4 replies to this topic

[bretterin]

We are SQF level 3 meat processing facility, and I need help.  Our SQF auditor wrote a major non-conformance on our quality plan.  We use color as our critical quality point (QCP).  In short, we check the color of the sausage after it exits the smokehouse, and off color product is rejected.  He was OK with this CQP, but he wants us to validate it.  Does anyone have any suggestions on how I can do this?

[FurFarmandFork]

Hmm, so a validation in this case would be a review/study that shows the procedure will work as expected when all things are good to go.

 

Potential solution 1:

I would collect several off color sausages on the "edge" of acceptability and make your operators who perform the task determine what's good and what isn't.  Then keep a record of that study that shows that under normal conditions the visual check should be sufficient to prevent off color sausages.

 

Potential solution 2 (my preference):

Do a quarterly or annual review of all customer complaints related to issues you identified as QCP's. Have your controls been effective in years where you had these procedures in place? If so then I would say you've validated them using past history and continue to verify they are effective moving forward. Any changes will be re-validated using complaint data from the period after the change was made.

[Charles.C]

Hi bretterin,

 

I presume you are referring to clause 2.5.1

 

I note that you are also required to verify the CQP's critical limits. (2.5.2.2).

 

Sadly, as previously, multiply, discussed on this Forum for ver. 7.2, SQF has chosen to go it's own quirky way on the topic of Va/Ve thereby generating a history of contentious audits.

 

If you care to search the Forum a little you will see what i mean. The pragmatic approach is probably to follow what other people hv tried in the past and hope that yr current auditor is on the same page as theirs was.

 

I wish you Good Luck !

[Ryan M.]

Use your customer / consumer complaints and internal records of rejected product due to off color.  This would "set the edge" or the limits for your validation.  You probably already do this, but have colored pictures of the sausage of what is "acceptable" or "unacceptable" for sausage color.

[Charles.C]

The debate over interpretation of  "Validation" is that previously SQF/7.2  claimed to follow (updated) Codex (which would exclude option2 in Post2) but in practice often audited via interpretations based on older Codex publications.  The latter would currently be regarded by Codex as Verifiication activities.

 

However, interestingly, SQF8 now seems to have abandoned any attempt to modernise as illustrated by changes in the Glossary definitions as quoted below -
 

SQF 7.2

As defined in the NACMCF Hazard Analysis and Critical Control Point Principles and Application Guidelines, Adopted August 14, 1997 as amended from time to time and the Food and Agriculture CODEX Alimentarius Commission Hazard Analysis and Critical Control Point (HACCP) – Guidelines for Implementation and Use, ALINORM 97/13A as amended from time to time. Essentially validation as applied to control limits seeks to prove that the intended result was achieved and that it actually worked.

 

 

SQF8 Manufacturing

As   defined   in   the   Food   and   Agriculture   Organization’s   CODEX   Alimentarius Commission.  Hazard  Analysis  and  Critical  Control  Point  (HACCP)  System  and Guidelines  for  its  Application  –  Annex  to  CAC/RCP  1  –  1969,  Rev.  4-2003),  –  “A system, which identifies, evaluates and controls hazards which are  significant for food safety.  Essentially  validation  as  applied  to  control  limits  seeks  to  prove  that  the intended result was achieved and that it actually worked.

 

 

PS - In case any one is vaguely curious over previous discussions on this tortuous topic can see -

 

http://www.ifsqn.com...ng-methods-etc/