Specification requirements for products supplied by own Organization?

Hi everyone,

We are in the process of certifying 16 plants within the same organisation. So far we managed 9 certifications (SQF2000, level 2) with a few minor non conformances. Last week one of our auditor raised a non-conformance for not having customer specifications for "In Process" product that are transfered from one plant to another.

These "In Process" product are liquid dairy byproduct (ie: liquid whey), that are send to other facilities to be dried and packed in 25kg bags and 1000kg totes and then sold to clients.

My questions are the followings: "Does SQF consider the liquid whey to be an "In Process Product" or a "Finish product" for the first facility? Since this product will be transformed within the same organisation do we really need customer specification or can internal specification be sufficient? We already have the internal specification, but our auditor insisted that we needed finish product specifications for customers (under SQF Code 4.3.6.3) since the first plant (seller) is shipping to a second plant (buyer).

Or can we object to that the observation?

Thanks

DenisB

Hi everyone,

We are in the process of certifying 16 plants within the same organisation. So far we managed 9 certifications (SQF2000, level 2) with a few minor non conformances. Last week one of our auditor raised a non-conformance for not having customer specifications for "In Process" product that are transfered from one plant to another.

These "In Process" product are liquid dairy byproduct (ie: liquid whey), that are send to other facilities to be dried and packed in 25kg bags and 1000kg totes and then sold to clients.

My questions are the followings: "Does SQF consider the liquid whey to be an "In Process Product" or a "Finish product" for the first facility? Since this product will be transformed within the same organisation do we really need customer specification or can internal specification be sufficient? We already have the internal specification, but our auditor insisted that we needed finish product specifications for customers (under SQF Code 4.3.6.3) since the first plant (seller) is shipping to a second plant (buyer).

Or can we object to that the observation?

Thanks

DenisB

4.3.6.3 asks if you have a finished product specification register.

Sounds like it's not an in-process product.

Thanks for your comment Glenn,

The arguments from the auditor was that if the product leaves the facility to be transformed by another plant, it can't be considered "in process". If it were to be transformed within the same facility, then OK, it is "in process".

We manufacture several type of ingredients for bakeries and confectionaries, but not all of our facilities do the same operation - therefore, some of our operation generates ingredients that need further processing within the same organisation (different facility but same company). True, for the site, it is a finish product shipped in bulk for futher processing, but for the company, it is considered an "in process" product.

Regards

DenisB

4.3.6.3 asks if you have a finished product specification register.

Sounds like it's not an in-process product.

If DenisB's company has an internal specification for the 'in process" product, why do they need a "customer specification"? I mean what is the difference? The letterhead the document is printed on, how well presented it is? As long as the relevant information is available, who cares what format it is in, as long as it is a controlled one. I mean what is the risk the auditor thinks you will avoid by using a customer spec as opposed to the internal one you currently have?

i always thought "customer specs" were part of the sales and marketing approach for the company as well as a valuable information tool, which is why you take the care to make them presentable etc. If its internal, i dont care about the marketing speal and why i should consider using "product xyz to improve the look and flavour of my finished product and enhance my customers satisfaction and improve yields etc etc etc".

It should be fairly obvious i would challenge this NCR.
My 2 cents worth.

Bawdy.

What you have reported demonstrates another reason why it is necessary to re-assess how auditing is done today. I am sure that all auditors may not see it the same way as your auditor. Why this is the case is known but nothing is being done about it.

I will say you can take this to arbitration and, if common sense rules, you are likely to have the non-conformance removed. If it is not removed, it will be a clear case of abandoned common sense.

This happens sometimes and we end up with temper tantrum auditing that insists: “It says so right here. Therefore, you are non-compliant.”

My vote is: if your internal specification is complete for the type of product, it meets the requirement.

I can't imagine that this couldn't be overruled. If the liquid whey is further processed at the 2nd plant to process into finished final product it's WIP. Who has specs for WIP???

If DenisB's company has an internal specification for the 'in process" product, why do they need a "customer specification"? I mean what is the difference? The letterhead the document is printed on, how well presented it is? As long as the relevant information is available, who cares what format it is in, as long as it is a controlled one. I mean what is the risk the auditor thinks you will avoid by using a customer spec as opposed to the internal one you currently have?

What you have reported demonstrates another reason why it is necessary to re-assess how auditing is done today. I am sure that all auditors may not see it the same way as your auditor. Why this is the case is known but nothing is being done about it.

Dear GCSE-FHP and Bawdy.
please let us relax. We do not know what is the internal spec of DenisB and neither do we know what is in his customer specification.
There are a lot of organisations, where the internal spec is very summier and only includes a product name and article number.
Perhaps the transport to the second factory takes a while and legal requirements say that a specification is needed for products transported.

DennisB can you provide us with information regarding the content of the internal spec and the content of an external spec? What are the differences between these documents, within your company?
Do you also provide products from the sites to other sites/organisations or are all the products produced on this site dispatched to a second site?

The arguments from the auditor was that if the product leaves the facility to be transformed by another plant, it can't be considered "in process". If it were to be transformed within the same facility, then OK, it is "in process".

If all the sites are certiifcated separately, this is definitely true.
If the product "whey" could also be supplied to another factory, there need to be a specification.

4.3.6.3 asks if you have a finished product specification register.

Sounds like it's not an in-process product.

Just to clarify - Your Auditor is correct. Regardless of whether or not the product is going to another one of your plants for further processing, the product leaving your facility is therefore a finished product and should have been on your finished product register along with the specifications (or reference to same).

Dear Madam A. D-tor',



Thank you for your reply, the liquid whey we ship from this particular facility to another of our facility (one hour away - by transport) is the by-product from cheese manufacturing. A silo of liquid whey can be filled from the manufacturing of various types of cheeses (cheddar, mozzarella, colby, monterey jack...), therefore, composition may be different from one silo to another. But the dried product (at the second facility) will always be the same (mostly caseins, lactose and a bit of dairy fat).

This is within the same company. For management, it can be compared to transfering from one sector of the company to another sector. This liquid whey is not sold in any way within the company nor to any customers. As the SQF Code call for "Full Finish Product Specification" - I dont see how the auditor could have raised a non compliance for this. The product may leave the facility but never leaves the companies control.

The only internal spec we have is storage time and storage temperature controls, the liquid whey is never analysed - has no physical or microbiological specifications as it is an in process product. All our liquids are shipped within our organisation - never leaves our control.

We do manufacture and sale other products to other companies(customers) all these have full specifications as these are sold for retail or further transformation.

Regards



DenisB

Dear GCSE-FHP and Bawdy.
please let us relax. We do not know what is the internal spec of DenisB and neither do we know what is in his customer specification.
There are a lot of organisations, where the internal spec is very summier and only includes a product name and article number.
Perhaps the transport to the second factory takes a while and legal requirements say that a specification is needed for products transported.

DennisB can you provide us with information regarding the content of the internal spec and the content of an external spec? What are the differences between these documents, within your company?
Do you also provide products from the sites to other sites/organisations or are all the products produced on this site dispatched to a second site?


If all the sites are certiifcated separately, this is definitely true.
If the product "whey" could also be supplied to another factory, there need to be a specification.

Madam A. D-tor may be right. I may have misunderstood DenisB and over stated the case in some respects.

So tell us again DenisB,

Do you sell any of this "In Process" product (liquid dairy byproduct - liquid whey) to customers outside of your company or do you use all of it within your company?

Never mind. I saw your answer after I posted the question above. My understanding of your first post appears to be correct. Since you do not sell the in-process product to customers outside of your company, I did not over state the case in my previous post.