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(A) SQF Practitioner: definite vs. indefinite article


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#1 bacon

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Posted 04 September 2012 - 03:33 PM

As the code specifies:
_____________
2.1.2.4 The senior management shall designate an SQF practitioner for each site with responsibility and authority to:
i. Oversee the development, implementation, review and maintenance of the SQF System, including food safety fundamentals outlined in 2.4.2, and the food safety plan outlined in 2.4.3.
ii. Take appropriate action to ensure the integrity of the SQF System; and
iii. Communicate to relevant personnel all information essential to ensure the effective implementation and maintenance of the SQF System.
_____________

This issue make make more sense in this context:

The flood of demand from retailers for GFSI benchmark audit certifications seems to be causing a newly created role (that is typically held buy the QA Manager). As I see it, in the US, many food packers/processors that are new adopters of GFSI benchmarked standards the QA Managers already having too much on their plates and do not have the bench-strength to manage the global standard documentation no top of their other personnel and food safety managing duties. Hence one can find positions like “document control specialist”, “HACCP Coordinator”, “GFSI Coordinator”, “SQF Practitioner”, “BRC Compliance Coordinator” etc. (all requiring GFSI managing experience and HACCP Certification) that food packers/processors are seeking to fill.

In the food proceeding facilities I am currently working at, they have designated one person as the "SQF practitioner" by position title to manage the SQF System. So the problem I am finding is: the SQF practitioner's (separate from the QA Manager management role) responsibilities, per the language of the SQF Code, can be quite large for one person to do alone (for example, potentially cause much redundant signage for documents that have already been reviewed and verified).

(In the past I have primarily work with BRC and they seem to have more of a "team" effort emphasis when it comes to assuring food safety/quality).

So, per the SQF Code: "an SQF practitioner", "an" is an indefinite article. Hence, one could argue that this allows multiple SQF Practitioners for verifying/validation the many aspects of a facility's Food Safety System (even though the code runs rampant with: shall be done by "the SQF practitioner").

Does anybody see any flaws in this reasoning?
Cheers
C. Baron


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><((((º> Salmon of Doubt & NOAA HACCP lover of Bacon

#2 esquef

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Posted 04 September 2012 - 04:32 PM

"one could argue that this allows multiple SQF Practitioners for verifying/validation the many aspects of a facility's Food Safety System (even though the code runs rampant with: shall be done by "the SQF practitioner"

Our SQF auditor told us that there could be multiple SQF Practitioners in a single site facility so long as there's a single individually who's ultimately responsible and accountable for the intrgrity of the food safety management system (as well as quality for Level 3).

I'd be fairly certain that if there were multiple Practitioners involved that resonsibilities would need to be carefully documented. I'm the single practitioner in a single site facility and the audit was conducted prior to when Edition 7 went into effect, but I'd have to assume that the same is true for multi-site facilities.



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#3 bacon

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Posted 25 September 2012 - 08:13 PM

Thank you for the feedback esquef ,I am doing just that. The system I inherited was deigned after the SQF 2000 guidance document, literally, and they only have one SQF Practitioner: a heavy load for one person to carry.

Cheers,
-B


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#4 Huijoy

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Posted 08 February 2013 - 04:15 PM

From my understanding of the code SQF Practitioners must have a defined back-up:

2.1.2.8 Job descriptions for those responsible for food safety shall be documented and include provision to cover for the absence of key personnel.

Which loops back around to 2.1.2.5 and 2.1.2.6 :


2.1.2.5 The SQF practitioner shall:
i. Be employed by the supplier as a company
employee on a full-time basis;
ii. Hold a position of responsibility in relation to
the management of the supplier’s SQF
System;
iii. Have completed a HACCP training course;
iv. Be competent to implement and maintain
HACCP based food safety plans; and
v. Have an understanding of the SQF Code level
2 and the requirements to implement and
maintain SQF System relevant to the supplier
scope of certification.
2.1.2.6 The responsibility for establishing and
implementing the training needs of the
organization’s personnel to ensure they have the
required competencies to carry out those functions
affecting products, legality, and safety shall be
defined and documented.

Therefore, you would need two qualified practitioners at your site. To designated one person as the "SQF practitioner" by position title to manage the SQF System would be non-compliance. If the QA Manager management role takes you away from performing validation responsibilities you have available back-up to help perform the validation.

I would be curious to see who agrees.

As the code specifies:
_____________
2.1.2.4 The senior management shall designate an SQF practitioner for each site with responsibility and authority to:
i. Oversee the development, implementation, review and maintenance of the SQF System, including food safety fundamentals outlined in 2.4.2, and the food safety plan outlined in 2.4.3.
ii. Take appropriate action to ensure the integrity of the SQF System; and
iii. Communicate to relevant personnel all information essential to ensure the effective implementation and maintenance of the SQF System.
_____________

This issue make make more sense in this context:

The flood of demand from retailers for GFSI benchmark audit certifications seems to be causing a newly created role (that is typically held buy the QA Manager). As I see it, in the US, many food packers/processors that are new adopters of GFSI benchmarked standards the QA Managers already having too much on their plates and do not have the bench-strength to manage the global standard documentation no top of their other personnel and food safety managing duties. Hence one can find positions like “document control specialist”, “HACCP Coordinator”, “GFSI Coordinator”, “SQF Practitioner”, “BRC Compliance Coordinator” etc. (all requiring GFSI managing experience and HACCP Certification) that food packers/processors are seeking to fill.

In the food proceeding facilities I am currently working at, they have designated one person as the "SQF practitioner" by position title to manage the SQF System. So the problem I am finding is: the SQF practitioner's (separate from the QA Manager management role) responsibilities, per the language of the SQF Code, can be quite large for one person to do alone (for example, potentially cause much redundant signage for documents that have already been reviewed and verified).

(In the past I have primarily work with BRC and they seem to have more of a "team" effort emphasis when it comes to assuring food safety/quality).

So, per the SQF Code: "an SQF practitioner", "an" is an indefinite article. Hence, one could argue that this allows multiple SQF Practitioners for verifying/validation the many aspects of a facility's Food Safety System (even though the code runs rampant with: shall be done by "the SQF practitioner").

Does anybody see any flaws in this reasoning?
Cheers
C. Baron






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