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2.9.3.1 - requirements for Instructions in SQF


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#1 shyshadow48

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Posted 16 February 2016 - 08:46 PM

Hello All!

 

I have a question with 2.9.3 Instructions. I am not sure if i am understanding it.

 

I work in a FDA bakery facility and are working towards becoming sqf level 1.

 

2.9.3.1 Instructions shall be available explaining how all tasks related to food safety and regulatory compliance are to be performed. 

 

 

Do i have to create instructions in how to use machinery? or ...

 

My understanding is that i can use the pre requisite program. For example, the Supplier Approval and Monitoring SOP, Food Safety Fundamentals SOP, non-compliant product SOP, etc.

 

Would that qualify? or am i not understanding it? thinking too much about it? hopefully someone can help me.

 

 

 

thank you.

 

 

 

 



#2 Tony-C

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Posted 17 February 2016 - 04:14 AM

Hi shyshadow48,

 

From SQF:

 

SQF Code Edition 7.2 Level 1 2.9.3 Instructions
2.9.3.1 Instructions shall be available explaining how all tasks related to food safety and regulatory compliance are to be performed.

2.9.3 Implementation Guidance
What does it mean?
Work instructions shall be available for all employees who carry out tasks that are part of the SQF System, e.g., contribute to meeting regulatory compliance; the food safety, quality and process efficiency controls identified in the SQF System and customer specifications.
What do I have to do?
Instructions can be provided in a number of ways such as:
• Written work instructions may be useful when a particular task is complicated (i.e., requiring skilled operators) or repetitious (e.g., mundane work that generally results in a high turnover of staff and requires a constant training effort). These instructions can serve as a valuable training reference when staff needs to check the correct way of doing a task. Written instructions can be in the form of pre-requisite programs (refer 2.3.1 i) and will be available (if practical) where the task is performed.
• Photos and diagrams can be particularly useful to overcome language barriers or when a task involves a number of different steps.
Instructions may be included in the food safety and quality manual (2.1.3), and must be kept up to date as process or System requirements change.


2.9.3 Auditing Guidance
Work instructions will be assessed at the initial desk audit and compliance at each facility audit by interview with key personnel, observation of tasks and examination of records. Evidence may include:
• There are specific work instructions for maintenance of food safety plan and associated tasks;
• There are specific work instructions for maintenance of pre-requisite programs and other tasks related to the SQF System;
• There are specific work instructions for adherence to customer specifications;
• Work instructions are known and applied by personnel conducting food safety and quality tasks;
• Work instructions are updated as changes occur to the process or the SQF System.

 

Kind regards,

 

Tony



#3 Charles.C

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Posted 17 February 2016 - 05:50 AM

Hi Tony,

 

I noted this is Lvl1 which is -

 

Level 1      Food  Safety  Fundamentals:  An  entry  level  for  new  and  developing  businesses  covering  only GAP/GMP/GDP requirements and basic food safety elements (Module 2)

 

Are tasks in GAP/GMP/GDP considered as related to FS ?

 

I would have said Yes.

 

It seemed to me that this then implies that the para.2.9.3.1 has achieved near-infinite scope.

(I noticed Lvl 2/3 have slipped the word "critical" tasks in which maybe means something < than near-infinite albeit the "critical" seems to have been totally ignored in the Guidance)

 

I expect i have missed something obvious but first  reaction was -

What a Load of !!!


Kind Regards,

 

Charles.C


#4 Tony-C

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Posted 17 February 2016 - 07:09 AM

Hi Charles,

 

There is still a requirement for a Food Safety Management System (M):
2.1.3.1 A food safety manual shall be documented..... :Include or reference the written procedures, pre-requisite programs and other documentation necessary to support the development and the implementation, maintenance and control of the SQF System.

The requirements in Module 2 for level 1 are less stringent compared to level 2 & 3 as you would expect and there are also some exclusions.

Clauses not applied at level 1:
2.1.5 Complaint Management
2.1.6 Business Continuity Planning
2.3.1 Product Development and Realization
2.3.3 Contract Service Providers
2.3.4 Contract Manufacturers
2.4.3 Food Safety Plan (M)
2.4.4 Food Quality Plan
2.4.8 Product Release (M)
2.5.6 Product Sampling, Inspection and Analysis
2.8.1 General Requirements for Identity Preserved Foods
2.9.4 HACCP Training Requirement

Kind regards,

 

Tony



#5 Chris DeV

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Posted 19 February 2016 - 07:59 PM

Shyshadow 48,

 

Tony gave the great synopsis above for the scope of what you need to do. The following examples may assist you.

 

1 - Food safety work instructions - written SOPs for how to monitor your CCPs, how your allergens are handled, etc. etc.

2 - Regulatory work instructions - written SOPs for how to verify correct labels, how to properly weigh finished products, etc. etc.

 

These are just very basic examples. Anything related to a task performed for food safety reasons would need written instructions on how to do it. How do your warehouse personnel keep allergens separated from non-allergens (SOP)? How are incoming raw materials labeled, rotated, and protected from contamination (SOP)? If you have metal detectors, how are they calibrated, verified, etc. (SOP)? 

 

You would need written instructions for all of these tasks, all of which should be in your Food Safety Manual (or separate SOP manual), as well as records showing the required personnel were trained on it and their competence in performing each task measured.

 

It's a daunting task, but I bet you have more of this on hand than you think you do. :)

 

Chris






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