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.
