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Appointing an SQF Practitioner


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#1 MmeMuffin

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Posted 19 December 2014 - 01:01 AM

I have taken over developing a FSMS for reaching SQF certification. I finally have gotten the boss on board and helping to develop the HACCP plan. 

He went to the HACCP certification course (didn't want to pay for both of us to go), and has written most of it , though I am doing some revising (I have taken courses on HACCP but am not certified)-- is this okay? 


He is not in the office frequently enough to be the SQF practitioner. He does have the most thorough understanding of how the facility operates, but he is gone for several weeks at a time on a frequent basis, and I believe a SQF practitioner should be able to oversee the day-to-day operation. 

Am I wrong? Any ideas on how to approach this subject? I am 100% willing to take on the role of SQF practitioner. I WANT it, weirdly. I guess I didn't realize how much I wanted this role until now, because I feel like my responsibilities are being stripped from me-- how crazy am I?? :P


Edited by Mel.D, 21 January 2015 - 04:38 PM.


#2 fgjuadi

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Posted 19 December 2014 - 07:17 PM

Yes, you can have more tahn one practitioner (we have two here, becuase what if I'm on vacation in the bahamas and we need a back-up)

 

Divvying up responsibilities across departments is a great idea - you can't do it alone!  but those people aren't usually considered practitioners, they are considered member of the HACCP or Food Safety team.  No matter what you call them, they need to have adequate training. SQF practitioners themselves need documented training, and SQF provides a test (for a fee) to demonstrate SQF knowledge.  The test isn't mandatory, but it is the easiest way to prove your knowledge of the system.   Practitioners also must be competent, so if one drops the ball, then you're out of compliance.  Better to have them as part of the HACCP team.

 

You're not wrong, but it seem seems liek you're pretty stressed out - remember, your boss is paying you, so you can suggest, but at the end of the day he holds the purse strings.  Try to think of it more as "Gee, they're paying to do almost nothing, they're sure gonna be mad when it doesn't work, but maybe they'll listen to me more."   It's totally normal to want control over SOP etc - if I didn't have final approval I'd throw a fit


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#3 Snookie

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Posted 19 December 2014 - 08:24 PM

If you have concerns, address and CYA but overall Magenta said it well. 

 

if I didn't have final approval I'd throw a fit

 

Am thinking that could be both scary and entertaining.  :cool:


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#4 RG3

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Posted 19 December 2014 - 09:06 PM

2.1.2.5 The SQF practitioner shall:

ii. Hold a position of responsibility in relation to the management of the supplier’s SQF System; (Shown in your Org Chart & Job Description)
iii. Have completed a HACCP training course; (IHA certified if preferred)
iv. Be competent to implement and maintain HACCP based food safety plans; and (Showed through a having HACCP course)
v. Have an understanding of the SQF Code level 2 and the requirements to implement and maintain SQF System relevant to the supplier scope of certification. (You don't necessarily need to take a Implementing SQF Systems Course you Can be done by taking the test on the SQFi site http://www.sqfi.com/.../online-exams/)
2.1.2.6 The responsibility for establishing and implementing the training needs of the organization’s personnel to ensure they have the required competencies to carry out those functions affecting products, legality, and safety shall be defined and documented. (I think this can be used as your focus of argument to be able to have FULL CONTROL and not have it dispersed everywhere. The rest of the people can put in their two cents when you review all your documents at least annually)

2.1.2.8 Job descriptions for those responsible for food safety shall be documented and include provision to cover for the absence of key personnel. (As mentioned by MM the back up needs to fulfill iii-v)



#5 Charles.C

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Posted 20 December 2014 - 03:57 AM

Dear Mel.D,

 

It sounds like you are in a rather difficult situation. My sympathies.

 

I have taken over developing a FSMS for reaching SQF certification.

Actually it seems more like yr Boss has taken over development. :smile:

 

You make no mention of product / process. IMEX it is rather unusual that the “Boss” would actually have (a) the technical capability and (b) the time to perform all the HACCP (FSMS) activities you mention.

Delegation of responsibilities is of course a normal Management function but based on your post, it almost seems (to me) that your boss is protecting their position via “divide and conquer”. The reason, if any, is unclear. Another (worst case?) possibility  is that your job may be at risk.

 

I deduce that –

 

(1) Currently the “Boss” is the sole officially  designated Practitioner. And the officially designated, back-up, “acting” Practitioner is ?

(2) Your nominal position is ? QA Mngr ?

 

The answer to (1) would appear to dictate your claimable options as per the activities listed in previous post.

 

IMEX, regardless of any chosen routes for Certification of the FSMS system, it is “standard”  for HACCP Plans to have an introductory page which states the person who is designated as “responsible” for the HACCP Plan. Typically the position is filled by the QA Manager (or equivalent terminology).

If this Page exists in your HACCP Plan, I am curious as to who is nominated ? .

 

Rgds / Charles.C


Kind Regards,

 

Charles.C


#6 MmeMuffin

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Posted 22 December 2014 - 03:30 PM

Dear Mel.D,

 

It sounds like you are in a rather difficult situation. My sympathies.

 

Actually it seems more like yr Boss has taken over development. :smile:

 

You make no mention of product / process. IMEX it is rather unusual that the “Boss” would actually have (a) the technical capability and (b) the time to perform all the HACCP (FSMS) activities you mention.

Delegation of responsibilities is of course a normal Management function but based on your post, it almost seems (to me) that your boss is protecting their position via “divide and conquer”. The reason, if any, is unclear. Another (worst case?) possibility  is that your job may be at risk.

 

I deduce that –

 

(1) Currently the “Boss” is the sole officially  designated Practitioner. And the officially designated, back-up, “acting” Practitioner is ?

(2) Your nominal position is ? QA Mngr ?

 

The answer to (1) would appear to dictate your claimable options as per the activities listed in previous post.

 

IMEX, regardless of any chosen routes for Certification of the FSMS system, it is “standard”  for HACCP Plans to have an introductory page which states the person who is designated as “responsible” for the HACCP Plan. Typically the position is filled by the QA Manager (or equivalent terminology).

If this Page exists in your HACCP Plan, I am curious as to who is nominated ? .

 

Rgds / Charles.C

Charles, 

We are a dry, low risk milling operation that sells a GF grain, flour, and mixes. We are very, very small, and I am the first employee outside the "family and friends" of the owners that has been hired to do anything other than operating machinery in the plant- so there has been a lot of growing pains just in that regard already. I was originally hired for more research and development than anything else.

When I started working here in January, I took it upon myself to slowly start suggesting changes that should be done in order to bring the plant up to a more respectable level of food and worker safety. There were fire extinguishers that hadn't been inspected since 2009, the loading doors that lead into the production area were always left open- with no means of keeping birds from flying into the plant. Nobody wore hairnets, chemicals were stored incorrectly, plant workers were smoking in the back warehouse... I could go on. The boss has a hard time viewing the food as FOOD and not feed because he was a farmer for the majority of his life (and still grew the product we mill up until this year which was his last). I have been on him about the HACCP plan being insufficient - it was one page long, had no CCPs, didn't define any processes, etc- since about March. 

I finally convinced him that things needed to change after we had a visit from a huge manufacturer that wanted to use our flour as an ingredient... he basically said there was no way he could use our stuff unless we become SQF level 2 certified. Things then started actually happening and he sent me to attend a course on developing a food safety management system. He attended the HACCP course because it was a 3-4 hour drive away and he was in that area of the state already for the previous weeks because that's where his home is (he spends a few weeks here, then a few weeks at home). He didn't think it made sense (aka, is too cheap?) to pay for me to travel to the course when he was already in the area, and I agreed it would be good for him to attend because I wanted him to hear it from someone other than me for a change. This was good and he does have a better respect for food safety now, but he also thinks he can keep it as informal as the rest of the plant... when I want and need some definition of who is doing what. 

To answer your questions:  
1. My boss is the person who is now HACCP certified, but he is asking me to finish the last half of it (he doesn't have time). He refers to me as "the food safety lady"... and I've written almost all (still working on it) of our SOPs, Documentation forms, etc. that aren't exclusively addressed in the HACCP plan. My desk is piled high with resources and drafts of training documents for employees... he has had me dedicate the past few months to focusing on getting this in place... so I was under the assumption that I was the SQF practitioner. 

2. I was originally hired for nutrition consulting and recipe development.. I've never had an official title because I do a little bit of everything.

The day-to-day plant operation consists of myself, one production/operations manager (who is waaay too busy), two plant employees who operate the machinery and package product, and my boss when he's here. There are several offsite employees and owners who are here maybe once a month... but that's it. We are at a breaking point where we can't grow without SQF, but we can't hire anyone else to implement SQF. 

He did tell me last week that he "just put peoples names down so it wasn't all one person". That makes me feel (a little bit) better... I think I originally read a bit far into it... but I still need to sit down with him and define a few things. I think I'll use the organizational chart I've been working on and have him help define who does what and tell him I need it on paper... this way I can know exactly where I stand.

Thanks!



#7 MmeMuffin

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Posted 22 December 2014 - 03:33 PM

I can't seem to find out how to edit--

So I should say-- it wasn't ME who convinced him that things needed to change... the money did ;)



#8 Mr. Incognito

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Posted 22 December 2014 - 03:42 PM

Edit should be on the bottom right of your post.  

 

It can be pretty hard working in a mostly family business or when all of the management is family.  I haven't done it but I've worked with a few people who have and it was a pretty rough situation for them.  It was part of the reason I ended up working with them actually.  And part of the problem was management that didn't want to listen.

 

You don't have to have HACCP certification to help with the HACCP plan but it needs to be reviewed by the food safety team and signed off by the plant manager.  Someone in the process does need to have HACCP certification.  There are some less costly routes to get HACCP certification such as online courses like the ones IFSQN has.  I know someone who did it on their own to further their career through a different online source... but he was a little crazy so I was happy I ended up being the quality coordinator rather than him.  He wasn't the most balanced person I'd ever met (but certainly not the least balanced either).  Just mostly inappropriate in different ways.

 

It would be good for you to have it and the auditor will be happy if you do.  It was one of the first questions that the auditor asked me when the he came back after I was hired.  I was hired between their desk audit and their initial certification audit.  Of course then he asked other things like if I had worked with FSSC before to which I replied no but that I was an SQF Practitioner and he liked that as well.

 

I would say, if I was you, that I had a hand in writing the HACCP manual but that majority of it, and the review, was by the HACCP trained employee.  It's not a lie... he did work on it as well and will have to review it.


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#9 Charles.C

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Posted 23 December 2014 - 09:28 AM

Dear Mel.D,

 

Now, you really have my sympathies.

 

Indeed I know yr situation only too well. Sounds like the only thing you are lacking is a dog. :smile:

 

IMEX, respectable training courses for HACCP are operationally adequate to be an expert  w/wo papers but the suggestion in previous post is a good one IMO. Even at yr own expense (you are salaried?). Nothing to beat a document or 2 from auditor's POV. Not to forget the upcoming free webinars on this forum.

 

I would make 100% sure that you include a frontispiece I mentioned before in YOUR HACCP plan defining the "responsible" person (s) for the Plan to include  yours truly. I am sure there are plenty of examples on the net demonstrating the necessity for such a document. Maybe add a line for emergency contact at the last minute if strategically necessary. :smile:

 

Do SQF allow the designation of HACCP Coordinator ? Sounds impressive, especially on a resume. ;)

 

 And IMO increased responsibility = opportunity for a pay request.

 

Of course, the ultimate bottom line is how much you need/want to be Superwoman ?

 

Good Luck !

 

Rgds / Charles.C


Kind Regards,

 

Charles.C





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