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What is the purpose having a specified "SQF Practitioner"?


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#1 bacon

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Posted 12 October 2012 - 04:21 PM

What is the purpose having a specified "SQF Practitioner"?
________________________________________________________________________________________________________
2.1.2.4 The senior management shall designate an SQF practitioner for each site with responsibility and authority to:
i. Oversee the development, implementation, review and maintenance of the SQF System, including food safety fundamentals outlined in 2.4.2, and the food safety plan outlined in 2.4.3.
ii. Take appropriate action to ensure the integrity of the SQF System; and
iii. Communicate to relevant personnel all information essential to ensure the effective implementation and maintenance of the SQF System.

2.1.2.5 The SQF practitioner shall:
i. Be employed by the supplier as a company employee on a full-time basis;
ii. Hold a position of responsibility in relation to the management of the supplier’s SQF System;
iii. Have completed a HACCP training course;
iv. Be competent to implement and maintain HACCP based food safety plans; and
v. Have an understanding of the SQF Code level 2 and the requirements to implement and maintain SQF System relevant to the supplier scope of certification.

2.1.4.4 The SQF practitioner shall be responsible for validating changes to food safety fundamentals and food safety plans that have an impact on the supplier’s ability to deliver safe food.

2.5.1.1 Validation and verification activities shall be the responsibility of the SQF practitioner.

2.5.1.2 The frequency and methods used to validate and verify food safety fundamentals, critical limits, and other food safety controls identified in food safety plans shall be documented and implemented and meet their intended purpose.

________________________________________________________________________________________________________

I find this it is creating some confusion with new adopters of GFSI benchmarked audit standards.

So one can hire a "SQF Practitioner" that did not design a food safety system but merely orchestrates the SQF documentation requirements. If taken this way, it can create an tremendous amount of bureaucracy and redundancy.

Observation: I am seeing in the market (on the Nth American side), many, many positions for SQF Practitioner/HACCP Coordinator/Food Safety Document Specialists… all dealing with GFSI benchmark audits. As I see it, the big retailers are now suspending further business with suppliers who are not GFSI audited. Now that the American food packing/processing industry is under the gun, they are scambling. In that scramble, they just can’t pile more responsibility onto the QA Managers… so they hire a HACCP certified for SQF Practitioner/HACCP Coordinator/Food Safety Document Specialists…

The troubling thing with this is a 1st time facility bending to GFSI compliant don’t generally know quite how to deal with all of the document formation/retention/control and presentation (I am living it 1st hand). Thus they seem to end up creating a separate position that “makes paper safe”.


So, just think of SQF clause 2.5.1.1 & 2.5.1.2 requirements (given their guidance document) and the QA Manager is not SQF Certified… but they do have a separate “SQF Practitioner” just doing allot of redundant paperwork (I am trying to change this and simplify their SQF review method).

Has anybody else come across this?




Being a BRC guy, I just have not seen this phenomena. No "requirements", the QA Manager who designed the Food Safety System is the person responsible for adhering to the requirements of the BRC code. Simple, things are verified and validated (attesting to the integrity of a food safety systems) by qualified personnel and life goes on.

Cheers,

-B


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#2 Simon

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Posted 13 October 2012 - 02:31 PM

Hi Baron, in a lot of management systems esp. pharmaceutical there's a requirement for an independent (from production) quality unit/department and a qualified person responsible for managing the system and making the calls. In BRC their must be a HACCP Team leader and they must be suitably trained/competent(not sure of the wording in the standard). I think SQF are saying there should be a person who is competent and who has the responsibility and authority to do what’s needed and make calls. In larger organizations they may have a quality manager and a food safety manager (practitioner), but in smaller ones it’s usually a dual role…and personally I’d much prefer to see that.

I'm sure the SQF practitioner can still be named Quality Manager or whatever as long as he/she carries out those duties and is suitably qualified/competent.

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Simon


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#3 Tony-C

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Posted 14 October 2012 - 03:43 PM

I'm sure the SQF practitioner can still be named Quality Manager or whatever as long as he/she carries out those duties and is suitably qualified/competent.

Regards,

Simon


Key for me is:
2.1.2.4 The senior management shall designate an SQF practitioner for each site with responsibility and authority to:
i. Oversee the development, implementation, review and maintenance of the SQF System, including food safety fundamentals outlined in 2.4.2, and the food safety plan outlined in 2.4.3.


This person clearly needs to be knowledgeable and well trained. A lot of companies have a structure where there is a Senior Technical person (let's say Technical Manager) who would be the SQF Practitioner and a QA Manager who would carry out more routine work and assists/manages the paperwork.

Thus they seem to end up creating a separate position that “makes paper safe”.

I assume that you mean this person is the SQF Practitioner. This is the wrong way round and a recipe for disaster.

Regards,

Tony
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#4 bacon

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Posted 15 October 2012 - 12:39 PM

I assume that you mean this person is the SQF Practitioner. This is the wrong way round and a recipe for disaster.

Regards,

Tony


Oh, I know. A dreadfully wrong way, excessively bureaucratic.
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#5 Mr. Incognito

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Posted 31 January 2013 - 12:26 PM

"SQF Practitioner" is not a job title so much as a position.

A Quality Manager can be an SQF Practitioner just as much as my position "Quality Coordinator". A person per plant has to be designated as the SQF Practitioner and is basically overall responsible for the implementation and maintenance of the system.

The code spells out the requirements of the position. It's really just internal to SQF not an actual company job title.

Now sometimes the Quality Manager doesn't want the burden of taking care of the whole system so they have someone else do it. My manager and I are sharing the load about 60/40 right now with me at the 40% end of it. Right now I'm writing document control because I am in fact the document control person in my plant. But she outlined certain sections she wants me to accomplish.


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#6 john123

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Posted 01 February 2013 - 07:29 PM

SQF had no problem with us designating our Plant Manager as the SQF Practitioner, as he was the only one with current, formal HACCP training. As Quality Supervisor I work directly with him to keep the SQF issues updated. I've got HACCP training coming up in two weeks, where I'll be able to step up to more of a Practitioner roll myself.


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#7 Mr. Incognito

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Posted 05 February 2013 - 05:25 PM

SQF had no problem with us designating our Plant Manager as the SQF Practitioner, as he was the only one with current, formal HACCP training. As Quality Supervisor I work directly with him to keep the SQF issues updated. I've got HACCP training coming up in two weeks, where I'll be able to step up to more of a Practitioner roll myself.


The SQF Practitioner not only needs HACCP training certification but also the SQF practitioner course.
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#8 esquef

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Posted 05 February 2013 - 06:14 PM

The SQF Practitioner not only needs HACCP training certification but also the SQF practitioner course.


That requirement was dropped over a year ago I beleive. Here's what is on the SQFI website re. SQF Practitioner requirements:






Q. What are the requirements to be an SQF practitioner? Do I have to register as a practitioner?

A. The education and knowledge requirements of an SQF practitioner are outlined in SQF Code, 7th edition in element 2.1.2.5. They are as follows:

The SQF practitioner shall:

  • Be employed by the supplier as a company employee on a full-time basis;
  • Hold a position of responsibility in relation to the management of the supplier’s SQF System;
  • Have completed a HACCP training course;
  • Be competent to implement and maintain HACCP based food safety plans; and
  • Have an understanding of the SQF Code their level of certification and the requirements to implement and maintain SQF System relevant to the supplier scope of certification.
As you can see, there is no specific requirement for training. The practitioner must demonstrate knowledge of the current version of the SQF Code. Some choose to do this by either successfully completing an Implementing SQF Systems training course, or by successfully completing an Implementing SQF Systems examination. Additionally, the practitioner may adequately demonstrate knowledge of the Code by having an effectively-implemented SQF System or appropriately address questions posed by the auditor at the time of the certification audit.

Note that there is no requirement to register or “certify” as a practitioner. As mentioned above, a person in the role of a practitioner must meet the requirements found in 2.1.2.4 and 2.1.2.5 of the SQF Code. Therefore there is no need to “reregister,” “recertify” or retake either the Implementing SQF Systems course or the Implementing SQF System examination once taken. However again, keep in mind that the SQF practitioner will need to demonstrate knowledge of the most current version of the Code during the certification audit.



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#9 George @ Safefood 360°

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Posted 05 February 2013 - 06:16 PM

I like this subject regarding the SQF. It is one of those quirky aspects of the SQF that sets it apart from other GFSI standards. I have often considered what the nature and impact of the 'SQF Practitioner' is on the management of a food safety system. It is an interesting subject.

In the BRC for example the food safety plan centres on the HACCP Team which has a Team Leader. This is where the development, maintenance and validation activities take place. We are familiar with the concept of a 'Management Representative' from the ISO stable. We also know that regardless of the requirement or name used there is always one person in a food plant who takes on or is given the main responibility for the food safety system.

SQF have the Practitioner. This is a special person who on the basis of training is designated as the person to look after the system and in many ways acts as a local SQF representative or custodian of the certification. They are the SQF's man/woman inside the company... I personnaly like the idea of the SQF practitioner. It makes perfect sense. A person who is trained in the finer detail of the standard and its requirements and a competent person who the SQF can conduct their business though - the owner of the standard.

I think the spirit of the requirements are valid. A qualified representative in the certified company who acts in the interests of the standard, its implementation, maintenance and validation. I do not believe it is intended to corner off the paper aspects of the standard to the Practitioner and food companies should resist such a move in their own interests. But I take the point that in larger organizations this can be a tendency given internal organizational structures.

Another potential negative side to the practitioner is how Senior Management fit into the concept. For example in larger food businesses the most senior technical guy will not normally conduct validation of the food safety plan. This will be a duty conducted by the local site technical manager or a member of his/her team. But SQF say that the practitioner must conduct this. This has the (perhaps unwitting) result of pushing down the practical responsibility and authority for the SQF from Senior Management which for me is a strange scenario.

I think the SQF requirement for a practitioner has another interesting impact. It creates a Market! Unlike BRC and other GFSI standards, this key role can be taken by anyone who is competent and trained in the principles of HACCP. SQF has the additional requirement for specific knowledge of the SQF standard and the creation of an entity called the Practitioner. As more and more companies move towards certification as a requirement to do business, this creates an added value to the person known as a Practitioner. Nothing wrong with this but it may well have an impact. Similarly the SQF stands out as having qualified SQF Consultants. Again, this seems like a logical and very sensible approach to create barriers for entry to any cowboys thinking of getting into the food safety consultancy business.

SQF - always provides food for thought


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#10 john123

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Posted 05 February 2013 - 08:35 PM

The SQF Practitioner not only needs HACCP training certification but also the SQF practitioner course.


Yes, worthy clarification there and something I ommitted from my post. We have 3 people (myself included) who took the SQF exam to prove knowledge of the SQF system (as listed there in 2.1.2.5), but only our Plant Manager had the required HACCP training documentation to be eligible as the Practitioner.
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#11 bacon

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Posted 12 February 2013 - 03:18 AM

Another potential negative side to the practitioner is how Senior Management fit into the concept. For example in larger food businesses the most senior technical guy will not normally conduct validation of the food safety plan. This will be a duty conducted by the local site technical manager or a member of his/her team. But SQF say that the practitioner must conduct this. This has the (perhaps unwitting) result of pushing down the practical responsibility and authority for the SQF from Senior Management which for me is a strange scenario.


This is exactly what I encountered and I found it to be very strange as well. And if deployed in this manner, it will not be sustainable and, IMO, make things worse by creating a greater divide between food safety/quality and the resource requirements necessary to sustain the food safety/quality system.

And to John123's comment: I had them add 2 additional SQF practitioners (to a total of 4 with myself) with HACCP training. For one, it made more sense as the QA Manager was the site technical manager that validates. I, hired on as The "SQF Practitioner", changed my title to "SQF Management Coordinator" (effectively eliminating the position).

I think the SQF requirement for a practitioner has another interesting impact. It creates a Market! ...... Similarly the SQF stands out as having qualified SQF Consultants. Again, this seems like a logical and very sensible approach to create barriers for entry to any cowboys thinking of getting into the food safety consultancy business.


It has. I have seen it grow and been recently very much apart of it. Not a cowboy, but ones CV and references can speak to that; any food packer that is not looking/verifying deserves what they get.
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#12 Mr. Incognito

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Posted 21 February 2013 - 06:30 PM

I'm sure you can try to convince them you know the code well enough to be the practitioner without the class but having it cements it in fact that you have taken the SQF course and passed the SQF exam. I wouldn't leave that interpretation to chance. But to each their own. That is how we decided to show competence in the code. Direct requirement? I'm not an auditor so I don't know. Will an auditor think you don't because you don't have the certificate? I don't know.


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#13 TheDude

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Posted 03 October 2013 - 05:51 PM

I'm sure you can try to convince them you know the code well enough to be the practitioner without the class but having it cements it in fact that you have taken the SQF course and passed the SQF exam. I wouldn't leave that interpretation to chance. But to each their own. That is how we decided to show competence in the code. Direct requirement? I'm not an auditor so I don't know. Will an auditor think you don't because you don't have the certificate? I don't know.

 

I did not take the SQF course or exam. The auditor said he was a little worried for me at first but as the audit commenced, he realized I knew the code and was fine with it. Everything you need can be found in the code, guidance and this forum.


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#14 Charles.C

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Posted 03 October 2013 - 06:13 PM

I did not take the SQF course or exam. The auditor said he was a little worried for me at first but as the audit commenced, he realized I knew the code and was fine with it. Everything you need can be found in the code, guidance and this forum.

 

Dear leesqf,

 

Is this the same auditor as referred in yr parallel post ?

 

http://www.ifsqn.com...ion/#entry64996

 

Rgds / Charles.C


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#15 TheDude

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Posted 03 October 2013 - 06:15 PM

Dear leesqf,

 

Is this the same auditor as referred in yr parallel post ?

 

http://www.ifsqn.com...ion/#entry64996

 

Rgds / Charles.C

 

Yes it is.


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#16 Mr. Incognito

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Posted 04 October 2013 - 04:33 PM

It is a good course to take it gives out a lot of information and inside knowledge on how to get things done.


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#17 Charles.C

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Posted 04 October 2013 - 09:38 PM

Dear All,

 

Interesting thread. :thumbup:

 

As a non-user of SQF,  I  echo some of the earlier doubts over the benefit of this unique creation.

 

I include a little more code detail (7.1) additional to previous -

 

 

1.5   Designate an SQF Practitioner

Whether or not an SQF consultant is used, the SQF Code requires that every supplier have a suitably qualified SQF practitioner on site to validate and verify the food safety fundamental requirements, food safety plans (at level 2) and food quality plans (at level 3).  The requirements for an SQF practitioner are described in 2.1.2.4 and 2.1.2.5 of the SQF Code.  Some sites may choose to have more than one SQF practitioner to meet shift and operational requirements

 

2.5.1     Responsibility, Frequency and Methods

2.5.1.1   Validation and verification activities shall be the responsibility of the SQF practitioner.

2.5.1.2  The   frequency   and   methods   used   to validate  and  verify  critical  limits  established  for

those hazards associated with the source, storage and  use  of production  inputs,  and  the  application

of  pre-requisite  programs  shall  be  documented and implemented.

2.5.1.3  Records of all verification activities shall be maintained.

 

 

Some Comments

 

To a non-user of SQF like myself, and assuming a Consultant is not employed, I suggest that, for a medium sized outfit, the above /  previous extracts appear IMEX as auto-included by Top Management within the requirements “generously” donated  to most QA Managers (QAM) after their Company opts to implement a FSMS system. If so,  the title / position of "Practitioner" is operationally redundant IMO. Of course, perhaps SQF wish to (nobly) ensure that the designated QAM has an appropriate job description for their purposes ex Top Management. :thumbup:  I suppose financial motivations might also have some relevance. :whistle:

 

On the other hand, use of a Consultant does suggest that some kind of backup / Check and Balance type mechanism might be available which could perhaps be beneficial to a QAM who would probably still end up responsible for the operational implemention of the FSMS system on a day-to-day basis.

 

The above extracts illustrate the importance attached to Validation and Verification as far as SQF /  Practitioner are concerned. As well documented in this forum these 2 functions have generated a remarkable amount  of headaches, particularly as interpreted by SQF auditors. Similar confusion also seems to exists for designated Practitioners. To an external observer the responsibility for resolving this mess appears to be wholly located within the  SQF team responsible for the interpretation of the Code.

 

I sincerely hope that QA-Practitioner people  taking the SQF Practitioner course are less likely to encounter, for example,  leesqf’s  validation difficulties (see my  xlink in #14).  If so, QA managers would seem well-advised to take the opportunity if available. If experiences of the course indicate otherwise, I suppose the decision is a (very) free choice. :smile:

 

Rgds / Charles.C


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#18 TheDude

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Posted 07 October 2013 - 12:06 PM

 

I sincerely hope that QA-Practitioner people  taking the SQF Practitioner course are less likely to encounter, for example,  leesqf’s  validation difficulties (see my  xlink in #14).  If so, QA managers would seem well-advised to take the opportunity if available. If experiences of the course indicate otherwise, I suppose the decision is a (very) free choice. :smile:

 

 

The auditor stated that we did better than most including those who have taken the course. We received a 97%. 3 minors- candy wrappers found next to a garbage can/cigarette butt by a warehouse door and a shatter-proof guard had a 1 inch crack. From what I gather from comments on this forum, the auditor will always find something wrong otherwise it may look like they are not doing their job. There is also the issue of different interpretations of the code which I believe is the case with the "difficulty" you mentioned above.

 

It isn't a bad idea to take the course or even only the online test just to have that piece of paper. I was just confident in my understanding of the code and also wanted to save time/money by opting out.

 

I am curious from other users, do you feel you gained any knowledge from the course that you could not have learned from the guidance or this forum? Also, how long was the course you took. I believe the closest courses offered in my area were 3 days long and 4 hours away (add cost of travel/hotel/food/other expenses).


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#19 Mr. Incognito

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Posted 07 October 2013 - 05:09 PM

Charles,

 

The reason we were told at the class to have a SQF Practitioner is that there is someone that is onsite that is the main person working the SQF system.  It is not to say that person can't have another job like Quality Manager, Quality Coordinator, Director of Operations, etc.. It's more of a figurehead for the system.  It should be the go-to person when it comes to SQF.


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#20 Charles.C

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Posted 07 October 2013 - 06:23 PM

Dear Merle,

 

IMEX of haccp-based, FS systems, there is invariably one person, typically the QAM, who is designated to be operationally “responsible” for the design and implementation of the FSMS system. This is regardless of any certification to private standards and has certain minimum requirements such as possessing HACCP training credentials. So now this Company-appointed person can have another, SQF created, title for free. I’m surprised SQF don’t also stipulate attendance / passing of their “Practitioner” course. Sort of bonus for “supporting” SQF I suppose. Fair enough. And hopefully a Company stipend also.

 

@LeeSQF -

 

I am curious from other users, do you feel you gained any knowledge from the course that you could not have learned from the guidance or this forum?

 

I presume you mean the Practitioner course. Good Question. Would be equally interesting to know if any difference to a "standard" SQF training course.

 

Rgds / Charles.C


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#21 Mr. Incognito

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Posted 10 October 2013 - 06:49 PM

Charles:

 

You can say that typically a Quality Manager is the one in charge of all of quality however in some plants the Quality Manager wears many hats and is involved in many things.  In such a case they can designate someone else to the the SQF practitioner (like me the Quality Coordinator) and that frees them up for things like working on labeling, reviewing the quality implication of upcoming projects, doing other Quality Manager things while the SQF Practitioner is doing their job working on the system.

 

Also it is to ensure that each PLANT has their own practitioner and not one for every plant of a corporation IE 1 person being the designated person for 10 plants and not knowing what is really happening quality wise in all of them because he's 1 person and too busy.

 

@Lee/Charles

 

I haven't been to a standard SQF training course I'm not sure what you mean by that but the SQF Practitioner course was taught by people who know the system very well and had hands on experience as auditors or part of a CB in a previous role so they had insight that perhaps those types of people may not be able to do in their current role.  For example our auditor can't "consult" for us, so as to say he can't tell us what to do just if we are doing it right or not.  So I don't know if auditors are allowed to be on forums like this to answer questions.

 

I don't know if I can say I learned things there that I couldn't have found out here but what I do know is what I learned there allowed me to get a very good passing score on the test.  Like I said before if it's not an outright requirement it's highly suggested.  If your implementing SQF chances are the price to take the class shouldn't break the bank and it does show commitment from the company to send someone to the course.

 

What do you really have to lose?


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#22 Charles.C

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Posted 10 October 2013 - 11:09 PM

Dear MerleW,

 

So you like SQF. I get it. :smile:

 

I agree with you, different Companies do not all have the same viewpoint on how to manage Food Safety. And similarly for Food Safety Standards. One could probably make a comparative list of "agreed" pluses and mines. As far as the SQF concept of introducing a Practitioner is concerned, It might be interesting to have a Poll ?.

 

I have nothing personally against SQF, in fact I think they deserve praise for the accessibility of their FS Codes, not to mention their Guidance documents. However i also feel the "Formulating Group" responsible for the Code are overly reluctant to correct various, well-documented (eg here) defects in their presentation. Stubborness is a very common human characteristic and can be admirable. It  can also be self-destructive when taken to excess.

 

So I don't know if auditors are allowed to be on forums like this to answer questions.

Do you mean that you have not noticed any qualified SQF auditors posting on this forum ?

 

What do you really have to lose?

I'm guessing this was rhetorical ? :smile:

 

Rgds / Charles.C


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Charles.C


#23 Mr. Incognito

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Posted 29 October 2013 - 01:39 PM

I do think it's a pretty good standard.  The only one I have direct experience in and it seems to do the job.

 

Maybe they are stubborn because it started out in Australia? lol j/k.  Some day I hope to get there I could have once but I screwed up the chance.

 

I can't say I've seen someone explicitly say "I'm an SQF Auditor and (blah blah blah)" .  That being said I don't always read every word of every post.

 

Kind of rhetorical.  The only thing you have to lose is 2 days of your time and a little money but if a company is serious about showing commitment to being food safe and the SQF scheme then I think that is a very small price to pay...

 

(I'm known to be a far too serious person lol)


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#24 bjc1963

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Posted 17 May 2014 - 06:35 PM

I'm new to SQF. It was mentioned in this forum that the SQF Practitioner is not a separate job, but an added responsibility to another job title. In this case it was added to the Compliance Coordinators duties. We are currently in the certification process and were told during our pre-audit assessment that a position job description needed to be created for an SQF Practitioner, which leads to believe its a separate position. Couldn't we just add the responsibilities on to his duties of the coordinators or is this due to that anyone could be assigned the task?


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#25 Charles.C

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Posted 17 May 2014 - 07:22 PM

Dear bjc,

 

Not a SQF user but I think you will find that the requirement details for the  "Practitioner" are  spelled out in the Standard. Hence >> auditable content.

 

Rgds / Charles.C

 

PS - added, see posts #1-3 for details.


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