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Do you have to have procedure for every topic in Module 11?

Module 11 SQF

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#1 fsweet

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Posted 13 December 2016 - 08:17 PM

Hello! I am new to the food safety world and trying to develop / implement Level 2 in our facility, which has presented me with several questions that I would LOVE to get some clarification on.  

 

We produce dry drink blends, therefore none of our incoming materials or finished product requires refrigeration or temperature control.  Am I required to write procedures for PRP's that we don't use (ex. refrigeration) or do I have to write out that our products don't require it, or can I just not address it at all and skip it?  Also, can I combine 11.6.6, 11.6.7, and 11.6.9  and list it all under 11.6.6 and have the loading/unloading sheet listed under 11.6.6? or do I need to make two trailer inspection sheets specifically for 11.6.7 & 11.6.9?

 

I really hope my question's aren't confusing, I just really need help. 



#2 Tporter

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Posted 14 December 2016 - 12:27 AM

Hi kstew,

 

In my experience with SQF, only the elements that are marked as Mandatory must be addressed in your Food Safety Plan. As far as I can tell, none of the elements in Module 11 are mandatory. That being said, any elements that pertain to your manufacturing process must be addressed. For example, if you do not use any type of refrigeration at all in your facility, you can skip that element. Just make sure that you don't accidentally skip something.

 

For your second question, one PRP can cover multiple elements in the SQF plan. You don't need a separate one for each element. I found it was easiest to just incorporate everything I could into as few programs as possible to save time and energy.

 

When I was auditing a new program, I used the SQF Code Checklist (Excel file) and entered the PRP and supporting forms, etc. that would satisfy each element for Module 2 and Module 11 or entered "Exempt" with an explanation. 

 

I hope my answers aren't too confusing!

 

Tricia



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#3 fsweet

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Posted 14 December 2016 - 01:38 AM

Thank you so much for your reply, this answers my questions on this topic!



#4 Ryan M.

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Posted 15 December 2016 - 11:05 PM

This, but also bear in mind you need to state as such about refrigeration not required for the ingredients, work in process, and finished goods.  I would think this would be covered in your hazard analysis, and your product descriptions for your HACCP plan.

 

Hi kstew,

 

In my experience with SQF, only the elements that are marked as Mandatory must be addressed in your Food Safety Plan. As far as I can tell, none of the elements in Module 11 are mandatory. That being said, any elements that pertain to your manufacturing process must be addressed. For example, if you do not use any type of refrigeration at all in your facility, you can skip that element. Just make sure that you don't accidentally skip something.

 

For your second question, one PRP can cover multiple elements in the SQF plan. You don't need a separate one for each element. I found it was easiest to just incorporate everything I could into as few programs as possible to save time and energy.

 

When I was auditing a new program, I used the SQF Code Checklist (Excel file) and entered the PRP and supporting forms, etc. that would satisfy each element for Module 2 and Module 11 or entered "Exempt" with an explanation. 

 

I hope my answers aren't too confusing!

 

Tricia



#5 Ryan M.

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Posted 15 December 2016 - 11:07 PM

Just to be on the safe side use water activity as your metric and follow the TCS (temperature controlled for safety) and non-TCS (does not require temperature control for safety).

 

http://www.fda.gov/F...s/ucm094159.htm

 

Typically, the magic number is 0.85 or less on water activity.  However, the link above shows 0.88.  pH plays a factor as well.



#6 teaks

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Posted 16 December 2016 - 03:24 PM

I am, too, developing the SQF system here, and searched the guidance document for the words "shall be documented."   I figure that means that there has to be a procedure or policy in place.







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