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Question on complying with 2.4.1.2 Food Legislation (2, 3) (M) and 2.1

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#1 jteddy78

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Posted 07 May 2013 - 11:46 PM

Hello all,

 

I want to first thank all of those whom had posted their questions and responses via this board.  I have found the information here very useful in preparing for my first SQF Level 2 audit. 

 

We did pass but were documented for several Minor issues.  The one problem we ran into was that the auditor had a different interpretation, or expectation, regarding some the SQF provisions. 

 

Two items that we and the auditor do not agree upon are:

1.  2.4.1.2 Food Legislation

2.  2.1.2.9 Management Responsibility

 

Prior to receiving our annual audit, we did seek consult, and were told we should be fine with these two items.  However, the auditor didn't agree.

 

Can you share how you complied with these requirements? 

 

Thanks!



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#2 Charles.C

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Posted 08 May 2013 - 02:57 AM

Hello all,

 

I want to first thank all of those whom had posted their questions and responses via this board.  I have found the information here very useful in preparing for my first SQF Level 2 audit. 

 

We did pass but were documented for several Minor issues.  The one problem we ran into was that the auditor had a different interpretation, or expectation, regarding some the SQF provisions. 

 

Two items that we and the auditor do not agree upon are:

1.  2.4.1.2 Food Legislation

2.  2.1.2.9 Management Responsibility

 

Prior to receiving our annual audit, we did seek consult, and were told we should be fine with these two items.  However, the auditor didn't agree.

 

Can you share how you complied with these requirements? 

 

Thanks!

Dear jteddy,

 

You may get more relevant replies if you elaborate a little on the nature of yr disagreement ?

 

Rgds / Charles.C


Kind Regards,

 

Charles.C


#3 cazyncymru

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Posted 08 May 2013 - 10:53 AM

Hello all,

 

I want to first thank all of those whom had posted their questions and responses via this board.  I have found the information here very useful in preparing for my first SQF Level 2 audit. 

 

We did pass but were documented for several Minor issues.  The one problem we ran into was that the auditor had a different interpretation, or expectation, regarding some the SQF provisions. 

 

Two items that we and the auditor do not agree upon are:

1.  2.4.1.2 Food Legislation

2.  2.1.2.9 Management Responsibility

 

Prior to receiving our annual audit, we did seek consult, and were told we should be fine with these two items.  However, the auditor didn't agree.

 

Can you share how you complied with these requirements? 

 

Thanks!

 

 

Hi JTeddy78

 

In the UK, we are lucky that the FSA print a list of current Food Legislation every 3 months. I keep a copy of this on file so at least i can pretend that iknow which legislation is relevant (with the help of a highlighter pen!)

 

Link is

http://www.food.gov....oodlawguide.pdf

 

 

Caz x



#4 Oldairyman

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Posted 09 May 2013 - 12:02 AM

First SQF 2.1.2.9  is a level III requirement , not level II

However, if you are going for Level III , You need to prove upper management is directing and organizing your continuous Improvement projects, charting, engineering, KPI, CIP, 5s, how are they ( Management ) implementing systems to improve quality and profits.  Show it prove it .

Second 2.4.1.2  Scientific information, Industry standards, developing research . In documentation

  • “ You must show that you have the latest legislation from your country or the country you are shipping to or receiving from “  Ministries of Ag, or Dept. of Ag etc.
  • Ideas,.....
  • Example say, fried product scientific  literature on Acrylamides
  • Risks for mycotoxins in food, the drug companies overlooked.
  • In the US the “ Modernization act “
  • Risks of Air systems with Listeria
  • This forum ( IFSQN ) can and should be used as a source of industry standards
  • High Pressure pasteurization is it safe ? 
  •  Bla blab la  you could bury an auditor with research information related to your food product.
  • You should show the auditor, your the experts in the manufacturing of your product.

I don't know what your auditor had a problem with, but I hope this helps ,, Jeff

:spoton:

 

 



#5 SQFconsultant

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Posted 09 May 2013 - 09:11 PM

First SQF 2.1.2.9  is a level III requirement , not level II

 

 

 

 

Sorry, but this is an incorrect statement - 2.1.2.9 can be found under both Level II and Level III - it does not apply under Level I.

 

Glenn


Kind regards,

 

Glenn Oster
 
GOC GROUP / +1.800.793.7042 / Food - Food Packaging - Food Storage/DC

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Serving Small-to-Mid-Size Businesses | We are International - Accepting all major C-Currencies

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#6 SQFconsultant

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Posted 09 May 2013 - 09:13 PM

First SQF 2.1.2.9  is a level III requirement , not level II

 

 

 

 

Sorry, but this is an incorrect statement - 2.1.2.9 can be found under both Level II and Level III - it does not apply under Level I.

 

Glenn

 

Hello all,

 

I want to first thank all of those whom had posted their questions and responses via this board.  I have found the information here very useful in preparing for my first SQF Level 2 audit. 

 

We did pass but were documented for several Minor issues.  The one problem we ran into was that the auditor had a different interpretation, or expectation, regarding some the SQF provisions. 

 

Two items that we and the auditor do not agree upon are:

1.  2.4.1.2 Food Legislation

2.  2.1.2.9 Management Responsibility

 

Prior to receiving our annual audit, we did seek consult, and were told we should be fine with these two items.  However, the auditor didn't agree.

 

Can you share how you complied with these requirements? 

 

Thanks!

It would be easier if you posted what you provided for these and what the statement was that the Auditor made on the Reliance system.

 

Glenn


Kind regards,

 

Glenn Oster
 
GOC GROUP / +1.800.793.7042 / Food - Food Packaging - Food Storage/DC

SQF, BRC & IFS System Development, Implementation & Certification Consultants

Serving Small-to-Mid-Size Businesses | We are International - Accepting all major C-Currencies

Internal Auditor Training | eConsultant | SQF, BRC & IFS Pre-Development or Pre-Audit GAP

http://www.GlennOsterConsulting.com  -- 

 

 

60% Savings to Ownership/Senior Partners when using C-Currency "XRP" Expires: 04-NOV-20

https://glennosterco...-development-pr
 

 

 

 

 

 

 

 

 
 
 
 
 
 
 
 
 

#7 jteddy78

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Posted 15 May 2013 - 09:54 PM

Hello,

 

Thank you for the feedback.  To be more specific, we were citied for the following:

(1)  2.1.2.9- The Senior Mgmt. shall establish processes to improve the effectiveness of the SQF System to demonstrate continuous improvement.

 

Our internal policy states we will constantly improve the Food Safety and Quality Programs and solicit consultation services to continually improve policies and procedures.  We have documentation of obtaining a SQF consult (SQF gap analysis) and provided meeting notes stateing based on the results, no changes to the program were necessary.

 

Auditior response: there were no specific records, reports or actions available to support continuous improvement.

 

(2)  2.4.1.2-- The methods and responsibility for ensuring the organization is kept informed of changes to relevant legislation, scientific and technical developments and relevant industry codes of practice shall be documented and implemented.

 

Our program states the FSQA Manager is responsible for attending food safety related conferences(several specific symposiums identified), subscribe to FDA recall and safety alerts, communicate with local, state and federal agencies, develop, modify and update SOPs, HACCP and policies and procedures to meet changes in federal, state and local regulations. (SUMMARIZED)

 

      Auditor response: There is no documented statement on who will be responsible for keeping informed or how they will keep up to date with legislation, scientific or technical developments.

 

      

Thank you all again for your feedback!



#8 tadelong

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Posted 28 May 2013 - 04:40 PM

I can't honestly see how they could give you those non-conformances if you had your paperwork as you say. What was your score? I suspect it was about 83. Two too many to comfortably challenge for an A rating.







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