10 replies to this topic

[stsqf]

Just curious if anyone with SQF auditing experience can answer this question for me:

Do they conduct the traceability exercise during the document review or facility audit? My assumption is the facility audit due to the fact that you do not have to bring the auditor to your site to have the document review portion of the audit.

Also, if you have any experience with what they ask you to be able to trace - any insight would be helpful! We are able to trace product one up and one back - just curious how extensive they are and if they look more for time or accuracy i.e. extensive ingredient recall in less than 2 hours.

Thanks for your help in advance!

[Inesa]

Dear stfqs,

I don't have any answers for you.

But I've just made a topic about Traceability in Legislation forum. There you can find theoretical stuff about traceability if you don't feel you know enough about it. It's nothing big, but it might help and maybe give some ideas for the future.

Best Regards
Inesa

[Simon]

Just curious if anyone with SQF auditing experience can answer this question for me:

Do they conduct the traceability exercise during the document review or facility audit? My assumption is the facility audit due to the fact that you do not have to bring the auditor to your site to have the document review portion of the audit.

Also, if you have any experience with what they ask you to be able to trace - any insight would be helpful! We are able to trace product one up and one back - just curious how extensive they are and if they look more for time or accuracy i.e. extensive ingredient recall in less than 2 hours.

Thanks for your help in advance!

In my experience of audits the auditor will pick a finished goods item or purchased part and ask you to conduct a trace excercise there and then on site and then audit the documentation. Usually you pass the traceability number (batch code etc.) on to a colleague and they run around like a headless chicken whilst you and the auditor continue with the audit.

One foward and one back is the norm and if everyone does the same 'effectively' the links in the chain are unbroken from farm to fork. I'm not sure about expectations on time for SQF, but if I were the auditor and you got the trace code in the morning I would expect to have an efficient and effective review of all trace information within an hour or so, at least before I left in the afternoon; or else I'd be leaving a nonconformity.

Regards,
Simon

[Cathy]

I have done a few SQF audits, and I work for multiple certification bodies in the U.S. I expect to be able to review the results of a trace exercise you have done previously. If what I receive for the desk audit does not cover as much detail as I prefer, i will ask you to show me that you have the systems in place to conduct solid tracing for fnished product, raw materials and packaing. I do not require a trace exercise conducted during the on-site audit. It's a very busy time - we have enough to do. The current audit file for the desk audit asks if the effectiveness of the trace system is tested annually and if this has been done.

[Simon]

Hi Cathy,

I do not doubt it’s done the way you describe, but to be honest I think it’s a cop out by the standards owners.

The only time a real traceability action needs to be carried out is when there is a problem or crisis when the traceability system needs to react quickly and be carried out efficiently and effectively. Anyone can put together a nice traceability paper chain at their leisure for an auditor. I suppose it’s a bit like the planned v’s unannounced audits situation; the advent of unannounced audits will ensure that food businesses live the system rather than running around a few days before (and just in front and around the corner from the auditor) dotting the i’s crossing the t’s and straightening everything up...that’s not what food safety is about!

If a traceability exercise was done on the day of the audit (and I argue that is possible and reasonable) the auditee would be testing and retesting their traceability system rigorously prior to the audit. Like I said earlier if the batch code was chosen at the start of the day and the stop watch pressed this would be achievable and the review of paperwork should only take 15-30 minutes. For me conducting such a live exercise provides far more value than looking at some of the other less critical paperwork or systems.

Regards,
Simon

[cocoabeanny]

Hi,

I am not familiar with SQF Audits but I can tell you my experience from ISO 22000 and customer audits (B2B only).
A few customers are asking to see the results of a conducted traceability exercise, but most of them want to see a real case. Often they bring the code of a product they received from our plant and ask for the tracing. As we have a continueing production and no IT system, all on paper forms we can do it within 3 hours, that was acceptable for everyone so far.
In my previous job I worked for an american company and there we did every brand every year. the Timeline was 4 hours. the business unit contacted the plant and the local warehouse and everything needed to be ready in 4 hours.

In the last ISO audit we experienced for the first time that the auditor asked from a finished product to the raw material and as this was a much larger pile- as we have to put some buffer time because of the continous production-she then asked which where the other end products produced from this pile. From our point of view this were in fact 2 tracings. Because we understoof 1 step up and one step down, that we know where the raw material comes from and we know where the finished good goes to.

Hope my describtion helps you a bit.

regards
Beanny

[stsqf]

Thanks for all the responses!

Just wanted to see what others experienced because ultimately - standard or no standard - it still seems like it is the discretion of the auditor. We had a 3rd party audit last week and the auditor (who is also an SQF auditor) performed a mock recall and mentioned that if she were doing an SQF audit she would ask to a traceability exercise on an ingredient. "Specifically an ingredient that is used in small quantities as that is the true test to any traceability program." However, she also said that when doing so they are looking less at the amount of time it takes to trace but more at the percentage you are able to trace.

I agree with Simon that with the right systems in place you should be able to trace in 15-30 minutes - we are transitioning to a database that will be able to accomplish this but for our SQF Certification audits this will not be in place quite yet.

(Side note to Cathy - we are having our SQF auditor come to our site for the document review as opposed to submitting all documents/records - I would think it should be treated the same either way however)

[Tatiana]

Hello there!

I`v been tru ISO 22000 and BRC audits for 5 years. They can either:
*Bring a container or package from the market and ask you to give them the trace back information in less than 2 hours. Ahd they will wait by your side, looking at all the documents!
*Pick up a container from the warehouse and again, ask you to give them the trace back info
*Look at your incidents, CAPA logs, 1-800 line logs, etc and pick up a query and again..... ask for the info and wait by your side!!!

For the trace forward they can either:

*Pick up a raw material lot number from the warehouse
*Ask for a material that has been recently involved on a recall and u use (like, i.e. cilantro, cheese, etc) and pick a day and .... Voilà!!!

I hope that information has been useful!!!! Good Luck!!!!

:)

[Charles.C]

Dear stsqf,

it still seems like it is the discretion of the auditor.

More likely Yes and No in my opinion. It is probable that there is a guidance for SQF auditors somewhere which spells out the (min - max) range of requirement to comply to the standard. My guess is that the procedure already described above was the minimum.

Cathy ??

Rgds / Charles.C

[Cathy]

I agree with the value of the on-site or on-the-spot trace exercise. It is the better way - it just isn't technically required yet - as far as I know. There is not a guidance or directive that adddresses it and the auditor training for SQF didn't really go over this - so - again - we are at auditor or cerrification body discretion.

On a side note...do you test beyond the trace? I find this is something many forget. The SQF code asks for a trace exercise (4..6.2.1) and in a sepearte place asks if the recall plan is tested (4.6.3.3) so I view these as two different things...can you trace product - and - could you actually bring it back efficiently based on the way your program is designed?

[Simon]

I agree with the value of the on-site or on-the-spot trace exercise. It is the better way - it just isn't technically required yet - as far as I know. There is not a guidance or directive that adddresses it and the auditor training for SQF didn't really go over this - so - again - we are at auditor or cerrification body discretion.

On a side note...do you test beyond the trace? I find this is something many forget. The SQF code asks for a trace exercise (4..6.2.1) and in a sepearte place asks if the recall plan is tested (4.6.3.3) so I view these as two different things...can you trace product - and - could you actually bring it back efficiently based on the way your program is designed?

That's a very good point Cathy. One is theory and one is practice.