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2.4.2.4 Food Safety Fundamentals (Management Review)


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#1 Loni Banaszak

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Posted 18 March 2015 - 02:39 PM

Hi!

 

I need some help, One of the minors we received during our "desk audit" doesn't make since to me.

 

 

The minor was against clause 2.4.2.4 Food Safety Fundamentals

 

It states the following:  

 

The effectiveness of the pre-requisite programs shall be verified as described in 2.5.4

 

Her evidence stated that:

The review of the effectiveness of the pre-req program is included in the management review but the methods and responsibilities are not documented. I have looked over my process over and over again and I cant figure out how I didn't show the methods and responsibilities.

 

I attached a copy, Maybe I am not seeing something she is. Is it as simple as adding a line that says all pre-reqs will be reviewed during management review for effectiveness? Maybe I am over thinking this lol

 

 

Thanks in advance!

 

Loni

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Thanks,

 

Loni


#2 jenky

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Posted 18 March 2015 - 03:41 PM

Based on what you presented, I believe the auditor is saying the methods/responsibilities for verifying your prerequisite programs is not documented as required by 2.5.4.  You should have a verification schedule that outlines each verification activity:  frequency, what exactly is being done, who is responsible.  Beyond the schedule, you need to document the specifics of how the verification activity is conducted.  In my experience, I just incorporate the verification methods, etc. into the appropriate work instruction for that prerequisite program.  For instance, for your pest management program - you might have a quarterly trend analysis review by the QA manager as a verification activity, or an audit twice annually by the Internal audit team.  My pest management policy details everything about the pest management program including how the effectiveness of the program is verified.

 

2.5.4.1 The methods, responsibility and criteria for verifying the effectiveness of monitoring pre-requisite programs, critical control points and other food safety controls identified shall be documented and implemented. The methods applied shall ensure that personnel with responsibility for verifying monitoring activities authorize each record verified.

2.5.4.2 Records of the verification of monitoring activities shall be maintained.

 

Without knowing how your prerequisites are written, I can only guess as to what the auditor is after.  However, based on clause where the minor was given, it appears the issue is with your prerequisite procedures not your management review procedure.


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#3 Simon

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Posted 18 March 2015 - 03:57 PM

Loni, In management review you do not tend to review the PRP's, procedures etc. but the outcomes of those procedures (at a higher level, trends etc.).  Meaning are they being effective in preventing internal/external defects and other types of failure.  Verification and monitoring of procedures should be carried out during their operation or at their conclusion by the responsible person, day to day activities (low level).

 

If it does not make sense I would be straight onto the auditor for clarification.


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#4 Loni Banaszak

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Posted 18 March 2015 - 05:01 PM

Ok, so what she I saying is that even though I mention a review of prps in management review, I also need a verification schedule to show how they are effective.


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#5 SpursGirl

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Posted 18 March 2015 - 05:47 PM

Attached File  Prerequisite Validation Worksheet.xlsx   16.18KB   267 downloadsAttached File  Pre-requisite Program Validaiton.docx   23.74KB   240 downloadsHi

 

I have a spreadsheet detailing the verification/validation of the PRP - I have attached for your reference.

 

I also have a written report to support each of the PRP validaions - also attached a completed one from last year as an example.

 

Not sure if it will be helpful but my SQF auditor was really happy with this.


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#6 Loni Banaszak

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Posted 18 March 2015 - 05:49 PM

attachicon.gifPrerequisite Validation Worksheet.xlsxattachicon.gifPre-requisite Program Validaiton.docxHi

 

I have a spreadsheet detailing the verification/validation of the PRP - I have attached for your reference.

 

I also have a written report to support each of the PRP validaions - also attached a completed one from last year as an example.

 

Not sure if it will be helpful but my SQF auditor was really happy with this.

Thanks, Ill take a look! I really appreciate it.


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Thanks,

 

Loni


#7 Charles.C

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Posted 18 March 2015 - 08:27 PM

I don’t wish to be too unkind towards the SQF Organisation since IMO every FS Standard has certain Achilles Heels/Pros. And SQF is no exception.

 

Nonetheless, if you care to look back through a host of existing threads, you will realize that SQF Auditors have driven many of the posters on this forum to distraction  over their interpretations of the SQF Standard, and notably with respect to the topics of validation and verification.

 

Just as one simple example, the SQF website states that validation is NOT required for Prerequisites. Regardless, it appears many SQF auditors ignore this, I presume, official Instruction (or perhaps  the website is assumed to be just an unintentional  trap for the unwary). Spurs Girl”s document is a possible demonstration of acceptance to this deviant behaviour but I seem to recall was in itself a special case so perhaps not.

 

I will elaborate no further for fear of over-repetition.Just try a little back-scanning through the a few months of threads in the SQF Forum.

 

Thanks / Charles.C

 

PS – No problem as it is but you may feel like changing the title of yr thread after the preceding discussion. :smile:


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Charles.C


#8 Loni Banaszak

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Posted 18 March 2015 - 08:52 PM

Charles,

 

You have lost me lol. My title is what it is because the document I showed her (my auditor) was my management review process to show that during that meeting we review the effectiveness of prps. I thought stating an showing that we do via the agenda and meeting items that PRPs are reviewed as as at the time of internal audit.

 

Sorry if I don't understand but I am really new to SQF, I come from ISO where we weren't required to verification and validation. I am just so lost

 

 

Loni :rofl2:


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Thanks,

 

Loni


#9 Charles.C

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Posted 18 March 2015 - 09:00 PM

Indeed, as i said, the title is fine. I was merely noting that the direction of the thread seemed to have mainlined onto other aspects which people scanning the titles of threads might also be (even more?) interested in.

 

Only a side-note, absolutely no problem to ignore. :crybaby::biggrin:


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Charles.C


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