I noted this in the July 2014, Module 11 Guidance document –
11.2.13 Auditing Guidance
Cleaning and sanitation procedures and schedule shall be reviewed at the initial desk audit.
Subsequent compliance to this requirement and the supplier cleaning and sanitation procedures shall be
reviewed at each facility audit through observation, review of records, and interviews with operational
staff and cleaning contractors if applicable. Evidence may include:
• The facility has an effective and appropriate cleaning program in place;
• All critical equipment and areas of the facility are covered in the cleaning program;
• Cleaning methods include what is to be cleaned, how it is to be cleaned, frequency of cleaning
and responsibility for cleaning;
• The cleaning program includes measures for verification of the effectiveness of sanitation;
• The cleaning of processing equipment is effective;
• The cleaning of utensils and protective clothing is effective;
• The cleaning of buildings, surrounds, and amenities is effective;
• Cleaning of utensils is carried out in an area separate from processing operations;
• Racks and areas for storing cleaned utensils are provided and appropriate;
• Pre-operational inspections are completed to ensure cleanliness;
• All critical areas of the facility are include in pre-operational inspections;
• Personnel conducting pre-operational inspections are trained and qualified;
• A sanitation verification schedule is available;
• Methods are established for verification of sanitation;
• Responsibility is established for verification of sanitation;
• An inventory of purchased chemicals is available and is current;
• Detergents and sanitizers meet local regulatory requirements;
• SDS sheets are available for all cleaning chemicals purchased;
Note that SQF consider the Guidance text as “non-binding”, ie the auditor can dump it if another interpretation is preferred.
(BRC would probably include their customary “risk-based” tag so as to similarly avoid a definitive statement).
Anyway, taking the text as is -
It appears SQF have 2 Guidance “criticals” of nominally open interpretation, the 2nd for pre-op purposes.
(I dare to suggest that 1st one is equivalent to “zoning” but only audit receivers will know in practice."
Based on above, I can perhaps understand an SQF auditor dinging if no documented respose to "critical" exists but as to what is an acceptable response – I guess it’s just another –
Rgds / Charles.C