8 replies to this topic

[HNG]

I work for a plant that has a contract manufacturer- last year we had them fill out a form/contract confirming compliance with our requirements, and also had them third party audited but not to SQF standards just a basic GMP audit. The new SQF code version 7.2  in 2.3.4.2i now says that the supplier must "Verify compliance with the SQF Code" whereas it used to just say verify that all customer requirements are being met. 

 

Does anyone know what that means - do the contract manufacturers now have to follow the SQF code in full?   And how would one 'verify compliance' --- since in the same section it says products and/or process of co-manufacturers that are high risk need an audit by the supplier or third party.  So if not high risk, what is required for verification if not an audit? 

 

Would greatly appreciate anyone's feedback on this.   Thanks in advance!

[Katja]

from what i understand you must only audit them if they are using a high risk process and you can audit them yourselves somewhat like you would do as an internal audit but on them. Good luck

[bacon]

Yes, HNG, as always, allot of grey area.... 

 

Really 2 parts of 2.3.4.2i

 

For all of your co-manufacturers:

 

(a) Verify compliance with the SQF Code and that

all customer requirements are being met at all

times.

 

For all of your high-risk co-manufacturers:

 

(b) Products and/or processes of comanufacturers

that are considered high risk shall be required to

undergo an audit by the supplier or other third party

agency to confirm compliance to the SQF Code and

agreed arrangements; and

 

How does a supplier "Verify compliance with the SQF Code" when not using a complete 3rd Party audit (high-risk or not)?

 

I haven't counted up all of the individual requirements of the 263 clauses (level 2) but is there any "guidance" out there to the "limits" on how one is to confirm compliance? How about 1 question out of each section for a co-manufacturer audit? Will that do? Or... a supplier can form an entire audit team to audit its co-manufacturers to the entire SQF Code... or, "or" point of (b) just tell all of your co-manufacturer to pass a 3rd party SQF audit (even if they are compliment with another GFSI benchmark like over 230 BRC clauses - that is, over 700 BRC requirements).  

 

I do know the system drives the behavior and it seems SQFI is rather obvious about this... unless I am overlooking something.

-Baron

 

[Charles.C]

Dear All,

 

It appears that SQF have suddenly discovered another opportunity for creating confusion, ie use of the word "confirm". Or was it always there ?

 

http://www.ifsqn.com...ult/#entry71135

 

Rgds / Charles.C

[bacon]

 use of the word "confirm"

 

 *shakes head*

Yea, that too...

 

To Tora14's point, understand validating is clear. Yea, with a creditable 3rd party audit, easy... but how about the suppliers own audit of their co-manufacturers... how does one know if it is "compliance with the SQF Code"?

 

Apart from a full blown SQF audit... (therefor just demand a SQF audit from you co-manufacturers).

-B

[tery]

I would greatly appreciate if please share template contract with co-manufacturer, co-manufacturer control procedure that meets the requirement of the SQF code?

 

Thank you

[makkawi]

Many thanks

[Tony-C]

I work for a plant that has a contract manufacturer- last year we had them fill out a form/contract confirming compliance with our requirements, and also had them third party audited but not to SQF standards just a basic GMP audit. The new SQF code version 7.2  in 2.3.4.2i now says that the supplier must "Verify compliance with the SQF Code" whereas it used to just say verify that all customer requirements are being met. 

 

Does anyone know what that means - do the contract manufacturers now have to follow the SQF code in full?   And how would one 'verify compliance' --- since in the same section it says products and/or process of co-manufacturers that are high risk need an audit by the supplier or third party.  So if not high risk, what is required for verification if not an audit? 

 

Would greatly appreciate anyone's feedback on this.   Thanks in advance!

 

Hi HNG,

 

I think that this is a clarification of the requirements.

 

If you look at Module 11 Guidance for Edition 7.1:

 

'Whatever the situation, any contract facility used to manufacture, in part or in whole, an SQF certified product MUST fulfill the same requirements as the SQF certified supplier.

What do I have to do?
The supplier must have a documented procedure detailing how they will ensure that product in the care of the contact manufacturer meets their customer specifications and the requirements of the SQF Code. Control of the food safety and quality management system in an external facility that is under different management is not an easy task. However the supplier must ensure that facilities selected to contract manufacturer are committed to meeting SQF System requirements. This includes management commitment, pre-requisite programs, document control and records, adhering to specifications, food safety plans, food quality plans and all other food safety and quality controls.
The supplier may simply require the contract manufacturer themselves to be independently SQF certified, or may choose to control the conditions in the contract facility via sampling, testing, inspections and internal auditing. In
the latter case, a verification schedule, including a sampling plan and internal audit procedure must be included.

Note: in situations where the auditor feels that there is product risk from the contracted facility, the auditor may require a visit to that facility to confirm compliance to the Code and the agreed arrangements.'
 

Regards,

 

Tony

[fgjuadi]

The supplier may simply require the contract manufacturer themselves to be independently SQF certified, or may choose to control the conditions in the contract facility via sampling, testing, inspections and internal auditing. In
the latter case, a verification schedule, including a sampling plan and internal audit procedure must be included.

 

This must be why so many suppliers send me their entire QA Manual and all procedures when I ask for an audit cert.  I love QA, but I don't want to go through their HACCP plan/ PRPs, etc.   I am not certified as an SQFI auditor and I'm not qualified to determine if they were up to standard.  Seems like the only way you could be sure is to only buy only from GFSI  certified manufacturers, and that's not currently possible for us.   Actually a lot of our suppliers are going through the same thing we are - growing company, looking to get certified, learning as we go. I'm not a paid consultant/auditor for them and I don't want to be one. Maybe I'm self centered, but I want to spend my company's time auditing *my* programs.

 

As a coman, I'm interested in what kind of sampling and testing is expected.  I know one of my customers sent out Finished Goods for allergen levels - the levels came back fine (negative for bars without allergens) but we had just distributed the product!  If it had been positive, we would have had to recall the product.  I've never been through a recall as a coman and when I heard the "good news" I was surprised they hadn't told me they were testing - their name is all over the product that would have been recalled, and I wouldn't have shipped to various distribution until after the results came back if I knew.  Another customer has won a few international confection awards for a bar we formulated/produce, so does that count as sensory testing?

 

Do y'all tell your coman when you're going to test their finished product? I suppose it defeats the purpose to tell them, but isn't that risky in terms of recall if you are not distributing the product?  What do you sample for? Do you share the required sampling plan with your coman?

Edited by magenta_majors, 11 July 2014 - 10:44 AM.