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GFSI Certification Process, not a pleasant experience


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#1 kmboardman

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Posted 21 December 2016 - 08:00 PM

Just received our GFSI Certification and I just want to say it was not a pleasant experience. From the cost of process, the quality and knowledge of the consultants and their Associate Lawyer range fees, ridiculous to say the least. To understand what the code says, and how they want it written or how the auditors wanted to see it per the consultant was more complicated than it should have been. Even in the forums and other online resources, I see people like myself ask for examples of a policy or even how a simple register is formatted and only vague explanations are offered in most cases, why not send an actual template or a policy; what is the big secret: Even the consultants appear to be uninterested in providing "to much information" because they want you to come back and pay their lawyer fees.

 

Like I said, I spent way too much money on this process, $7K just for the audit alone, not including my time or the consultants fees. I hope others will join me in starting a conversation about how to improve this process and reduce the price tag, small operators can't absorb these costs. Throughout the process I kept asking why this is so complicated, why is my consultant writing a policy that does't make sense for my operation, why aren't their templates showing exactly what SQF, BRC, etc, and the auditors want see and in what format, why do I need a $150/hr consultant to do this? I have been in food safety my entire life, 40+ years experience in processing; this should be be this difficult.

 

I would love to see some conversation on this, please help for those that are just getting this process going, This appears to be a money maker for a lot of people except the operators.

 

Sincerely.


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#2 Ryan M.

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Posted 21 December 2016 - 09:42 PM

The reason there aren't "standard templates" is because every operation is different.  My experience lies with SQF and the SQF code is written in a way where it lends flexibility to the specific operator in ensuring they comply with the code.  It doesn't tell you HOW to comply, but what is required for compliance if that makes sense.  They don't tell you how to do something, but you have to figure that out on your own.

 

Unfortunately, you wasted a lot of money on consultants and honestly many of them aren't worth much IMO, why?  Because they don't know your operation like you do.  What you really need is to hire someone who is dedicated to focus on the implementation and maintenance of your GFSI program, without that you will continually be frustrated.  If you are a small business and want to do this I think your best option is to hire a smart, driven, young person just getting into the industry and leave it to them to implement the program.  It would be a great experience for them and it would be the cheapest option for you in the long run.


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#3 Ryan M.

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Posted 21 December 2016 - 09:44 PM

Additionally, you should look ahead to compliance with FSMA and the Preventive Controls rule.  Depending on the size of your business you are required to comply right now, September of 2017, or September of 2018.  This same person you hire for your GFSI can also work to get you to compliance for the FSMA Preventive Controls rule.


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#4 RMAV

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Posted 21 December 2016 - 11:48 PM

What Ryan M said.  I'm not a fan of consultants in general.  I've found many often go "over the top" costing time and $$ not just in their fees but ongoing costs to my organization as well.  In the end, all you have to do is meet the requirements.  So often I find people inside and outside the organization read into the standard what is not there. 

 

Here's a couple of examples -

 

One consultant (didn't need one in the first place) had difficulty finding issues with our programs.  So, to justify his presence, he said we needed to show we considered the state mining regulation in the state from which we received an ingredient.  (After all, the standard said we had to ensure our suppliers met applicable regulation).

 

Another was within the organization.  The person said a floor scrubber could not be used and all floors must be mopped by hand, because, after all, a floor scrubber machine can be a source of cross contamination.  This is true in some operations, but not ours.  The cost of running a floor scrubber was $11,000 annually.  The cost of mopping by hand would have been $330,000 annually.  The cost of mopping by hand the way this person wanted it done would have been $2,400,000 annually.  Interestingly, this person was not convinced and insisted the standard be interpreted a certain way.  They were wrong, of course.

 

Different auditors can have different interpretations of the standard.  That's just a fact of life, unfortunately, but on the bright side, the standards have built-in appeals process.  You can always appeal an auditor's decision.  If they are wrong, most of the time I believe the certifying body will correct it.

 

Around here, I've found people to be quite helpful and some can even provide some documents now and then.  But it is also true that those who post almost zero details of their operations will not get much response because no one knows how to respond.  It goes back to what Ryan M said, every operation is different.  What is appropriate in one may not be appropriate in another as my insane floor cleaning anecdote shows.


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#5 Joseah

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Posted 22 December 2016 - 07:02 AM

Just received our GFSI Certification and I just want to say it was not a pleasant experience. From the cost of process, the quality and knowledge of the consultants and their Associate Lawyer range fees, ridiculous to say the least. To understand what the code says, and how they want it written or how the auditors wanted to see it per the consultant was more complicated than it should have been. Even in the forums and other online resources, I see people like myself ask for examples of a policy or even how a simple register is formatted and only vague explanations are offered in most cases, why not send an actual template or a policy; what is the big secret: Even the consultants appear to be uninterested in providing "to much information" because they want you to come back and pay their lawyer fees.

 

Like I said, I spent way too much money on this process, $7K just for the audit alone, not including my time or the consultants fees. I hope others will join me in starting a conversation about how to improve this process and reduce the price tag, small operators can't absorb these costs. Throughout the process I kept asking why this is so complicated, why is my consultant writing a policy that does't make sense for my operation, why aren't their templates showing exactly what SQF, BRC, etc, and the auditors want see and in what format, why do I need a $150/hr consultant to do this? I have been in food safety my entire life, 40+ years experience in processing; this should be be this difficult.

 

I would love to see some conversation on this, please help for those that are just getting this process going, This appears to be a money maker for a lot of people except the operators.

 

Sincerely.

I read disgust.

This is true but all this for food safety.

We need a regulator to ensure the Operator is part of the fun.


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#6 kmboardman

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Posted 22 December 2016 - 01:15 PM

Additionally, you should look ahead to compliance with FSMA and the Preventive Controls rule.  Depending on the size of your business you are required to comply right now, September of 2017, or September of 2018.  This same person you hire for your GFSI can also work to get you to compliance for the FSMA Preventive Controls rule.

our operation is regulated by USDA/FSIS, light years ahead of non-meat/poultry food operations.


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#7 RMAV

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Posted 22 December 2016 - 02:03 PM

My post might imply that I believe all consultants are bad.  I don't think they're all bad.  I believe there are good ones out there.  The last couple of auditors I've had are probably great consultants - knowledgeable, practical, etc.

 

Now a couple more stories because I can't resist:

 

I heard a consultant say that she can fail a facility in an SQF audit if she found a can of wasp killer spray in someone's desk under typical conditions:

-Not on pesticide list

-Person using it not licensed

-no log of where/when it was used (if it is not still sealed)

-improperly stored

-ineffective pesticide program

-ineffective pesticide training program

-etc.

-etc.

 

Another one said she once wrote a NC in an SQF audit because she found an employee's vehicle in the parking lot that was unlocked and had a can of Deep Woods OFF (mosquito repellent).  Uncontrolled pesticide.  This auditor will never set foot in my facility.


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#8 Ryan M.

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Posted 22 December 2016 - 03:12 PM

our operation is regulated by USDA/FSIS, light years ahead of non-meat/poultry food operations.

 

Well, I wouldn't say "light years ahead".  Compare USDA/FSIS to a dairy PMO operation and you are actually behind.  It is all relative and each operation is different.  While there are many good regulations and practices in place an a USDA/FSIS operated facility it isn't the top of the chain.

 

With that said, it doesn't really matter in the eyes of GFSI.  You still have the meet the requirements for GFSI, whatever type you choose.  You can argue with consultants and auditors all day and night about it until you are blue in the face, but at the end of the day you have to meet the requirements and PROVE that you meet them.  Every facility can benefit from this because without fail you find there are gaps or areas that can be improved in your food safety system.

 

Many customers these days want a supplier who is GFSI certified.  Our facility is a new start-up since May this year.  The first words out of every customer visit was, "Are you GFSI certified?"  When I said not yet the next question was, "When will you be GFSI certified?"  Then they walked out the door...well most of the potential customers.

 

At the end of the day it is your decision if you want to go down the road of GFSI, but know you likely have limited your customer base.


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#9 kmboardman

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Posted 22 December 2016 - 05:06 PM

All, my post was not to start a complaint or a tit for tat subject matter. I was and am still hoping for honest solutions to this problem and trust me, I have talked to enough operators who have or are going through this process and it is a problem. Setting up a GFSI FSM shouldn't be a $50K process. It shouldn't take a year or two like I have heard from others in the same situation.

 

How can we as a group and in the interest of food safety make this possible? And I am sorry, I don't buy the fact that we all have different operations thus we all have to reinvent the wheel when writing a FSM that complies with a GFSI code; A thermometer calibration policy or a metal detector policy shouldn't be that much different from one processor to the next.


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#10 Ryan M.

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Posted 23 December 2016 - 03:16 AM

It depends is the answer. Do you have someone in house that can read the sqf code, interpret the requirements, and apply it to your operation? Additionally you need to have someone who has the time to write the sqf system, implement it and maintain it.

While the basic programs don't need wheel reinvention they all have to be tailored to your facility and operation. The basics are really in the sqf code.

I don't know, but at this point t I don't think you have read the sqf code? I can tell you based on my experience the first time I implemented an sqf system at a facility (FDA facility by the way) I didn't have a deep understanding of sqf. All I did was go line item by line item in the sqf code and revised or wrote everything in line with the sqf code. Then conduct the training and come back and very everything on a regular basis.

So it isn't rocket science, but it takes time and effort and diligence to sustain it and not just implement it. And that's really the point....it is no longer sufficient to just meet regulatory requirements since they are subpar in a lot of ways in terms of food safety.

No offense, but I think this is the disconnect in your understanding. You talk about the cost of implementing, but what is the cost of you don't implement it and you have a minor or major recall? Or you have customers unwilling to do business with you?


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#11 Charles.C

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Posted 23 December 2016 - 05:48 AM

All, my post was not to start a complaint or a tit for tat subject matter. I was and am still hoping for honest solutions to this problem and trust me, I have talked to enough operators who have or are going through this process and it is a problem. Setting up a GFSI FSM shouldn't be a $50K process. It shouldn't take a year or two like I have heard from others in the same situation.

 

How can we as a group and in the interest of food safety make this possible? And I am sorry, I don't buy the fact that we all have different operations thus we all have to reinvent the wheel when writing a FSM that complies with a GFSI code; A thermometer calibration policy or a metal detector policy shouldn't be that much different from one processor to the next.

 

Hi kmboardman,

 

I daresay a lot of people may echo yr comments and for a variety of different reasons. I personally had no opportunity to use Consultants and although long-time experience in QA/HACCP (but not ISO) I found the text for BRC Food at times bordering on the "mystical". It is also not unlikely IMO that there exist both "good" and "less good" Consultants, particularly from a technical POV. And perhaps similarly with respect to charge motivations also. Perhaps you were just "unlucky".

 

No offence intended but It would have maybe helped to understand yr comments/generate discussion if you had initially supplied a little more specific information, eg -

 

(1) which FS standard did you attempt (note that strictly speaking, there is no such thing as a "GFSI Certification", this is entirely a [successful] promotional gimmick),

(2) what kind of business are you in ? eg food category, RTE ?

(3) what quantity/capability of technical back-up/QA system is available (already in place?) so as  to implement the GFSI-recognized FS Standard you selected ? eg do you already have any HACCP/ISO 9001 Certifications ?

(4) what kind of investment level do you consider as "reasonable" ?

 

PS - before today, I totally missed yr OP/replies so apologies for not inserting any previous feedback.

 

Welcome to the Forum ! :welcome:


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Kind Regards,

 

Charles.C


#12 AS NUR

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Posted 23 December 2016 - 09:21 AM

thanks God.. i did my certification process without consultant.. so i can save our money for this process... i just did training to interpret requirement of standard rightly.. and we did gap assessment and after that going to certification.

 

Rgds

 

AS Nur


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#13 SQFconsultant

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Posted 28 December 2016 - 02:37 AM

Wow, We love consultants and use them all the time in our SQF consulting business.

This way we can help our clients in the quickest amount of time and make the process of system development as cost effective and may I say as fun as possible.

Couple of items of note - mopping by hand appears to be incredibly dumb, as you mentioned what an incredible waste of money.

We've got a client thar uses 1 automatic floor machine in a 450,000 sq ft facility with 3 different types of floors/areas and ourside of cleanout and changeover they just have that one machine and we did a risk analysis together with their new sanitation conpany and had nada on cross contamination.

On the subject of challenges to the auditors, get this done before they are off the property. We ibstruct our clients in best ways to challenge. Etc.

Back to not trusting in the consulting process, thinking you are paying too much etc. Like I said we love consultants and if we can ever help to lessen that impression feel free to call on us, we don't work for free but have been known to restore confidence in the process by over delivering and accepting a lot less on the front end as long as our travel expenses were covered.

We love small to mid size operations cause that is what we ourselves are.

Glenn Oster


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Warm regards,

 

Glenn Oster

 

SQF Registered Consultant - Certified for 29 FSC's

Serving clients in: USA, Costa Rica, Panama & Caribbean Islands

International Toll-Free: 800-546-1452

 

http://www.linkedin.com/in/getgoc

 

www.GlennOsterConsulting.com


#14 kmboardman

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Posted 04 January 2017 - 06:32 PM

Wow, We love consultants and use them all the time in our SQF consulting business.

This way we can help our clients in the quickest amount of time and make the process of system development as cost effective and may I say as fun as possible.

Couple of items of note - mopping by hand appears to be incredibly dumb, as you mentioned what an incredible waste of money.

We've got a client thar uses 1 automatic floor machine in a 450,000 sq ft facility with 3 different types of floors/areas and ourside of cleanout and changeover they just have that one machine and we did a risk analysis together with their new sanitation conpany and had nada on cross contamination.

On the subject of challenges to the auditors, get this done before they are off the property. We ibstruct our clients in best ways to challenge. Etc.

Back to not trusting in the consulting process, thinking you are paying too much etc. Like I said we love consultants and if we can ever help to lessen that impression feel free to call on us, we don't work for free but have been known to restore confidence in the process by over delivering and accepting a lot less on the front end as long as our travel expenses were covered.

We love small to mid size operations cause that is what we ourselves are.

Glenn Oster

I am confused, you "love consultants" aren't you a consultant?


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#15 FurFarmandFork

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Posted 05 January 2017 - 06:45 PM

Hi Kmboardman, welcome to the forum! I'm sorry you had such a poor experience implementing the requirements of your certification, it can be frustrating especially when you're trying to make sure you don't mess up any FSIS requirements while implementing, I definitely get that. This response ended up obnoxiously long, so I'll break it out into categories and here's a TL;DR.

 

TL;DR:

  • Yes, it is expensive, and it's going to be whether it's consulting fees or company time, that's what it costs.
  • Yes, it does take sometimes years to get certified, and it shouldn't be easy to "tack on" if you're already under a government requirement. If it was, it would just be a piece of paper with no actual changes made.
  • No, it doesn't make sense for all small companies. Any company can just implement areas of the code that make sense for them even without actually getting "certified", which still means food safety and reduced risk of recall without the added cost of certification. However, if it means you get to sell to a major grocery chain, then there's an obvious ROI for actual certification. Anyone can embrace the principals whether or not you want the full certification and associated costs.
  • Ambiguity is the case with GFSI and FDA, which isn't what you get with FSIS who tells you exactly what they want through policy or your on-site inspection personnel. That's the way they work and it means increased liability for you along with added flexibility.
  • Embrace the ambiguity to make it work for your facility, separate your documentation to make auditing easy and training effective.
  • Find good consultants by identifying ones with industry experience doing what you want in your industry, clarifying that the relationship isn't about regulation research but about content generation, and by providing enough detail that what they make is for you, not generalized. Avoid consultants if you already understand the requirement and want someone to actually generate the program, bring that in-house or reach out to someone in your industry and ask if you can see how they did it.

 

Cost and benefit

 

I don't think the implementation costs you incurred are that abnormal. So while it seems like a lot, and it is, it comes down to whether that's the value of the certification for your company. This pays itself off it if allows you to sell to a major grocery chain who requires it, or if you avoided a $100,000 recall, but the former is easier to prove an ROI on than the latter. It may not make sense for very small companies who won't see these benefits because the volumes are so low recalls are unlikely, and the customer base is small or indifferent to the certification.

 

I know a few companies (mostly low-risk products that don't sell direct to consumer) that ultimately abandoned certification after not seeing a cost-benefit. They instead took the parts of the policies they liked that had an impact on product quality, and let others go that felt like overkill in their facilities (e.g. some of the calibration requirements you mentioned, or verification flows that can feel circular at small companies). This is why SQF is awesome for making the code free and available, anyone can embrace the principals that resonate with them without going through a paywall.

 

With regard to your comment "why do I need a $150/hr consultant to do this". This isn't a hard rule, but consultants generally need to charge at least 3x what they're worth as a salaried employee to cover their expenses, so you're essentially paying for what would be an employee worth 100k salary+benefits or probably somewhere in the neighborhood of 60-70k base salary.

 

Still seems expensive, but that's what SQF practicioners at large companies make, and their only job is to maintain these certifications. So whether it makes sense to bring someone on to maintain this stuff or if it's cheaper to continue outsourcing depends on the level of maintenance your program will need ongoing, but ultimately this is why SQF asks for a practitioner in the code itself, they recognize that the scheme requires labor and put in the requirement so that there's no question that it's going to cost at least as much as another person on staff.

 

On "consultants"

 

The world is full of bad ones, and good ones that didn't give you what you needed. IMEX, good consultants will have industry experience doing exactly what you need, so look for those and not people who worked 5 years, got some kind of education-based certification (e.g. certified food scientist or Certified SQF practicioner), and ran off to be their own boss. Also, really decide whether you are using consultants to consult or generate content. Members of the latter will push for details and generally do a better job if they aren't just copy-pasting generic templates for you in exchange for a fee, you should be able to recognize these because nothing will feel like it "fits" your facility well, and they won't ask for things like your existing paperwork to match the content you're currently using.

 

Consultants who "consult" are typically only good for basic information that you can find yourself if you have simple research skills. Keep in mind that the majority of the work these people do is helping folks who have zero knowledge of the tasks. These are folks like many "label consultants" who will review labels to tell you things like "you forgot to include an allergen statement" or that your net weight has the wrong units. Tons of people pay for this service rather than do the research, and so they have a market for it. However these types of consultants often don't have the skillset or genuine interest in helping you evaluate whether your product qualifies for a "made in USA" claim, except to send you the regulatory text or specify where it could appear on the package. Again, replaceable by someone with strong google-fu, but very helpful to that small bakery who is selling to stores for the first time and is a 3-man operation, no time to research label requirements when you're baking and running the business.

 

This is the reason why most consultant's aren't much help for companies pursuing complex certifications. They're trying to keep their costs to you low, so they don't get into details and just look up the information that you need to be compliant, not actually learn about and integrate it into your business, which takes much more time that a dedicated employee would inherently have, and the majority of small companies making the call really just need some basics covered they don't have the time or experience to investigate themselves.

 

But if you've found a good consultant who is knowledgeable and willing to help you generate content that will be effective at your company, they're only going to be as good as the information you've provided them. You mentioned you're under FSIS so you may have experience with the old label approval process? Even though FSIS used to review every label for every product, recalls for missing allergens still happened all the time. The reason? Missing allergen declarations would have been caught by the reviewer if they were given accurate ingredient statements, but they could only review labels based on what companies provided. So if they missed an allergen or didn't declare sub-ingredients in the approval application, reviewers had no clue that anything was missing. They aren't setup to ask for all of your ingredient labels as part of the approval, since that would be a huge timesink and they aren't there to act as a full time employee for your company. Consultants operate the same way, if you state "I need to comply with X requirements and this is my process", any nuance of missing information will be missing from what they provide, and they will refuse to provide specifics because they don't work there and can't know if you've shared everything.

 

The forums work in much the same way, but with more industry experience shown. This is demonstrated by the first comment after any question usually starting with "can you provide more information?". Since this forum generally assumes that you've already done your google-fu and you're parsing out some specific detail unique to your situation.

 

Speed to certification

 

As far as speed to cerification, you mentioned it seems crazy that it takes 1-2 years. 2 years would be pretty long, and really just demonstrates that these are companies adding it to existing duties rather than prioritizing it with personnel and capital. But in general there are a ton of multi-department moving pieces to implement. I would agree that someone knowledgeable of the code, how it is audited, and on-site at your company could crank out the "program" in a few months with their time dedicated to the task (not just added to an existing position), but actually implementing it effectively and getting people on board? That's what takes forever. You had a leg-up with FSIS with regard to a lot of existing programs and facility maintenance, but getting your maintenance guys on board with tracking plastic, repairs, etc., operators handling chemicals differently, getting suppliers "approved", or adding a label revision control program takes a long time to get going in an effective way.

 

An opposing point here is that these certifications shouldn't be easy, that's what makes them worth it. You may have past experience with getting an AIB sanitation audit or some other audit in place, which is basically a phone call, day audit, some corrections, and done. Those audit's aren't effective and it showed. GFSI schemes are intended to be rigorous and different from a government or other audit. In short, they shouldn't be easy to implement if you're already under FSIS, otherwise that just means that they're useless and a piece of paper attached to zero policy or process changes.

 

Embracing your certification

 

Certifications are more frustrating if you don't embrace them as a culture, which is what I read from many of your comments. You stated (and I agree) that you had your stuff together due to FSIS inspection and the rest feels like overkill.

 

Depending on your volume and product/process risk, it can be! Nothing wrong with admitting the reality on how often an undamaged pair of calipers is actually going to go out of spec. Or how terrible establishments doing nothing right can keep on operating for years without issue or oversight. Take one look at warning letter history to see plants covered in rodent feces operating as per usual, they're definitely not maintaining a register of brittle plastics....

 

They way I tell my employees that SQF is part of our company culture is that it's a collection of "good ideas". Even though the risk is minimal for our process or we have no clue how something could lead to recall, every part of the code is a "good idea" that we should try to embrace, even if it isn't super critical or likely. Food defense is often a soft target, since any sort of personal safety carries a sarcastic "doesn't matter if we do that, someone could just do something during X supply chain step...". Just because the work could be undone, doesn't mean protecting the product under your control is a "bad idea", and that embracing SQF you've agreed to do whatever the code suggests because it can only help, not hurt, food safety, even if it isn't 100% effective.

 

It's a good discussion to have about GMP's as well, when employees question hairnets in the presence of hairy arms, I come back to the "good idea" principal. It doesn't hurt, so why would we throw it out?

 

Making it better ongoing or for other new companies

 

I have some (free! :)  ) recommendations for you to hopefully make this easier/cheaper ongoing, since that was your request in your original post. Keep in mind that based on the information you provided, I'm making the following assumptions:

 

1. You're a 1 man QA department or at least with no technical or regulatory compliance staff reporting to you.

2. Your company is very small (<2mil/year or under 20 employees)

3. You're producing an amenable product that may or may not sell direct to consumer

4. This is your first time implementing this type of audit scheme

 

And of course, it’s still going to be frustratingly vague J

 

First, if you can't do it yourself with your other duties, it sounds like it's time to bring someone new into your QA department to help manage this. A document controller is a good first step who can provide verification on production docs, organize them, and free you up from paperwork management time. Supplier maintenance is a huge timesink that this person can help you with, and can be a multi-purpose employee other departments can rely on as well. The position can be relatively inexpensive, but a hard one to fill since good document control is a special skillset, and not just anyone who can use word is good at managing revision control and organized databases. Find someone who can generate content and organize it in a universal way, not just someone who can follow a flowchart.

 

Second, instead of consultants, try reaching out to others in your industry who already have certification in place and ask how they met the requirements you're struggling with. Identify a non-competitor (e.g. similar product but different market, like if you process heat&serve TV dinners reach out to a jerky producer or some other amenable snack food that might have a similar process flow or shelf life/risk) and get in touch with their QA manager. Most companies under GFSI are committed to food safety in general, and may be willing to let you check out how they organize their FSM (registers, etc.) even if they can't share the proprietary details. It's really easy to remove confidential information and send templates around. I learned what I know from my original training and then by touring several other companies both in and out of schemes to get ideas on different routes of presentation, as well as grilling my auditors (from all agencies and customers) on what they see at other plants. This is a great way to also find out those "standardized" calibration requirements. Your supplier approval program can also be a source of examples of SOP's if you request them as part of your documentation.

 

Note: this can also be a good way to find solid "consultants" who currently have industry jobs but are willing to weigh in on your stuff for free in the interest of food safety in your food sector. E.g. IFSQN members. They can also weigh in with opinions, since they aren't charging for services and carry less liability for your decisions than consultants.

 

Third, embrace the ambiguity. As an FSIS establishment, you basically had your HACCP plan written from a long history of specified process flows, control points, etc. It's a blessing in most cases as it makes government audits simple and the requirements are clear. But it also means there hasn't been a reason to reinvent the wheel or generate your own content for fear that it won't be what's expected from your product/industry. This is the hardest thing to do, because it requires you to consider hazards that have never been an issue, and the reality that you may not be able to describe controls for the new hazards you identify. It also means that you can identify areas of little/no risk and avoid needless requirements there. This is hard for QA to do because we like it when the government tells us what the risk areas are, but that's not the point of the certification. Use the ambiguity as an opportunity to "eliminate" areas of the code that are overkill for your specific facility (e.g. label review for a facility with no potential for undeclared allergens), and be prepared to defend your program when needed, which is why you're present for audits and not just turning in paperwork.

 

Fourth, regarding your desire for information on formatting, register arrangement, policy examples, etc. I see this as another area where FSIS has given the meat industry what FSIS wants to see in the past and your on-site inspector has been a partner in creation to make their job easier (e.g. can you post your holds with this info so I can call you if I have questions?). This isn't they way FDA or GFSI schemes operate, they love to make result-oriented requirements and leave the how up to you. Which isn't simple for QA, as it places all the liability on you with very little guidance, and forces you to defend your FSM to auditors who don't like the way it was organized in your case.

 

My recommendations for anyone creating this stuff for the first time would be this (based on my experience, which is strictly SQF, whom is generally more less detail fixated than BRC).

 

Policies: from a policy level, auditors want to see the material from the code reflected almost word-for-word and bullet-by-bullet in policy, with nouns and verbs altered for your product/process/facility. This doesn't make good training material, but simplifies audits, so I recommend creating "policies" to demonstrate you observe the code for your managers and yourself, and more layman training documents to implement it with your employees. Because you have the code, this has already written itself. A great example is your policy to enforce GMP's, which might include a million bullet points on hand washing, clothing, jewelry, closing doors, etc...but your training may be a simple picture of an employee who is ready for work, demonstrating all the requirements without having to list out 1000 words to prove the policy exists.

 

Registers: Million ways to do this, but simply put, when an inspector arrives you should be able to provide a list of all your SOP's in whatever format. This could be a bunch of file folders on a computer, a handwritten list, quality system software reports, or a table of contents for your binder of SOP's. Any other register (suppliers, labels, training) can be the same type of deal, with the requirement being that it's current and can be brought up quickly, and could be used to find information. My "registers" are my active databases of information that I use daily, since I can print out columns to generate lists quickly.

 

Formatting: like I said, you have two tiers of documents, policy ones for managers and audits, and training tools for employees. Format the policy documents to mirror the code you're trying to follow so that it's easy for the auditor to check those boxes. Format the training docs so that they're helpful to employees and you actually implement the policies in a meaningful way.


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For discussions related to food safety, production, and agriculture. Check out my blog at http://furfarmandfork.com/.

 


Thanked by 2 Members:

#16 SQFconsultant

SQFconsultant

    SQFBRCconsultant

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  • Interests:We specialize in helping food companies to develop & implement SQF & BRC programs in the United States and Panama

Posted 18 January 2017 - 09:27 AM

I am confused, you "love consultants" aren't you a consultant?


YES! I am a consultant and head up our company, but there are certain areas we don't cover, for instance labeling and for that we seek assistance from outside consultants as we choose to serve our client well instead and of giving half butt advice.

We have other consultants call on us when they need assistance.

Glenn Oster


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Warm regards,

 

Glenn Oster

 

SQF Registered Consultant - Certified for 29 FSC's

Serving clients in: USA, Costa Rica, Panama & Caribbean Islands

International Toll-Free: 800-546-1452

 

http://www.linkedin.com/in/getgoc

 

www.GlennOsterConsulting.com


#17 QAGB

QAGB

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Posted 26 January 2017 - 09:41 PM

Hi Kmboardman,

 

I'm sorry to hear your GFSI certification experience was not pleasant. Our first one was not either. 

 

We're BRC certified, and that's what we've been since our initial certification. It started with 2-3 people trying to get procedures and programs revised or totally implemented for a facility with 4 totally different operations and 200+ ingredients. Since we were going from a much easier auditing scheme to the more strict and precise BRC scheme, we were afraid. We had already been told by people that BRC was extremely hard to pass, and that it would take a lot of time to get to certification.

 

At that point, we went with getting consultants. We hired two consultants, and while it was nice to have them on "retainer", they were not as useful as we had hoped. We did, however, get them to help with a bit of documentation. They helped us with our BRC annual review templates, and risk assessment formatting. Everything else was left up to us to figure out. We could ask questions, but they were just there for the guidance; not to necessarily hand us documentation or SOP templates. One of the consultants did get upset that we decided not to use some of the documentation since we felt it didn't apply; so that also was interesting to deal with. We had a gap analysis done by one of the consultants, and they both were there for our initial audit; but we didn't really need them.

 

As a summary, I'd say if you have enough people to break down the GFSI standard of your choosing into parts and focus on implementing each part piecemeal, then that would be the best way to go. We had weekly QA meetings, and went through each BRC clause. Week 1, we might have focused on 1.1. We would take a look at the BRC standard and Interpretation Guide to see what we had and what we didn't have. We would assign work to each other, and work on that for a week. The next week, we would update on 1.1, and start working on the next clause if we were ready. Consultants are helpful if you have a very small QA Dept., like Earth2O said, or you're just starting out on Quality certifications in general (if you never had AIB, GMA SAFE, GMP or any other food safety audit at all). It also depends on the consultant as well. Some consultants will get caught up in unnecessary complaints -- like floor scrubbers as mentioned above. Other consultants have been through the process and know what most auditors will look for; and won't nitpick at your process. I guess it's more "the luck of the draw".

 

I think if we had ever really needed help on creating a typical document, we probably could have gotten that from the consultants we had. We just had most things already in place, and what we didn't, BRC spells out fairly well what is required anyway. It's just a matter of adapting it to your process; as was said above.

 

If you were to have questions about anything that seemed vague, you could definitely come to IFSQN because many of us have already been in your position, and would likely have answers for you. Free consultation! :)

 

QAGB


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