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How to justify an elimination from the Scope of Audit?

scope elimination from scope rationale

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#1 Suzie B

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Posted 31 March 2015 - 06:07 PM

Hello All,

 

I am looking for guidance on justifying an elimination from scope before my SQF Audit.  I have a refrigerated storage building that cannot not be certified.  It is 100 years old with wooden floors, no drains, and unsmooth walls.   It is a stand alone building. 

 

What documentation do I need to provide to request it be eliminated from the scope of the audit?  With this building, we don't stand a chance of certification.  Without it, certification is practically a certainty.

 

Any suggestions are appreciated

 

~S~


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#2 Simon

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Posted 31 March 2015 - 06:14 PM

Hi Suzie, the key question is what is the building used for?

 

Regards,

Simon


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#3 Suzie B

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Posted 31 March 2015 - 09:54 PM

Hi Simon,

 

This is a sticky situation as the room is currently used to store refrigerated product between 33 and 38 degrees F.  The customers who store in that room do not require a certification. 

 

I was told that it is possible to exclude an area from the Scope of the audit.  I was just wondering if anyone has ever tried, and been successful.  How did they justify it?  What is relevant and what is not?

 

Thanks


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#4 Charles.C

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Posted 01 April 2015 - 05:24 AM

Dear suzieq,

 

Does the standard specifically define the construction materials. I presume all the contents are fully packaged. How abut the temperatures ?

i have had to live with a cold store where the inner walls were encrusted with ice and the coils needed defrosting every 2-3 hours so as to meet frozen temperature limits.

But the proof of the pudding ......

 

 

The only SQF manouevre for a known, unavoidable, presumably non-critical, NC which I can recall seeing here was to formulate a compromise gesture.

 

There are examples discussed here where a "promised" replacement / repair for obvious no-nos (wooden items from memory) received relatively benign auditor responses. The only awkwardness was in that some cases supporting evidence was requested, eg quotations.

 

Clearly this is only a delaying tactic and could badly rebound if zero action foreseen. But. when all else fails, KTC. :smile:


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Kind Regards,

 

Charles.C


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#5 erin.m.v

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Posted 14 April 2015 - 01:13 AM

Hi Suzie,

 

My facility has a very old, stand-alone building that was turned into a freezer in the 1920s/1930s, which was not included in our scope at the time of our certification audit in 2013 (under 7.1) because it would hundreds of thousands of dollars to get all three levels of the building up to SQF standards. 

 

During our certification audit (under 7.1), we never said that we were excluding a building from our scope of certification, we just never spoke of it at all.  This was lucky for us because during our recertification audit a month ago, the auditor only asked if there were any changes to be noted and since there weren’t, nothing more was said about it and he moved on. 

 

If we were to have to include that building in our scope, I imagine that I would be doing extensive risk analyses for every problem that we were NOT going to be able to solve (e.g., frost falling off coils on ceiling over product), which included documented evidence that those problems have never caused a food safety problem, as well as documented proof of everything we are doing to minimize the potential impact of these problems on the products we store in that building (e.g., twice daily inspections, daily cleaning).  And then I would just wait and see...

 

I am very curious about how this all plays out!  We are the only facility within our company that has this particular issue, so I'm not sure how others are handling it.

 

Good luck!

- erin -


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#6 Charles.C

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Posted 14 April 2015 - 07:20 AM

hi erin.mv,

 

I assume the storage was also not (overtly) included in yr flowchart/main process line,  or the auditor experienced a caviar lunch.

 

BTW, if not mentioned previously, Welcome to the Forum ! :welcome:


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Kind Regards,

 

Charles.C


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#7 JSwenPDX

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Posted 12 May 2015 - 06:30 PM

Can the original poster update us on the results?


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#8 Suzie B

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Posted 29 June 2015 - 05:37 PM

Thank you all for your responses.  After months of exhaustive research, I am sad to say I am no further to a conclusion.  The results have been split down the middle.  I'm encouraged by Erin's remarks since it is very similar to our situation.  It is cost-prohibitive to upgrade the building (built in 2013).  Our latest third-party auditor said I can omit the building from the SQF Certification as it is a stand-alone building. However, since it was the first structure built on our campus, it is right in the center of the complex.  Hard to miss it.  There is no guideline that addresses this situation (that I can find).  Our SQF Certification Audit is scheduled for Jan 2016.  I will update you all after the audit.  Wish me luck.....

 

  :thumbup:  

 

~S~


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#9 JSwenPDX

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Posted 29 June 2015 - 05:45 PM

We just did our initial certification audit in May. We did a last minute line exclusion from the certification. This was due to continuing installation of equipment to the line. I reached out to my CB to tell them I wanted to exclude the production line, they asked for a formal letter with food safety reasoning. They approved the exclusion and the audit went smoothly.

 

In my opinion, I wouldn't try to exclude the storage from the certification because it's not a production line - it's storage. Instead, I would not label the building on your map and when on the tour, if the auditor asks about the building, I would mention that it is a storage where no raw materials or finished products within the scope of the certification are stored there. Then just keep walking toward your next destination. Write it in your storage policy to back yourself up.

 

Goodluck!


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