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SQF Version 7 - Raw & Packing Materials 2.3.2.4


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Snookie

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Posted 17 April 2012 - 06:08 PM

Version 7, 2.3.2.4; says"...Validation of raw materials and ingredients shall include Cerificate of conformance; or certificate of analysis; or sampling and testing. In produce, these would not be the norm, only some commodities do pathogen testing. Therefore, what would those of us who do produce in commodities not testing use to meet this criteria?


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Simon

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Posted 25 April 2012 - 07:56 PM

BUMP for Snookie - please help if you can.

Thanks,
Simon


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Snookie

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Posted 26 April 2012 - 03:10 PM

Thanks Simon....but am good, think I have figured it out. But am disappointed did not hear any other feedback :dunno:


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Tim1

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Posted 05 May 2012 - 12:57 PM

Hello, just wanted to add something since no one has done so. We are fruit and veg packing facility, and some of the things I request from our suppliers is migration testing for all packaging suppliers and we also do tissue testing, water tests, etc. from all our raw suupliers. The code only requests and COA or COC starting in July 1st which in turn is alot easier for suppliers to provide vs the migration testing and other tests I stated. Hope this helps. :bye:



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Posted 07 May 2012 - 10:10 AM

Dear Snookie et al, et al,

But am disappointed did not hear any other feedback


Sorry for your disappointment but the most likely reason is that the OP contained no mention of the specific products or process concerned. Perhaps you thought it was obvious.
Rightly or wrongly, it is often more likely that people will respond when they can identify with the actual situation.

Rgds / Charles.C

Kind Regards,

 

Charles.C


Snookie

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Posted 07 May 2012 - 03:02 PM

Hello, just wanted to add something since no one has done so. We are fruit and veg packing facility, and some of the things I request from our suppliers is migration testing for all packaging suppliers and we also do tissue testing, water tests, etc. from all our raw suupliers. The code only requests and COA or COC starting in July 1st which in turn is alot easier for suppliers to provide vs the migration testing and other tests I stated. Hope this helps. :bye:




Am not worried about the packaging that is easily covered and most companies are readily prepared with migration standards. My concern was the phrase, " ...and testing." Not sampling or testing but and. While leafy greens have started pathogen testing in their fields, most other commodities, fruits, carrots, you name it...do not do that kind of testing. Combine that with the research shows that TPC, yeast & molds etc have little value to us in terms of quality or safety. So what kind of testing should be done? But that is perhaps where I was not seeing "the forest for the trees". When thinking of testing, my brain went to micro testing as we do so much it in our plant, be it in sanitation or other areas. Think the simple answer is the "test" is temperature. It is a simple test but it is a test and a reasonable given the product.

Edited by Snookie, 07 May 2012 - 03:03 PM.

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Charles.C

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Posted 08 May 2012 - 07:57 AM

Dear Snookie,

Thks for the feedback. I think I understand yr OP more clearly now. Not a user of SQF myself but i will try to roll the ball a little. :smile:

I presume we are talking about (essentially harvested/unprocessed) primary production of fruit/vegetables at the beginning of the process to reach the transition point from pre-farmgate to post-farmgate stage. ?

The ( ver.7/2012) para which you mention is (slightly expanded) -

2.3.2.4 Raw and packaging materials and ingredients shall be validated to ensure Product safety and quality is not compromised and the material is fit for its intended purpose. Validation of raw materials and ingredients shall include certificate of conformance; or certificate of analysis; or sampling and testing.
2.3.5.1 Finished product specifications shall be documented, current, approved by the supplier and their customer, accessible to relevant staff
and may include:
i. Microbiological and chemical limits;
ii. Labeling and packaging requirements;
and
iii. Product quality attributes.
2.3.5.2 A register of finished product specifications shall be maintained.



For context I include below (minus packaging related) the corresponding paras of the previous (now obsolete) sqf 1000/2000 codes. I presume you were using 1000.

(1000)
4.3.1.1 Specifications for raw materials purchased that impact on finished product safety and quality shall document and keep current.
4.3.1.2 A register of raw material specifications shall be maintained.
4.3.4.1 Finished product specifications shall be documented, current, formally agreed with the customer, and accessible to relevant employees.
4.3.4.2 A register of finished product specifications shall be maintained.
4.4.1 Food Legislation (Regulation)
The Producer shall ensure that, at the time of delivery to its customer, the product supplied shall comply with the food safety legislation that applies to the product and its production in the country of its origin and destination.



(2000)
4.3.2.1 Specifications for raw materials and ingredients that impact on finished product safety and quality shall be documented and kept current.
4.3.2.2 A register of raw material specifications shall be maintained.
Note: Raw materials include but are not limited to additives, hazardous chemicals and processing aids.
4.3.6.1 Finished product specifications shall be documented, current, approved by the supplier and their customer, accessible to relevant staff
and include:
i. Microbiological and chemical limits;
ii. Labeling and packaging requirements;
and
iii. Product quality attributes.
4.3.6.3 A register of finished product specifications shall be maintained.

It appears that SQF are “struggling” to put together an appropriate, modernistic (eg "validation" :smile: ), all-in-one combo text. Not surprising to experience some difficulty in view of the rather different scenarios / scopes involved. :smile:

I suspect that the word “testing” is intended to match the "validation" requirement assuming that the other offered alternatives are not available. If so, yr idea of a temperature check may be (somewhat) insufficient. :smile: I hv previously encountered (non-SQF) complications of this sort when purchasing raw, unprocessed seafood. Was able to manouevre via the approved supplier route using mutually agreed raw material specifications (which i assume you must already have) and some (very) basic organoleptic measurements by the supplier. Micro.measurements for received input lots were (technically) out of the question and this is surely a common scenario.

(I agree with you that many micro.textbooks consider that micro.regs for earthy produce are not meaningful however in view of the absence of later bactericidal elimination steps plus pathogen problems of recent years this might now be a more sensitive issue. As you say, for some well-known leafy products, testing / special pathogen control procedures are already implemented.)

What was SQF's previous viewpoint for the raw material used as input for postgate processing - any micro.data expected ?? Hopefully not. :smile:

I am guessing that other people here must surely hv already faced this question ? Or is everyone a guinea pig for SQF at the moment ?.

Rgds / Charles.C

Kind Regards,

 

Charles.C


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Snookie

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Posted 08 May 2012 - 03:24 PM

Dear Snookie,

Thks for the feedback. I think I understand yr OP more clearly now. Not a user of SQF myself but i will try to roll the ball a little. :smile:

I presume we are talking about (essentially harvested/unprocessed) primary production of fruit/vegetables at the beginning of the process to reach the transition point from pre-farmgate to post-farmgate stage. ?

The ( ver.7/2012) para which you mention is (slightly expanded) -



For context I include below (minus packaging related) the corresponding paras of the previous (now obsolete) sqf 1000/2000 codes. I presume you were using 1000.




It appears that SQF are “struggling” to put together an appropriate, modernistic (eg "validation" :smile: ), all-in-one combo text. Not surprising to experience some difficulty in view of the rather different scenarios / scopes involved. :smile:

I suspect that the word “testing” is intended to match the "validation" requirement assuming that the other offered alternatives are not available. If so, yr idea of a temperature check may be (somewhat) insufficient. :smile: I hv previously encountered (non-SQF) complications of this sort when purchasing raw, unprocessed seafood. Was able to manouevre via the approved supplier route using mutually agreed raw material specifications (which i assume you must already have) and some (very) basic organoleptic measurements by the supplier. Micro.measurements for received input lots were (technically) out of the question and this is surely a common scenario.

(I agree with you that many micro.textbooks consider that micro.regs for earthy produce are not meaningful however in view of the absence of later bactericidal elimination steps plus pathogen problems of recent years this might now be a more sensitive issue. As you say, for some well-known leafy products, testing / special pathogen control procedures are already implemented.)

What was SQF's previous viewpoint for the raw material used as input for postgate processing - any micro.data expected ?? Hopefully not. :smile:

I am guessing that other people here must surely hv already faced this question ? Or is everyone a guinea pig for SQF at the moment ?.

Rgds / Charles.C





I am thinking your guess is correct that we all guinea pigs for the SQF at the moment. :helpplease: The requirement I am talking about is new, just came out in February. Before we could rely on our specification requirements, now the change says Letters of conformance or testing and sampling.


You may be very well right about the testing equating with validation, but there are auditors with a very strict definitions of words, so testing is what they are going to be focused on and temperature may not be viewed as sufficient. Which leads to my dilemma. We take fresh fruits and vegetables, clean them, cut and sale them. I am all for food safety and meeting requirements, but think we also need to balance out all of this with some sanity. No one is going to be healthy or well fed, if in the drive to safety we make healthy food even more expensive than it is now. :doh: Okay am done venting. Going forward just need to figure out how to meet this requirement with some sanity.

Edited by Snookie, 08 May 2012 - 03:25 PM.

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Charles.C

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Posted 09 May 2012 - 04:24 AM

Dear Snookie,

Have done a little more scrutinising of the SQF standards, recent past and present. Again the following only refers to food segment, not packaging.

AFAI can see, no definition of the following terminology exists in the above SQF standards but seems to me that the Certificate of Conformance (COC) could be suitable (intended?) for yr situation. (BTW, I noted that this terminology is not new to the packaging segment.)

A variety of “definitions” of COC exist but, in the simplest format, I saw these for COC and COA, the latter for comparison.

A COC is my company saying to yours - "Our product was made in accordance with your required specifications"

A COA is my company saying to yours - "The material I supplied to you has been analyzed to XXX standard or procedure and here are the results:"


I assume that yr supplier (or both of you) are able to validate that, in general, the supplied goods will meet yr mutually agreed specification. (this is analogous to validating critical limits in HACCP).

Unlike the COC, Validation does not normally involve a lot-by-lot documentation however SQF are well-known to have some rather strange views on this topic (eg see SQF glosssary / this forum) therefore a check will be required .

Maybe you hv already analysed / ruled out this option :smile: ?

Rgds / Charles.C

PS I attach a (non-food) sample COC, obviously the first 2 lines would be nearer the present format requirements.

Attached File  CertificateOfConformance.pdf   160.65KB   128 downloads

PPS - of course, in many situations, the validation would presumably be available via organisations like Eurepgap :rolleyes:

Kind Regards,

 

Charles.C


pices

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Posted 10 May 2012 - 02:20 PM

is this the same for packageing of fresh and frozen seafood for distribution to retail stores and restruants???





Hello, just wanted to add something since no one has done so. We are fruit and veg packing facility, and some of the things I request from our suppliers is migration testing for all packaging suppliers and we also do tissue testing, water tests, etc. from all our raw suupliers. The code only requests and COA or COC starting in July 1st which in turn is alot easier for suppliers to provide vs the migration testing and other tests I stated. Hope this helps. :bye:






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