What materials fall within the scope of SQF 2.3.2 (specifications)?

Our process contains only one ingredient and one type of packaging material, but we use many cleaning products, lubricants, paints, and other chemicals though. Do any or all of these items fall within the scope of SQF 2.3.2? Thanks in advance for the guidance.

Hi



From my understanding you need full specifications for all raw materials, packaging and processing aids but for things such as cleaning chemicals, paints etc a MSDS is sufficient. I only hold MSDS for my cleaning chemicals - although I do hold actual specifications for the terminal sanitisers I use on food contact equipment. This was acceptable to my auditor last year and I intend to follow the same practice at my next audit which is next week!


The actual SQF guidance document says the following for clause 2.3.2............"The supplier is required to maintain specifications for raw materials that impact finished product safety. For example, this can relate to cleaning compounds, ingredients, packaging, etc. You are required to keep Material Safety Data Sheets (MSDS) and labels for all chemicals that may be used on-site."

Hope that helps.



Sarah

A lot of this is going to depend on your auditor unfortunately. While you may not need a full blown specification for anything that comes into contact with or might come into contact with food or food contact surfaces you are going to need some sort of documentation that it is appropriate for food use and this is not typically on the MSDS.

Three years ago during our initial desk audit I was asked for specifications on packaging material. I had them for all food contact materials but did not have them for shipping cases because the standard required specifications for materials "that impact on finished product safety" and I did not consider the shipping container to fall within that definition. Our auditor disagreed, arguing that if the shipping container was out of specification it could lead to damage of the inner package and a food safety hazard (even though out products are dry and do not require any special packaging for safety).

2 years ago during our first recertification audit our maintenance manager spent about 16 hours on the phone with equipment suppliers trying to chase down documentation that paint used on motor housings and such was approved for food plants, even though all of these were mounted in such a way that should their be any paint chips (which there was not) they would have ended up in a protective catch pan rather than in the product. The auditor based this on the statement that "11.2.9.5 Paint used in a food handling or contact zone shall be suitable for use and in good condition and shall not be used on any product contact surface." It was under edition 6 so it was in a different place in the code, but the same wording. Try getting documentation of the paint used on 20+ year old equipment sometime!

The amount of supporting documentation for SQF can become almost overwhelming. I was fortunate enough to convince our management to invest in a document management system when we started into this, and it has helped tremendously. In early December of last year as I was prepping for our audit I ran a report and found that we had about 3,700 active documents in our system, and we are a relatively small operation.

2.3.2 does change for the Level you reach in SQF (1, 2 or 3). But even at Level 1, they're asking for specifications on"ingredients, additives, hazardous chemicals and

processing aids, that impact on finished product

safety shall be documented, comply with relevant

legislation, and kept current."


I think this is where many of us can defend things not related to food safety. For example, I have MSDS on Windex that our custodian uses in the office areas. Windex is NOT allowed on our production floor, and is not a cleaning tool listed in any of our cleaning procedures, so it does not impact finished product safety. Ergo, I have not supplied full specifications on Windex. For our packaging supplies and equipment cleaning, we've got the COC's that prove we're using the "right stuff" for our equipment and food storage.

Our process contains only one ingredient and one type of packaging material, but we use many cleaning products, lubricants, paints, and other chemicals though. Do any or all of these items fall within the scope of SQF 2.3.2? Thanks in advance for the guidance.

SQF Code 2.3.2 is clear and concise - in answer to your question - yes, ALL.



Glenn Oster

http://www.GetGoc.com