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idealdreams

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Posted 08 March 2017 - 06:41 PM

Howdy guys. I made a post in January that we were getting ready for an SQF Level 2 qualifying desk and facility (certification) audit.

 

Our desk audit took place last month and went exceptionally well, only 9 minor NCs and all were easy fixes. I was commended by the auditor for the language of my programs in place.

 

Our facility audit started on Monday and ended today, so 2.5 days. 12 minors and 1 major. Ouch. Looking at a 78 so far, tentatively provided the technical reviewers do not make any further changes after our auditor submits her findings.

 

So that places us in the C - Complies range of scores, meaning we are required to undergo a "surveillance" audit in 6 months instead of the typical reaudit in 12 months had we received a G - Good or E - Excellent score.

 

I kind of expected a poor facility audit score because there is such a huge lack of upper management commitment to the implementation of SQF and there are long periods of downtime in between production runs. We had only management level staff on site for the past month and a half. Other staff reports to work only when we're manufacturing, so it's very easy to forget your training when you're not coming in to work every day, Monday to Friday.

 

I can write all of the programs and make sure the quality manual is rock solid, but it's only as good as its effective implementation. I did all I could and I'm not saying I wasn't to blame for any of the NCs during the facility audit. But I certainly cannot accept responsibility for 22 points worth of NCs.

 

Is it typical for a supplier to receive a poor first audit? Our hits mostly had to do with lack of product identification (raw materials, mostly) and allergen management - employees were observed using incorrect color coded utensils and containers to match the allergen that was being used during processing. Our major hit was in allergen management and the rest were all minor NCs.

 

I'm quite disappointed to say the least, especially since this is a small family owned business who will now have to shell out another $4,000 for the surveillance audit in 6 months instead of 12 months.



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Posted 09 March 2017 - 02:33 AM

No it is not typical for a supplier to receive a poor first audit.  

 

Most are quite well prepared with buy-in thru all management and ownership levels.

 

For instance we have never had an SQF client score lower than a 93 on the first certification audit with most in the 95-100 range.


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idealdreams

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Posted 09 March 2017 - 08:11 AM

We received no third party counseling for the development and implementation of our SQF system. Glenn, obviously your clients are going to receive high(er) scores because they are PAYING you quite a large amount of money to ensure just that. I would hope your clients would receive nothing lower than a 93. Respectfully, your instances are irrelevant to me and those others who do not seek outside counsel since we did not have the guidance of an expert or firm and it sounds more to me as though you are trying to sell your consulting services here instead.

So no, it's not typical in your cases for your clients to receive poor scores, but that's not really what I asked. I should have been more clear in my original post.



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Posted 09 March 2017 - 03:14 PM

I do not think it's typical.  If a facility is anticipating a low score (as you said you were), they usually choose not to move forward and instead focus on fixing the problems internally. 

 

I would be extremely concerned about the major finding.  Allergen control is critical.  You need more training and/or a more robust program if your employees are so casually cross contaminating your products.  Your job is to advocate for these programs with management.  I would not be worried about $4000 for the re-inspection when you're at risk for a product recall.



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Posted 09 March 2017 - 03:57 PM

Typical?  Well, it is all relative let's just say that.  My latest facility, first SQF audit Level 3 last year was 88% score which I was not happy with.  However, I and our facility director took it with a grain of salt because we focused on the language of the non-conformances and why they happened.  After the close out review meeting it was all understood and we saw it as an opportunity to improve.  However, some of the items were really splitting hairs in our facility and a bit outside of the SQF code.

 

I would view this as an opportunity to have a frank discussion with your people involved in the management commitment.  The most common failure of SQF implementation doesn't lie with the Quality Manager or SQF Practitioner, but the management commitment from everyone else.  Hopefully, this is a a wake up call for upper management to say, "Hey we need to get serious about this." because a not so great SQF score is one thing, but a recall or harming the public with your product is a completely different level.  An allergen recall for your small facility would probably shut the doors down for good.

 

Did your SQF auditor discuss the management commitment issue?  I sure hope he/she did.



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Posted 09 March 2017 - 03:57 PM

No it is not typical for a supplier to receive a poor first audit.  

 

Most are quite well prepared with buy-in thru all management and ownership levels.

 

For instance we have never had an SQF client score lower than a 93 on the first certification audit with most in the 95-100 range.

 

I would hope so!  That's what people pay consultants for, right?  Those without consultants to assist is a different matter.



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Posted 09 March 2017 - 07:00 PM

We had our certification audit last month with a score of 86.  Not the best score but with no management commitment, I'm surprised we passed at all.  It seems most companies fit into two categories.  One is 100% committed and does excellent, the other is just happy to pass and that is considered "good enough".  It is frustrating from a QA standpoint when the commitment is not there. 



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Posted 09 March 2017 - 07:20 PM

My section 4 (CFIA, HACCP, FSEP) audit took 6 months to close and was a disaster, HOWEVER, once that was done, we know that we will have another within 2 years, that hopefully goes much better.

 

You will learn ALOT once you start practising the code, then and ONLY then will you be able to make improvements. What make sense on paper will not always translate to practice. I believe that you are perhaps being a little harsh on yourself. Yes, allergens are a big deal in this day and age, but you are by no means an expert in writing a program to meet a standard and wouldn't know what you didn't know

 

You're right about management level commitment..........and production line staff you aren't there all the time won't have been harped on enough to fully understand the implication of allergen cross contamination.........if you detail out how much a recall will cost perhaps then your managers will get on board

 

Best of luck


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idealdreams

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Posted 09 March 2017 - 10:39 PM

I do not think it's typical.  If a facility is anticipating a low score (as you said you were), they usually choose not to move forward and instead focus on fixing the problems internally. 

 

I would be extremely concerned about the major finding.  Allergen control is critical.  You need more training and/or a more robust program if your employees are so casually cross contaminating your products.  Your job is to advocate for these programs with management.  I would not be worried about $4000 for the re-inspection when you're at risk for a product recall.

 

I knew the desk audit would go great however I had a gut feeling that the actual certification audit would not go as well, simply because the owners (there are two of them) are not putting in the time or effort to help implement the system. They are under the mindset that they can sign off on all the necessary documents and only practice the written policies/procedures for audits and then slack off in between audits.

 

I have expressed my concern in regards to lack of management commitment so many times and I'm simply tired of bringing it up. If the company wants to keep shelling out $4,000 for audits every 6 months, so be it.

 

I am not extremely concerned about the major finding because all tools are thoroughly cleaned and sanitized and we do allergen testing following every production run to ensure proper cleaning. It's not as though active cross contamination was occurring. Nonetheless, I see your point and I'm not brushing off the major finding by any means.

 

We use three of eight regulatory allergens and all products are manufactured on one production line. I am very well versed in allergen management and definitely do not need additional training and our written allergen management program is quite extensive and complete. It's the implementation of said program that resulted in our major finding. Between the lack of management commitment in implementing the entirety of the program and the extensive periods of downtime, it's no wonder our employees weren't as up to speed on the written program as they should have been. Not saying it's not my fault at all, but all employees are trained extensively in allergen management upon their hire and annually thereafter. It's the downtime and lack of management support that cost us 10 points.

 

Typical?  Well, it is all relative let's just say that.  My latest facility, first SQF audit Level 3 last year was 88% score which I was not happy with.  However, I and our facility director took it with a grain of salt because we focused on the language of the non-conformances and why they happened.  After the close out review meeting it was all understood and we saw it as an opportunity to improve.  However, some of the items were really splitting hairs in our facility and a bit outside of the SQF code.

 

I would view this as an opportunity to have a frank discussion with your people involved in the management commitment.  The most common failure of SQF implementation doesn't lie with the Quality Manager or SQF Practitioner, but the management commitment from everyone else.  Hopefully, this is a a wake up call for upper management to say, "Hey we need to get serious about this." because a not so great SQF score is one thing, but a recall or harming the public with your product is a completely different level.  An allergen recall for your small facility would probably shut the doors down for good.

 

Did your SQF auditor discuss the management commitment issue?  I sure hope he/she did.

 

There are definitely 2-3 non-conformances that I feel are way outside of what's written in the SQF Code. When I brought this up to the Auditor in an attempt to "dispute" them, so to speak, I was told that certain things just come with experience and should be practiced even though it's not explicitly written in the SQF Code.

 

Example: SQF Code 7.2, 11.7.4 states that an environmental monitoring program must be in place and define the responsibilities, target organisms, frequency, number of samples, etc. and I developed our program in accordance to what was written. I also used the guidance document.

 

We received a minor NC for our environmental monitoring program because our auditor personally felt that we weren't swabbing enough zones (we swab only zones 3-4, not zones 1-2). So we lost a point because she felt our program wasn't complete, despite there being absolutely NO mention of the zones to be swabbed in the SQF Code.

 

We had our certification audit last month with a score of 86.  Not the best score but with no management commitment, I'm surprised we passed at all.  It seems most companies fit into two categories.  One is 100% committed and does excellent, the other is just happy to pass and that is considered "good enough".  It is frustrating from a QA standpoint when the commitment is not there. 

 

I'm surprised we passed with a 78. As far as "senior management" is concerned, there are two owners of the company. On paper, a president and vice president, however it's a 50:50 partnership so both have equal say. Their take on the implementation of the SQF system is to simply sign the policies and procedures I've developed to comply with the SQF code, without reading them, and expect that they're magically just put in place.

 

Outside of audits and routine quality control monitoring, I sit at a desk. I can't babysit all of our plant employees to ensure they're doing what's written - that is the responsibility of the owners. Granted I SHOULD have caught several of these minors during my internal audits, it's hard to do when there are such large gaps in production. There was no production between 1/25 - 3/6. How am I to audit what employees are doing when they're not even in the building?

 

My section 4 (CFIA, HACCP, FSEP) audit took 6 months to close and was a disaster, HOWEVER, once that was done, we know that we will have another within 2 years, that hopefully goes much better.

 

You will learn ALOT once you start practising the code, then and ONLY then will you be able to make improvements. What make sense on paper will not always translate to practice. I believe that you are perhaps being a little harsh on yourself. Yes, allergens are a big deal in this day and age, but you are by no means an expert in writing a program to meet a standard and wouldn't know what you didn't know

 

You're right about management level commitment..........and production line staff you aren't there all the time won't have been harped on enough to fully understand the implication of allergen cross contamination.........if you detail out how much a recall will cost perhaps then your managers will get on board

 

Best of luck

 

I learn more about SQF on a daily basis and I am amazed at how far I have come on a personal level in my understanding of the code and what is expected. I began to develop the SQF system two years ago and the programs I wrote two years ago were nowhere near as comprehensive as they are now. Our recall/withdrawal program two years ago was one page. It's up to 12 pages and counting now.

 

I am sure our programs will only get better after each audit, just as they have done over the last two years, however it is discouraging that I am left to develop and implement the entirety of the SQF System without management's help. It's a lot of work for only one person, especially when the owners don't help to enforce anything I have in place, because they don't know what's written.



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Posted 10 March 2017 - 01:04 PM

Hi ideal dreams,

 

Personally, based on the FS Standard involved, yr OP/Resources/Operational situation, I think you did quite well to achieve a "C". :thumbup:

 

IMEX there are many, many QA Managers who will identify with yr preceding comments, and the assessment in Post 7. You only have to look back through this Forum to see various examples.

 

Many Top Managements (TM) simply believe that the QA Department will wave a magic wand over incoming auditors/production lines and all the well-known/documented  defects will suddenly become invisible.

 

i am curious as to the feedback from yr own TM, eg an "Opportunity for (Everyone's[?]) Improvement" or Satisfaction with the "C" despite the financial implications ?.


Kind Regards,

 

Charles.C


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Posted 10 March 2017 - 01:32 PM

Perhaps I am way off base here, but it looks a little like the owners DO NOT have a vested financial interest in the success or failure......how can they keep on running with such large gaps in production? I'm just putting this out there, because this may be a loosing battle......if the owners have proceeded with SQF because a customer demanded it, but they don't want or feel they need it, you will always be expected to wave your magic wand and make everything rosy. No, you cannot manage this on your own, no one could. 

 

A very frank conversation maybe? All your cards on the table and take the fallout as it comes???? ( I feel your pain, we are small, 2 owners, one of which has no understanding of what is required to keep our registration) plus a "silent" partner who also has zero understanding


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Posted 10 March 2017 - 05:09 PM

Hi ideal dreams,

Personally, based on the FS Standard involved, yr OP/Resources/Operational situation, I think you did quite well to achieve a "C". :thumbup:

IMEX there are many, many QA Managers who will identify with yr preceding comments, and the assessment in Post 7. You only have to look back through this Forum to see various examples.

Many Top Managements (TM) simply believe that the QA Department will wave a magic wand over incoming auditors/production lines and all the well-known/documented defects will suddenly become invisible.

i am curious as to the feedback from yr own TM, eg an "Opportunity for (Everyone's[?]) Improvement" or Satisfaction with the "C" despite the financial implications ?.


The owners are definitely not happy with the need for a 6 month surveillance audit, only because of the additional financial burden, however they are not putting the blame on any one person. If the company had a never ending bank account I am sure they wouldn't even care about the 6 month reaudit. It's just really disappointing that they set these hugh aspirations and offer no assistance in making them happen.

I wrote the entire quality manual. For every section of Module 2 and 11 (e.g. 2.1.1, 2.1.2, etc., etc.), there is a corresponding program in our quality manual which state the requirements of the code, how we comply specifically, and then includes any written programs or supporting documents all in one place. Add that to the HACCP manual, SOPs, SSOPs, and I have essentially written a book.

I do what I can to bring employees on board with what's written, but it's impossible to get it fully implemented without the help from the owners. Had the facility been DOING what was written, we should have had an excellent rating.

Perhaps I am way off base here, but it looks a little like the owners DO NOT have a vested financial interest in the success or failure......how can they keep on running with such large gaps in production? I'm just putting this out there, because this may be a loosing battle......if the owners have proceeded with SQF because a customer demanded it, but they don't want or feel they need it, you will always be expected to wave your magic wand and make everything rosy. No, you cannot manage this on your own, no one could.

A very frank conversation maybe? All your cards on the table and take the fallout as it comes???? ( I feel your pain, we are small, 2 owners, one of which has no understanding of what is required to keep our registration) plus a "silent" partner who also has zero understanding


You are not off base by any means. The large gaps in production aren't voluntary. It's based on customer demand. We are primarily a purchase order driven company, so if there are no POs coming in, there's likely no production. We have had several large accounts (and I mean large) in the past who have all required GFSI certification however they continued working with us in under the requirement that we are certified within x amount of time.

So as you said, SQF was chosen to satisfy the GFSI certification requirement demanded by our customers. It's not something the company would have done if our customers weren't requiring it.

The audit was actually fast tracked by one of the owners because he was in talks with another huge account that wouldn't even meet with him unless we had documented GFSI certification. It was at that point he told me to schedule an audit ASAP, and just as he requested, I did. That certainly didn't help the preparedness level at all.

As I mentioned in an earlier post, I have had discussions with the owners before about management commitment and helping to get the system implemented but it always falls on deaf ears. I have accepted the fact that I am essentially only there to ensure written compliance to the SQF Code (what's actually practiced mostly falls out of my hands) and to offer guidance based on the written policies/procedures, which of course may be disregarded anyways (as is usually the case).


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Posted 10 March 2017 - 07:32 PM

So as you said, SQF was chosen to satisfy the GFSI certification requirement demanded by our customers. It's not something the company would have done if our customers weren't requiring it.

The audit was actually fast tracked by one of the owners because he was in talks with another huge account that wouldn't even meet with him unless we had documented GFSI certification. It was at that point he told me to schedule an audit ASAP, and just as he requested, I did. That certainly didn't help the preparedness level at all.

 

Unfortunately, this happens all too often.  We were in the same boat.  A number of our current customers wouldn't even talk to us without have a GFSI audit/certification in place.  Yet, you need to have some timeline of operation to even get a GFSI audit.  So, as a new facility we were in a bit of a catch 22.  When I brought on board the facility director and VP of Operations thought we could be certified within a few months of starting.  What they didn't realize was the extensive training and practice required before we could even be ready.  Everything was written, but it was the training and practice of using the system in full production that delayed our timeline.  Not to mention I was tasked with building a lab, hiring QA personnel, and developing the entire SQF System at Level 3.



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Posted 10 March 2017 - 10:33 PM

We received no third party counseling for the development and implementation of our SQF system. Glenn, obviously your clients are going to receive high(er) scores because they are PAYING you quite a large amount of money to ensure just that. I would hope your clients would receive nothing lower than a 93. Respectfully, your instances are irrelevant to me and those others who do not seek outside counsel since we did not have the guidance of an expert or firm and it sounds more to me as though you are trying to sell your consulting services here instead.

So no, it's not typical in your cases for your clients to receive poor scores, but that's not really what I asked. I should have been more clear in my original post.


I appreciate the vote of confidence in our consulting work, however our clients sucess with their grading on first round certifications actually has very little to do with us - I can't ensure that a client does well, we are about 30% of the equation as it is ultimately up to the buy in from ownership straight down to the line employee on whether what we say they actually put into an effective implementation.

Quite frankly we have very little business generated via these forums with virutually all of our work generated via good will/referrals, Linkedin and side business from pro bono and rescue business.

We actually enjoy helping people whether we are paid or not.

As to the first time low score I still stick with what I said before because I too have been and will soon be again sitting on the QA manager side of the table in our own food businesses.

It is not typical to have a low score and grade on the first certification and buy in can have a dramatic effect up or down, regardless of whether you use a consultant or not.

Kind regards,
Glenn Oster
 
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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
 
 

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Posted 11 March 2017 - 01:17 AM

Hi SQF Consultant,

 

I don't quite understand yr last paragraph. i would hv thought Management "buy-in" is invariably a positive ?. And similarly competent Consultants.

 

I think you may be underestimating the struggle involved in less amicable situations. "Resources" is right up there IMO.


Kind Regards,

 

Charles.C





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