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Can the SQF food quality plan have no CQPs?


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#1 Mariah

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Posted 18 June 2013 - 05:05 PM

We are working on a food quality plan for SQF level 3. Using the SQF matrix we come up with a lot of our steps rating at a 14.  1-10 on the matrix is a critical quality point.  None of our steps rate between 1-10.  Can the SQF food quality plan have no CQPs?

One guy says yes you have to have at least one because that is what the presenter said in his SQF class. "You don't have a Food Quality Plan unless you have a CQP, you can't be certified to level 3 without at least 1 CQP"

Another guy says nope it doesn't "You have to go through the 12 steps and if you don't have a CQP its not a problem."

 

Who's right? 



#2 Mr. Incognito

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Posted 18 June 2013 - 06:36 PM

I think it's probably easier to justify a system if you have at least one and say it was the only one you found via your risk matrix.

 

We have one in our system and it's the organoleptic testing.  The product is tasted, smelled, looked at by the filler operator and the next day it is tested by the quality department.

 

It's the same question about having a system with no CCP...


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#3 Simon

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Posted 18 June 2013 - 06:57 PM

If you've done your risk assessment properly and thoroughly and you can prove it then of course you can have zero CQP's or 1 or 99.  By the same token you can do a risk assessment very poorly and arrive at zero, 1 or 99 CQP's.

 

If you are competent to carry out the risk assessment and you do it well then whatever will be will be.

 

If that is a rule of SQF certification it is ludicrous.

 

Regards,

Simon


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#4 Charles.C

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Posted 19 June 2013 - 03:41 AM

Dear Mariah,

 

This is distantly related to another recent thread here which contained a little discussion on – "What is the definition of a HACCP Plan" ?

 

http://www.ifsqn.com...cp-plan-format/

 

Some people consider it (HACCP Plan) only applies to the last few (result) pages after the hazard analysis which (typically) tabulate the evaluated  CCPs and how the designated control measures at them  are maintained, eg the critical limits, how where, when, who etc, activities, the corrective actions, ++. On this basis zero CCPs implies no data to show and therefore no Plan. I believe this was in fact a favorite loophole in the early days of meat haccp in USA, rapidly closed by regulatory requirements.

 

On the other hand, if you consider the documented implementation of the whole, eg Codex-type, system which ultimately generates the 0,1,2 etc  CCPs   represents the “HACCP Plan” then the opposite conclusion is reached.

 

So how do SQF define their (HACCP) Quality Plan ? Undefined perhaps?? (added later - see "PS" below)

 

Personally it seems illogical to me that one could have  a documented Hazard Analysis / determination of CCPs without a HACCP Plan, albeit a not-yet  complete one. :smile:

 

Rgds / Charles.C

 

PS - BRC6 only provide a glossary definition of HACCP.

their earlier intro gives -  "An HACCP plan. This provides a focus on the significant product and process food safety hazards that require specific control to assure the safety of individual food products or lines as detailed in Section II,Part 2."

Hmmmm, looks more like the narrow version IMO. I am surprised and disappointed

 

From glossary SQF 7 -

HACCP Method  The implementation of pre-requisite programs and the application of HACCP principles in the logical sequence of the twelve steps as described in the current edition of the CODEX Alimentarius Commission Guidelines, or the current edition of the HACCP guidelines developed and managed by the NACMCF.  The SQF Code utilizes the HACCP method to control food safety hazards and other quality threats in the segment of the food chain under consideration.

 

HACCP Plan  A document prepared in accordance with the HACCP method to ensure control of hazards

which are significant for food safety in the segment of the food chain under consideration.

 

Food Quality Plan  As described in level 3 of the relevant SQF Code. It shall be based on the HACCP method, include process controls at quality points in production to monitor product quality, identify

deviations from control parameters and define corrections necessary to keep the process under control.

 

The SQF defs. look pretty clear to me. IMO, SQF trumps BRC. :clap:


Kind Regards,

 

Charles.C


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#5 mariya

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Posted 19 June 2013 - 05:39 AM

very nice post i like this forum



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#6 Jus'me

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Posted 19 June 2013 - 09:25 PM

I am not sure but I would think it would be the same as a HACCP plan, afterall it is based on th esame principles only assessing quality instead of safety.  With that said though, I find it difficult to believe that you would have no CQP's.  I would think that there would be more chances of a CQP than for a CCP since quality is more broad than safety. A food can be safe but not necessarily of good quality.  I would look at the specs for your products, those are your quality attributes as well as your safety attributes.  If your specs are so vague as that their is no reasonable limits listed then no matter what you produce it will pass and spec is useless because it really doesn't set any limit. Does that make sense?  There has to be some limits, sensory evaluations, color, odor, taste, chemical attributes, etc. that you have a determined range for and if it is beyond this range then it is unsaleable, not for safety issues but for quality.  These would be your CQP's. Hope that helps.



#7 Charles.C

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Posted 20 June 2013 - 02:29 AM

I am not sure but I would think it would be the same as a HACCP plan, afterall it is based on th esame principles only assessing quality instead of safety.  With that said though, I find it difficult to believe that you would have no CQP's.  I would think that there would be more chances of a CQP than for a CCP since quality is more broad than safety. A food can be safe but not necessarily of good quality.  I would look at the specs for your products, those are your quality attributes as well as your safety attributes.  If your specs are so vague as that their is no reasonable limits listed then no matter what you produce it will pass and spec is useless because it really doesn't set any limit. Does that make sense?  There has to be some limits, sensory evaluations, color, odor, taste, chemical attributes, etc. that you have a determined range for and if it is beyond this range then it is unsaleable, not for safety issues but for quality.  These would be your CQP's. Hope that helps.

 

Dear Jus'me,

 

It may well depend on the product (very Low risk??)  and matrix  logic for significant also ( although > 10 looks pretty typical IMEX for 5x5s).

I remember a similar discussion with the zero CCPs popular in packaging FS Plans when first shown here.

 

However one has to have some practical respect for Merle's earlier comment also. Sometimes, a metal detector avoids a lot of arguments in Haccp (safety) audits. Although the typical requirement for a significant hazard to be "likely in occurrence" implies a potential minefield if an unwise selection of a quality factor, eg odour, is made and then requested to be substantiated ?

 

Rgds / Charles.C


Kind Regards,

 

Charles.C


#8 WBSimon

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Posted 21 June 2013 - 04:20 PM

Our product is considered a low risk commodity. The HACCP Plan we submitted to SQF 7, though it did have Control Points (CP's), none were found to be Critical Control Points (CCP's). Our HACCP Plan included all 5 of the Prelimary Steps, but only went as far as part 2 of the Principles. Parts 3-7 were left blank because they were Not Applicible.

 

I do not recomend having a "Token" CCP/CQP just to have one. Why make you life more difficult? If you don't have any CCP/CQP's, just verify and validate your CP's.



#9 Charles.C

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Posted 22 June 2013 - 08:19 AM

Our product is considered a low risk commodity. The HACCP Plan we submitted to SQF 7, though it did have Control Points (CP's), none were found to be Critical Control Points (CCP's). Our HACCP Plan included all 5 of the Prelimary Steps, but only went as far as part 2 of the Principles. Parts 3-7 were left blank because they were Not Applicible.

 

I do not recomend having a "Token" CCP/CQP just to have one. Why make you life more difficult? If you don't have any CCP/CQP's, just verify and validate your CP's.

 

Dear WBSimon,

 

Thks for input.

 

I agree with yr brave recommendation  but unless “just verify and validate your CP's”  is specifically required by SQF (is it ?), far better to also avoid IMO.

 

Rgds / Charles.C

 

PS – I can see the Ve necessity may be required as per this paragraph –

2.5.4.1 The  methods,  responsibility  and  criteria for  verifying  the  effectiveness  of  monitoring  pre-

requisite  programs,  critical  control  points,  critical quality  points  and  other  food  safety  and  quality

controls   identified   shall   be   documented   and implemented.    The  methods  applied  shall  ensure

that  personnel  with  responsibility  for  verifying monitoring activities authorize each record verified.

 

 

If so, it simply represents another SQF stupidity IMO, eg Verification of the Nose.

I also noticed that “CQP” itself appears  totally, glossary, undefined by SQF [!?]


Kind Regards,

 

Charles.C


#10 StevePNZ

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Posted 22 June 2013 - 11:00 PM

Yes - you don't need to have CQPs - I don't have any and no issue with auditor.



#11 Mr. Incognito

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Posted 28 June 2013 - 11:49 AM

What are you making?  We make yogurt and our QCP is organoleptic testing of the yogurt at the filler (By filler op) and then we (Quality Team) test it the next day to make sure it tastes right, right consistency, etc.


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#12 Charles.C

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Posted 28 June 2013 - 10:24 PM

What are you making?  We make yogurt and our QCP is organoleptic testing of the yogurt at the filler (By filler op) and then we (Quality Team) test it the next day to make sure it tastes right, right consistency, etc.

 

Dear MerleW,

 

Sort of  Devil's Advocate type question - Based on the above conclusion, can you validate that (yr?) experience with the product / process suggests that an organoleptic defect of a serious nature is likely to occur ?

 

Or perhaps you used some other kind of criterion ?

 

Rgds / Charles.C


Kind Regards,

 

Charles.C


#13 Rodriguez-Gonzalez

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Posted 01 July 2013 - 01:54 AM

Mariah:

 

From my perspective, both of them are right. Based on my research and experience I can tell you that a HACCP plan is a nice tool to analyze and manage risks, in this case associated with quality failures.

 

If you use the risk matrix you have a stronger assessment, and if your team considers that the frequencies and severities are not significant, that is your company responsibility. At the end of the day it has to work for your business.

 

Without CQPs you can save on monitoring systems, verification procedures and record keeping, but you need to have a stronger prevention plan. Alternatively, you can increase the threshold to 14, which is pretty much looking for "six sigma perfection" in your product attributes.

 

Last thing I learned about the future of SQF (Advanced Practitioner Training Survey) is that they are looking into having a Management System that utilizes indicators to measure effectiveness. In this case, having CPQ's may look good for your Audits.


Edited by Rodriguez-Gonzalez, 01 July 2013 - 01:58 AM.





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