Jump to content

  • Quick Navigation
- - - - -

Co-packer / no raw or exposed food! HELP

co-packer no exposed product no raw food help need answers SQF level 3

  • You cannot start a new topic
  • Please log in to reply
2 replies to this topic


    Grade - Active

  • IFSQN Active
  • 1 posts
  • 0 thanks

  • United States
    United States

Posted 27 May 2015 - 03:06 PM

I am writing this because we are trying to get SQF level 3 but from a co-packers point of view. Our auditor told us we are a rare breed and they are kind of unsure where/what category to put us in. Some of the procedure our auditor is telling us we need doesn't fit or doesn't make sense. So maybe someone else out there has already accomplished this aggravating task. They currently put us in SQF level 3 module 2 & 11. We receive in cream cheese in bulk, and place in to smaller cartons (So we take it out of one box and place into a small carton). The product is not exposed or raw... and we do not make it. Does anyone have any insight on processes or procedures we should be doing? are we In the correct module? Please help we are confused on a lot of stuff and any information will help.


Thanks, Miranda


    Grade - SIFSQN

  • IFSQN Senior
  • 374 posts
  • 234 thanks

  • United States
    United States
  • Gender:Male

Posted 27 May 2015 - 05:06 PM

Hi Miranda,

1st of all WHO put you in SQF level 3 module 2 & 11? Your company decides on the level you're shooting for, not the CB (or auditor). Also I don't understand how your company can re-pack cream cheese from bulk to smaller containers without some sort of product exposure. I do believe that the modules are correct. Module 2 is for just about everyone in the industry and covers System Elements:

2.1.1 Management Policy
2.1.2 Management Responsibility
2.1.3 Food Safety and Quality Management System
2.1.4 Management Review
2.2.1 Document Control
2.2.2 Records
2.4.1 Food Legislation
2.4.2 Food Safety Fundamentals
2.4.3 Food Safety Plan (at level 2, 3) Food Quality Plan (at level 3)
2.4.8 Product Release
2.5.2 Validation and Effectiveness
2.5.4 Verification and Monitoring
2.5.5 Corrective and Preventative Action
2.5.7 Internal Audit
2.6.1 Product Identification
2.6.2 Product Trace
2.6.3 Product Withdrawal and Recall
2.7.1 Food Defense
2.9.2 Training Program

Mandatory elements are designated with an “M” in Module 2 of the SQF Code (in other words, look in the code and any element you see marked with a capital "M" means that it's a mandatory element and you can't apply for an exemption from it).

Module 11 is Food Safety Fundamentals – Good Manufacturing Practices for Processing of Food Products.

This module covers the Good Manufacturing Practices requirements for the processing of perishable animal products, perishable plant products, processing of animal and plant perishable products, processing of ambient stable products, and production of bio-chemicals.
Suppliers implementing this module must also meet the requirements of Module 2: SQF System Elements.
Applicable food sector categories (FSCs) are:
FSC 8: Processing of manufactured meats and poultry
FSC 9: Seafood processing (including 9A, 9B, 9C)
FSC 10: Dairy processing
FSC 11: Honey processing
FSC 12: Egg processing
FSC 13: Bakery and snack food processing
FSC 14: Fruit and vegetable processing
FSC 15: Canning, pasteurization, UHT and aseptic operations (includes 15A, 15B)
FSC 16: Ice, drink, and beverage processing
FSC 17: Confectionery manufacturing
FSC 18: Preserved foods manufacture
FSC 19: Food ingredient manufacture
FSC 20: Recipe meals manufacture
FSC 21: Oils, fats and the manufacture of fat-based spreads
FSC 22: Processing of cereals, grains, and nuts

So I'd have to think that your company would fall under Module 11, Food Safety Category 10 (Dairy Processing.

Keep in mind that Level 2 is food safety only while Level 3 is food safety PLUS food quality. I believe that most co-packers go for Level 2 unless Level 3 is dictated by your customer(s). Typically Level 3 is sought by higher profile food companies (ex. retailers).

Hope this helps.




  • IFSQN Fellow
  • 3,781 posts
  • 950 thanks

  • United States
    United States
  • Gender:Male
  • Interests:American Patriot
    Never give up, never give in - always win!
    Martha's Vineyard Island, Massachusetts

Posted 01 June 2015 - 05:08 PM

I am not fully understanding your request - but I'll give a shot anyway...
First off SQF Auditors work for (or are contracted to) what is known as a Certifying Body or CB for short.
I am assuming you have not had your actual SQF audits as of yet and you are talking about the CB support staff and not an Auditor (this is not what an Auditor does).
If that is the case, CB's normally will ask a a number of questions before they even engage with you for upcoming audits. Things like what level you want to be, what your food sector categories are, etc. sometimes they will assist you on determining what your FSC's are the these determine what your modules will be.
At no time however will a CB dictate that you will be at a specific level.
Now, based on what you said, what I get from that is that you receive case packs of cream cheese that can be broken down into non-exposed individual cartons - as in you get a case of 100 packs of unopened cream cheese and you open the box and place 10 packs in each of 10 cartons for instance and send them on down the line.
If that is the case where you simply break down larger units containing many packages and separate them into cartons then I would be leaning towards FSC 26 for Food Wholesaling and Distribution and that equates to Modules 2 & 12.
This is of course all assumption based on your message.
Of course I also lean towards getting an SQF Registered Consultant to work with.

Kind regards,
Glenn Oster
GOC BUSINESS GROUP | SQF System Development, Implementation & Certification Consultants
Internal Auditor Training - eConsultant Retainer Subscriptions - Pre & Post SQF-GAP Audits - Consultant Training
Visit us @ http://www.GlennOster.com  or call us @ 772.646.4115 US-EST 8am-4pm Anyday except Thursday

0 user(s) are reading this topic

0 members, 0 guests, 0 anonymous users