold next year with a new auditor.

[QATim]

I am not sure if someone has mentioned it yet but you do have the option to challenge his findings. There is a formal process to do so that you can find on the SQF website.