9 replies to this topic

[Jonn Cotter_33853]

We are having our first SQF audit - Desk then Certification, the first week of April.  I am putting together missing programs we may need.  Does anyone have a template of what the Code for Environmental Monitoring 2.4.8 would look like?  We do have raw ingredeints such as flour, choc chips and such.  Does it need to be very indepth or is there something I can get through the audit with?

Thanks

 

[MsMars]

It would depend on the type of products you produce, your process, etc.  Do you do any kind of environmental surface swabbing or product testing for pathogens/indicators?

[Jonn Cotter_33853]

We do not currently do any swabbing or product testing for pathogens.  We purchased the company in Feb and began production in our facility in May.  We have not as of yet put anything in to place.  I guess my question is will we take a big hit for SQF for not having this already implemented?

[FurFarmandFork]

We do not currently do any swabbing or product testing for pathogens.  We purchased the company in Feb and began production in our facility in May.  We have not as of yet put anything in to place.  I guess my question is will we take a big hit for SQF for not having this already implemented?

 

2.4.8 Environmental Monitoring

2.4.8.1 A risk-based environmental monitoring program shall be in place for all food and pet food manufacturing processes. 

2.4.8.2 The responsibility and methods for the environmental monitoring program shall be documented and implemented.

2.4.8.3 An environmental sampling and testing schedule shall be prepared, detailing the applicable pathogens or indicator organisms to test for that industry, the number of samples to be taken and the frequency of sampling.

2.4.8.4 Environmental testing results shall be monitored and corrective actions (refer to 2.5.3.1) implemented where unsatisfactory trends are observed.

 

 

 

 

If you have not addressed the element anywhere in your policies, it's a potential for a major. If you have addressed it and not implemented effectively yet, would be a minor. This is clarified in the auditing guidance:

 

An environmental monitoring program must be in place for food processes that are handled, exposed, stored, processed or packed. This program should be included for food processes of all risk levels.

 

The reference to the environmental monitoring program is self-explanatory, but is worth repeating as it is considered mandatory for areas in which high risk food is processed, handled or exposed. Failure to have an effective environmental monitoring program will result in a major non-conformance.

 

 

You don't have to be swabbing for pathogens specifically if your sampling plan indicates that they aren't relevant to your product, however it sounds like your final product would definitely require a pathogen EM program You mentioned flour and choc chips. Aspen hills and blue bell both had issues with listeria in cookie dough that resulted in the former closing shop. Flour has been implicated in multiple E. coli outbreaks in the past few years, and chocolate chips have been recalled in the past for salmonella in chocolate chips. 

 

Get a program made and collect at least one set of data before your audit to demonstrate you've developed and implemented a program.

[Jonn Cotter_33853]

Thank you so much.  So my question is, if we get Certificates of analysis from the flour and choc chip suppliers would that be aceptable?  or should we be sending out samples of the actual raw materials to say Silliker?

[Charles.C]

We do not currently do any swabbing or product testing for pathogens.  We purchased the company in Feb and began production in our facility in May.  We have not as of yet put anything in to place.  I guess my question is will we take a big hit for SQF for not having this already implemented?

 

Feb 2017 ??

 

I only query since if the "May" is a typo IIRC you need data for at least 3 months production prior to audit.

[Jonn Cotter_33853]

Yes Feb 2017.  May 2017 is when production began in our facility.  What is llRC Charles?  Also production has been down since the beginning of March, slow season at this time.  

[FurFarmandFork]

Feb 2017 ??

 

I only query since if the "May" is a typo IIRC you need data for at least 3 months production prior to audit.

 

@Charles, I've seen this elsewhere but have never seen it in the code/auditing guidance, is there a reference to this 3 months guideline? I've gotten away with less than 3 months implementation in a lot of clauses, especially for brand new programs (such as many of those we didn't have guidance for until November of last year).

 

 

@John Cotter, your environmental program has nothing to do with product or raw material testing. It's about testing your production environment. It sounds like you need a lot more information on this subject, and I highly recommend watching these two webinars (free) from IFSQN to learn more, as this is more than just an audit requirement, but an important tool in your food safety approach.

 

 

http://www.ifsqn.com...-pathogens-r130

 

http://www.ifsqn.com...tal-monitoring/

[Charles.C]

@Charles, I've seen this elsewhere but have never seen it in the code/auditing guidance, is there a reference to this 3 months guideline? I've gotten away with less than 3 months implementation in a lot of clauses, especially for brand new programs (such as many of those we didn't have guidance for until November of last year).

 

 

Hi 3F,

 

Memory was 1month out in a referenced sense, perhaps less in actuality (see below).

 

From the SQF8 (SQF7.2 was same) Manufacturing Code -

 

Implement the SQF System – implement the prepared policies, procedures, work instructions and specifications,
and keep records to demonstrate compliance to the relevant modules of the SQF Food Safety Code for
Manufacturing.  In other words, “do what you say.”  SQFI recommends that a minimum of two months of records is
available before a site audit is conducted.

 

Also see this interesting 2017 thread - Posts 2, 4, 14, 17-23  :-

 

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

 

The sub-link in post 23 of above link implies (eg see posts 6,15 of sublink)  that <3 months may also generate some auditor difficulties.

[Charles.C]

Yes Feb 2017.  May 2017 is when production began in our facility.  What is llRC Charles?  Also production has been down since the beginning of March, slow season at this time.  

 

OK, no problem then.

 

IIRC = "if i recall correctly", various other popular abbreviations  here -

 

http://www.ifsqn.com...-abbreviations/