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Section 2.5.5 and 2.5.7 / SQF Module 2- Level 2 and Module 11


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#1 ana_baron

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Posted 22 April 2015 - 10:25 AM

Good Morning,

 

I would like some feedback regarding section 2.5.5. and 2.5.7. After a practice audit, auditor made observations  of programs that were poorly developed, one of them being Internal Audit. We are seeking to be certified under SQF 2000 Module 2/ Level 2 and Module 11. I have created some documents to be in compliance with code, and I just want some feedback and make sure I am in a good path. 

 

After not having having success on last practice audit my focus now is to clear understand the process sequence to ensure programs align with the SQF Code. To start with, I have created the following:

 

1.      SQF Internal Audit Format to verify the effectiveness of the SQF System (each of the sections of the Module)

2.      If deficiencies were identified during the Internal Audit, the Non-Conformance Log will be the document that will support the Internal Audit Format.

3.      Corrective and Preventive Action Request will help to outline any deficiency identified on the Food Safety Manual.

4.      Corrective and Preventive Action Summary Log will help just to have a register for tracking all CAPAs created.

 

What I understand between 2.5.5 Corrective Action and 2.5.7 Internal Audits is that Corrective Actions will be issued if any non-compliance regarding to HACCP or Food Safety related, and Internal Audits is more about ensuring each section of the modules are in compliance with the code. Feel free to give examples. 

 

I know it can be a lot of information. At this point I will rely on the SQF Code and your great guidance. We have had 2 consultants already and we thought we were on the right path. 

 

I truly appreciate your help.

Thanks!

Ana  

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#2 Mulan1010

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Posted 23 April 2015 - 06:08 PM

I think your materials for the corrective and preventive action request and logs look great.  The Internal Audit Format you have could probably use some tweaking, we were in the same boat until we adopted the SQFI checklist from their documents section ( http://www.sqfi.com/documents/).  Once we used their questions as guidance we had a much more positive result from our auditors.  We chose make our own forms based on the questions in the checklist and added few of our own.  One thing that I have noticed during our last 5 years of audits is that the auditors really like notes and comments, both good and bad, on the Internal Audit forms as they interpret them as proof that you actually performed an audit and did not simply pencil whip the form.


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#3 Charles.C

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Posted 24 April 2015 - 05:39 AM

Hi ana-baron -

 

Thanks for the attachments. Very brave. :smile::thumbup:

 

I am not a SQF user but can make a few comments on yr OP -

 

(1) As far as I can see SQF2000 became extinct around 2 years ago. Though the numbers 2.5.5 and.7 still seem in use.

(2) "Preventive" in Is this a Preventive Action" is I guess a misspelling with respect to the Code. Although the Guidance cleverly uses both forms together  so it probably doesn't matter.

(3) This is in no way a criticism of the form but IMHO SQF's handling of "Corrective action" is obsolete, atypical, demonstrates Code/Guidance inconsistency, and is a semantic nightmare. Better to say no more other than, IMO, here is a shorter, readable, and far more intelligent summary of the "functions" involved -

 

Attached File  CAPA in HACCP (2014).pdf   476.31KB   68 downloads

 

This topic has also been discussed on the forum, eg  -

http://www.ifsqn.com...rective-action/

(4) Based on my own experience with BRC, the IA checklist seemed to me to be too much of a summary-style format  for use on the production-floor. IMO needs expanding. I personally prefer to attach a dedicated CA (CAPA  for SQF !) section to the end of each audit to detail the CA for any audit-required follow-ups.

 

As per previous post, I have noted other approving comments about the SQF offered IA checklist (not seen by myself), particularly with respect to audits, so this may be the currently preferred route.

(5) Seemed to me the 2 logs might be easier to combine into one file but perhaps SQF makes this impossible. anyway the layout looked neat.

 

Regardless of the above, if yr consultants advise otherwise, their knowledge of SQF is likely to be much better than mine. I do prefer some aspects of SQF compared to BRC but both Standards surely have some Major Quirks of their own. :smile:


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Kind Regards,

 

Charles.C





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