23 replies to this topic

[DenisB]

Hi everyone,

 

I have a situation that I would like as many opinion as possible. The issue is, recently SQFi has instructed it's auditors to verify if the current Certification Body (CB) is on the manufacturer's approved suppliers list. As per SQFi, "Element 2.3.3 requires you to have specifications for those entities that provide a service that impacts food safety and quality. The CB has a direct impact to your operation and the facility should have a description of the services provided by the CB."

 

In our opinion, the CB does provide a service but we cannot see what is the impact on food safety and quality. The CB provides audit services to validate that we, the food manufacturer are applying the SQF Code accordingly in order to acheive certification. Our food safety programs were there long before SQF came along, as most, ours are based on HACCP and build using an ISO 9000 structure, a few adjustment were done to meet the SQF Code, but the purpose of the CB and his audit service is to assure the we meet certification criterias - we do not agree that there are any impacts on food safety from the CB for auditing. We would agree to this only if the CB would provide consultation services to our company.

 

If we are wrong, then we would also need to add to our approuved service provider the Canadian Food Inspection Agency (CFIA) as they provide certification to HACCP in some areas in Canada.

 

 

Thanks for your help and comments.

 

DenisB

 

Edited by Charles.C, 21 August 2014 - 05:15 AM.
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[Caboose]

Could you add a supplier approval based on their certification from the standard (ie. They are certified by SQF to be a certification body)? Otherwise if all they provide is HACCP certification courses you could just sit in "yearly" to audit the course?

 

Is CFIA the canadian version of FDA? I would doubt you would have to audit their programs but you could if you wanted to be extra thorough I suppose.

[Carol88]

Hi everyone,

 

I have a situation that I would like as many opinion as possible. The issue is, recently SQFi has instructed it's auditors to verify if the current Certification Body (CB) is on the manufacturer's approved suppliers list. As per SQFi, "Element 2.3.3 requires you to have specifications for those entities that provide a service that impacts food safety and quality. The CB has a direct impact to your operation and the facility should have a description of the services provided by the CB."

 

In our opinion, the CB does provide a service but we cannot see what is the impact on food safety and quality. The CB provides audit services to validate that we, the food manufacturer are applying the SQF Code accordingly in order to acheive certification. Our food safety programs were there long before SQF came along, as most, ours are based on HACCP and build using an ISO 9000 structure, a few adjustment were done to meet the SQF Code, but the purpose of the CB and his audit service is to assure the we meet certification criterias - we do not agree that there are any impacts on food safety from the CB for auditing. We would agree to this only if the CB would provide consultation services to our company.

 

If we are wrong, then we would also need to add to our approuved service provider the Canadian Food Inspection Agency (CFIA) as they provide certification to HACCP in some areas in Canada.

 

 

Thanks for your help and comments.

 

DenisB

 

Hi I am in Australia and I include our auditing body  and our auditor as I would like to ensure that they have their paperwork in order and that the auditing body employ auditors who are compliant and have the skills to audit.

[cazyncymru]

Hi Denis

 

ANYBODY who is providing you with a service, regardless of what that service is, should be on your approved supplier list.

 

Caz x

[Raj21]

Hello :-) , IMO, the certification body is the one to validate the process and does not have direct impact on food safety and/or quality. Consder two scenarios wherein the the certification body does a good audit on one side and a bad audit on the other. What could be the consequences to the company on the front of food safety and quality? None actually. Well, it is just the matter of the accountability of the producer as he is always liable for the product.

[Gurumug]

Auditing and the certification body as a service provider can be evaluated and in fact should be evaluated.

The evaluation criteria may vary ? What if the certification body always gives "soft" audit reports or employs auditors with no proper experience/background of what they are auditing.

If your certification/management system application is not up-to the mark and it gets clean chit every time , then their might be some "bear traps" in the system and ultimately n the product which go unnoticed.

[haccpmanager]

Yes you probably should include your certification body on your Approved Suppliers register.

 

But get ready to be issuing Non Conformances against them.

 

I have many clients and about half of them include their Certification Bodies.

 

Most of my clients send their Approved Suppliers annual questionnaires asking for current copies of their certifications/accreditations/licenses.

 

Guess who almost universally doesn't respond?

 

Their certification bodies.

[Tony-C]

Hi Denis,

 

Some relevant extracts from the SQF Code and Guidance:

 

SQF Code Edition 7.2
1.10 Select a Certification Body
The supplier is required to have an agreement with a certification body in place at all times which outlines the SQF audit and certification services provided.
2.3.3 Contract Service Providers  
2.3.3.1 Specifications for contract services that have an impact on finished product safety and quality shall be documented, current, include a full description of the service to be provided and detail training requirements of contract personnel.
2.3.3.2 A register of all contract service specifications shall be maintained.
2.4.5 Incoming Goods and Services
2.4.5.1 Raw materials, ingredients, packaging materials, and services that impact on finished product safety shall be supplied by an approved supplier.
2.4.5.4 The approved supplier program shall be based on the prior performance of a supplier and the risk level of the raw materials ingredients, packaging materials, and services supplied, and shall contain as a minimum:.......
2.4.5.5 A register of approved supplier and records of inspections and audits of approved suppliers shall be maintained.

SQF Guidance Clause 2.4.5
The approved supplier program must include providers of contract services such as transport, pest control, maintenance, labor hire, etc. The program will identify methods to ensure service providers and their staff adhere to the specifications outlined in 2.3.3.
The supplier must maintain a list of approved suppliers, including contract service providers. All providers of goods and services must be included on the register.

So you should have an agreement/service specification from your certification body, they should be on a register of contract specifications/approved suppliers and as part of the approval process you should verify the competency of the certification body and auditor.
 

Regards,

 

Tony

[DenisB]

Thanks everyone, but all this doesnt convince me to have a CB on an approved service supplier list. Our quality and Food Safety programs were in placed long before SQF came along, we are simply adhering to a Food Safety program owned by SQFi upon request of some of our customers. The CB is mearly veryfying that we are following SQFi's Food Safety Code to acheive certification. The auditors are working for a CB - the audit process has NO direct impact on our food safety or quality programs but does on the certification process. The audit (service provided) is an evaluation of how we apply the SQF program, the certification process is NOT a consultation.

 

If we must have our CB approved, we would also need to approve our Federal Food Inspection Agency (CFIA in Canada/Equivalent to the FDA in the USA) as they provide us with HACCP certification (CFIA own program called FSEP) that in some part of the country they have not auditied in more than 3 years du to lack of experienced staff - that said, we cannot disqualify our CFIA as a service provider, as we cannot disqualify our CB. We may have issues (complaints) with our CB but can never disqualify them as the only reason one would change CB is generaly based on Price of service.

 

To answer Tony's comment, we wouldnt be audited without a contract with our CB, this is part of the Code, we do verify competency of our auditors when they show up for the audit, but how do you verify competency of the CB; do you require their 3rd party audit results, proof of training of all relevant staff, proof that they are licenced by SQFi (how far do one need to go ???: Proof of competency of the Certification Manager ???) I could list you dozens of criterias that we require from our various service suppliers. We dont feel that this requirement from SQFi is of any added value to our food safety program it has no impact on food safety or quality and would also require more labor from our part - if we were using the CB as a consultant, I would agree  but an audit to a program has no direct impact on my food safety program - If we chose not to apply corrective actions following an audit we will eventualy loose our SQF certification - this would be our problem and does not mean that we manufacture unsafe food.

 

Thanks for all your comment - I'll be looking out for more.

 

DenisB

[Snookie]

So you should have an agreement/service specification from your certification body, they should be on a register of contract specifications/approved suppliers and as part of the approval process you should verify the competency of the certification body and auditor.
 

Regards,

 

Tony

 

Again it may be the lack of coffee in my brain, (not that I am sure it could get enough today), but I respectfully disagree.  How does a company verify competency of the certification body?  That is the responsibility of SQFI.  The auditor is another issue.  If they clearly don't know their stuff you take that up with the people who hired them.  But each company having to verify the competency of the CB, defeats the purpose of the what GFSI is supposed to do.  And in that case what is the point of paying them.  Think this opens up one very sticky wicket.  Quite frankly I agree with Denis's assessment in post #9. 

[Gurumug]

Agree with your viewpoint to much extent. 

 

CFIA/FDA or else can not be added to this list as they are legal bodies.

 

Yes. CBs are disqualified and changed only on basis of price of service usually but this IS the negative practice and does effect the food safety practices/status of a facility.

Its just not about certificate. Organizations globally, at times, due to various management level strategies , go for the CBs offering softer audits/auditors! They at times even present illogical reasons and have legal option to change CB and keep their certification continued, which was suspended by the previous CB without any hassle.

 

Largely, this practice is not taken care of by any ISO/Private food industry standard.

[Tony-C]

Again it may be the lack of coffee in my brain, (not that I am sure it could get enough today), but I respectfully disagree.  How does a company verify competency of the certification body? 

 

Check with SQFI here - Job done

[Gurumug]

An interesting review of the case(s) where Federal agencies and CBs verified the FSMS of facility and facility failed later practically, acting as the point of origin of a food safety breach/outbreak, can be found in this article especially this research paper mentioned in this.

 

 

 

Audits and inspections are never enough: A critique to enhance food safety  ABSTRACT Internal and external food safety audits are conducted to assess the safety and quality of food including on-farm production, manufacturing practices, sanitation, and hygiene. Some auditors are direct stakeholders that are employed by food establishments to conduct internal audits, while other auditors may represent the interests of a second-party purchaser or a third-party auditing agency. Some buyers conduct their own audits or additional testing, while some buyers trust the results of third-party audits or inspections. Third-party auditors, however, use various food safety audit standards and most do not have a vested interest in the products being sold. Audits are conducted under a proprietary standard, while food safety inspections are generally conducted within a legal framework. There have been many foodborne illness outbreaks linked to food processors that have passed third-party audits and inspections, raising questions about the utility of both. Supporters argue third-party audits are a way to ensure food safety in an era of dwindling economic resources. Critics contend that while external audits and inspections can be a valuable tool to help ensure safe food, such activities represent only a snapshot in time. This paper identifies limitations of food safety inspections and audits and provides recommendations for strengthening the system, based on developing a strong food safety culture, including risk-based verification steps, throughout the food safety system.

 

 

Practically audit processes are made questionable by the mere fact that auditors/CBs are paid for their service by auditee and I had faced the cases of losing/delaying of the payments when a client got a BAD report. 

[Snookie]

Check with SQFI here - Job done

 

Yes, I understand that SQFI has said these organizations are competent.  However, it does become a circular argument.  These organizations also say they provide competent auditors which sometimes they do sometimes they don't.  I have seen an SQF system certified at level 3 by one these very notable companies that did not come even close to meeting the standard and several of their auditors certified it.  If we have to start validating the validators..........where does it end? 

[Gurumug]

Validating the validators is essential. In fact approach of these systems is that at least everyone is audit-able and has to maintain some standard or keep themselves bench-marked against the best practices.

[Tony-C]

Yes, I understand that SQFI has said these organizations are competent. 

 

 

Post:

'Again it may be the lack of coffee in my brain, (not that I am sure it could get enough today), but I respectfully disagree.  How does a company verify competency of the certification body?'
Reply - 'Check with SQFI here - Job done'

 

Next Post:

'Yes, I understand that SQFI has said these organizations are competent. 

 

Included in your 1st post:

'The auditor is another issue.'

 

& in 2nd Post:

'However, it does become a circular argument.  These organizations also say they provide competent auditors which sometimes they do sometimes they don't.  I have seen an SQF system certified at level 3 by one these very notable companies that did not come even close to meeting the standard and several of their auditors certified it.  If we have to start validating the validators..........where does it end?'

 

We can help with that as well!

 

I look forward to seeing some suggestions on a solution

 

Regards,

 

Tony

[esquef]

As stated above CB's are considered suppliers, regulatory (CFIS, FDA, USDA, FSIS, etc), are not. CB's should definitely be on you contract service supplier list.

[fgjuadi]

GFSI Guidance Document has some interesting qualifications for CBs- and requirements for the Accreditation body (SQF, BRC, etC)

This may be more helpful for standard owners, but

Maybe they can be used to guide you in your own requirements? It's really, really long, but here are some -

http://www.mygfsi.co...Version_6.3.pdf

 

CBs should be -

- current accreditation to ISO/IEC Guide 65 or ISO/IEC 17021 (supplemented by ISO/TC 22003)

-Accredited by Accreditation Bodies that are members of the International Accreditation Forum (IAF)

-Accredited by Accreditation Bodies that are signatories to the Multilateral Recognition Arrangement (MLA)

-must have the named scheme included in their scope of accreditation including revision numbers and / or dates

-Accreditation is publicly available.

- Certification Body has a system to update the auditors’ details, where appropriate (The details of the auditor’s qualifications, training, experience and scope of activity in relation to the scheme’s product categorisation)

-Certification Body has a system to notifies you of withdrawal or suspension of certification

-The Certification Body shall operate an effective and fully implemented quality system.

The Certification Body shall require all staff involved with the certification process to sign a contract
or agreement, which clearly commits them to:
I. Complying with the rules of the organisation with particular reference to confidentiality and independence
from commercial or personal interests,
II. Declaring any issues in relation to personal conflicts of interest.

 

Etc Etc. 

 

I think asking for the accreditation and the ethics agreement would be enough for me.  I'm going to see if I can get that infos from my CB right now, actually.

Edited by magenta_majors, 22 July 2014 - 06:53 PM.

[DenisB]

As stated above CB's are considered suppliers, regulatory (CFIS, FDA, USDA, FSIS, etc), are not. CB's should definitely be on you contract service supplier list.

I do understand the fact the CFIA is a regulatory body in Canada but in addition of having regulation and laws applied and repected - the CFIA in Canada for any food other than meat and seafood - the FSEP program is volontary - your company has the priviledge to certified to this program if you transform or milk  honey, eggs ...  Therefore being volontary with the CFIA means that we can also change certifier (or CB as you may wish to call them) and go to an independent CB for a HACCP certification.

 

Regardless thta the CFIA is a regulatory body, we have the choice to drop the FSEP Certification and go to an independant HACCP certification just like we have the choice to drop SQF for BRC or any other GFSI scheme.

 

If we need to have our CB on the approved suppliers list - does this mean that I also need to have any other certification body on our approved suppliers list: HACCP, Organic, Allergen free....What about our Rabbi for our Kosher certification ??? Do we need to have him as well on our appoved suppliers list - to the Jewish community, it does represent a food safety certification.

 

Any others have similar situation with BRC, FSSC22000 , IFS...is it the same or is SQF the ony one requiring this?

 

DenisB

[esquef]

Denis,

 

With regard to Kosher, Halal, organic (covered in 2.8 - Identity Preserved Foods); these are not considered food safety issues by SQF, but rather quality issues. If you're facility is SQF Level 3 certified they'll need to be covered and I mwould think that they could/should be covered under your Supplier Approval program, but if you're at Level 2 Identity Preserved Foods are N/A in the SQF Edition 7.2 code.

[DenisB]

Hi esquef,

 

I know that Kosher and Organic are for those who are certified at Level 3 - but most of our facility are either Kosher certified and/or Organic even with a level 2 certification. We have no demand for a level 3 - therefore, not being level 3 we are still Kosher  and/or Organic - meaning that I still have controls in place to respect those certification. Maybe to anybody a Kosher certification has nothing to do with food safety - try explaning this to the Rabbi next time you see one - to them, it is has important as our HACCP or SQF program.

 

I dont beleive that not being Level 3 for SQ give one the priviledge not to apply some quality controls over their operations to make sure that the Kosher or Organic certifications are respected and audited internally. This being said, should a manufacturer list as approuved service supplier the abbi or the Organic certification organisation as well as the CB ?

 

DenisB 

[Charles.C]

Dear DenisB,

 

Fascinating speculations but perhaps simpler to invoke the Practitioner Should-Know-It-All Property to query SQF ? Especially if you've paid SQF for the Training Approval.

 

Perhaps an extension of  Post #12 is called for ? eg Scope of Approved suppliers"?

 

Rgds / Charles.C

[KevinR]

This is the kind of nit picking BS that detracts from the important requirements of a food safety system. Just another piece of useless paperwork to fill out, update, control;, veryify and validate for no benefit to anyone!

[Jelena C]

@DenisB  If you had so much time to write all this posts, you definitely have 5 minutes to put CB on a list of suppliers