The "code says so" is not my answer and "Making it easier" is not and has never been my stance. The code dictates what is required for all Mandatory areas. Recording is Mandatory.
Another Mandatory section is "Sr. Management shall provide the resources required to ensure the development, implementation and maintenance of the SQF System."
They have 1) Not provided resources and 2) Have not even read the Code provided to them 10 months ago. Also have no HACCP Team either. I am dealing with an establishment that has never enforced anything at any time in any way and the thought of having to monitor processes is not feasible. Making it easier! LOL!!!!!!! Like that's an option.
Again, most of the answers you just gave are variations of "the code says so" e.g. ""The code dictates..." "recording is mandatory..". Not saying you don't have a tough culture to fight through, but recognize when you're focusing on the code rather than meeting the requirement itself.
You need to find ways in which implementing parts of the code help you improve your quality systems and even production efficiency. I have parts of the code I personally think are overkill, and I risk assess them away or take the dang minor, as long as you address the actual risk and meet the requirement of the code there are a million ways to do it. So lets come up with some creative solutions for your specific gaps.
When my team and I read through the HACCP Plan sections for printed food packaging, line clearance at every stage in the process was defined as a risk area for mixed product.
18.104.22.168 Product start up and changeover procedures during packing shall be documented and implemented to ensure that the correct product is in the correct package and with the correct label, and that the changeover is inspected and approved by an authorized person.
An "authorized person" does not have to be you. Do you have any sort of record at all of how many of each product was made that day and when the start/stop times were? I imagine there has to be a record so that you can keep inventory. Add your signature at the end of the day and make sure you are part of the review process for the "job bag" documents you identified. That way they're reviewed on an annual basis with your involvement, and you verify the "inspection" performed by your operator. Demonstrate that this hasn't been an issue by using your "incident" or complaint tracking log. If there actually have been problems with this in the past, use that data to demonstrate to management how you can eliminate customer complaints and/or rework downtime by implementing a more robust inspection system. But if it hasn't been a problem, don't create a check or paperwork for the sake of the code. Find another way to demonstrate a record.
Every program I try to develop is met with "it's not feasible for your to record every line
clearance record" Why does it have to be electronic? Why can't we just file them with
the job bag like we do now?
I'd ask the same questions! I use a mixture of electronic and paper records. The only advantage electronic records have over paper is that they can be stored, duplicated, accessed, sorted, and analyzed easier. But if no one is using the records that way, then scanning/data entry is just an extra step with no advantage for you. How many lines are there? Can you do a single page review of products produced the previous day and have some sort of verification activity that helps make sure that there are no mixed cartons independently? My pest control records are 100% paper and I bring them to the auditor, same with tracebility and on-line paperwork. Then we stay on the computer to review all of our quality metrics and SOPs. Describing what the contents of the Job bag are would help us point out how they could be used effectively during an audit. Paperwork reduction should always be a goal to make implementing your system effective, because if you have tons of excess or redundant paperwork, people will mess up the stuff that's really important.
Also have no HACCP Team either.
I'm confused, your first post stated:
When my team and I read through the HACCP Plan sections for printed food packaging..
Did you mean you don't have a cross-functional HACCP team? Or that it's since been disbanded? Ours meets only when the plan needs to be reviewed.
"Sr. Management shall provide the resources required to ensure the development, implementation and maintenance of the SQF System."
They have 1) Not provided resources and 2) Have not even read the Code provided to them 10 months ago.
Your senior management team does not have to read the entire SQF code..that's your job as practitioner.
22.214.171.124 Senior site management shall designate an SQF practitioner for each site with responsibility and authority to:
i. Oversee the development, implementation, review and maintenance of the SQF System, including food safety fundamentals outlined in 2.4.2, and the food safety plan outlined in 2.4.3.
ii. Take appropriate action to ensure the integrity of the SQF System; and
iii. Communicate to relevant personnel all information essential to ensure the effective implementation and maintenance of the SQF System.
126.96.36.199 The SQF practitioner shall:
i. Be employed by the site as a company employee on a full-time basis;
ii. Hold a position of responsibility in relation to the management of the site's SQF System;
iii. Have completed a HACCP training course;
iv. Be competent to implement and maintain HACCP based food safety plans; and
v. Have an understanding of the SQF Food Safety Code for Manufacturing and the requirements to implement and maintain an SQF System relevant to the site's scope of certification
They're not going to read the code, and it is not essential that they do. What is required is that they hire someone with the capability to read and understand how to implement, and have the authority to implement it. Your company isn't giving you the authority to implement it in the way that you think is best, but that doesn't mean there can't be a conversation about how to meet the requirements in the way that makes the most sense for your company. Not every company is going to embrace SQF as a "culture" and many will just implement what they need to get the certification. This pisses us QA people off but it's still a step in the right direction.
As far as evidence of management commitment, they have demonstrated commitment by 1: designating a SQF practitioner meeting the requirements above (which you obviously do), and 2, by having a company that supports the requirements of the code and has had whatever level of investment necessary to meet the requirements in their facility. There isn't a dollar value assigned to the management commitment clause, it's assessed by looking at they systems you've implemented, and the state of your facility. If they won't fix things or implement anything, and you have findings and broken stuff everywhere, then that's evidence of lack of management commitment.
As you look for different solutions, audit yourself against the SQF guidance rather than the code. For example, the guidance for the changeover clause:
What does it mean?
To allow for effective trace back (refer to 2.6.2), recall (refer to 2.6.3) and stock control and rotation (refer to 2.4.9), materials and products at all stages of production must be labelled and identified. How the supplier goes about this is entirely their own choice, as long as product can be identified and tracked at every stage of production.
What do I have to do?
This element is mandatory. The supplier must be able to clearly identify product upon receipt, throughout the process and when it is a finished product. Product that is in-process may be identified in a variety of ways. The site could use bin tags, pallet tags, colors, product tags, etc. The site must be able to demonstrate how the product identification system works for incoming materials, work-in-progress and for finished product. The finished product label needs to contain information that accurately describes the product in accordance to customer specification and/or regulatory requirements in the country of origin and intended country of destination. The supplier is required to prepare a procedure outlining who is responsible for maintaining the product identification system and include in the procedure the methods used to identify product. When shipping finished product, the supplier must ensure the product is clearly identified and that all product identification details are accurately described on dispatch documents or otherwise included with a shipment once it leaves the business.
The product identification procedure shall be reviewed initially at the desk audit and compliance to this requirement by observation, and interviews with operational staff, and review of records at each site audit.
The site should expect that the auditor will select product at various stages during the process and ask for the origin of product, raw material supplier, etc. to test the identification system.
Evidence may include:
There is a documented product identification system in place;
The product identification system is effectively implemented;
Product is clearly identified during all stages of the process;
Finished product is labeled to customer requirements;
Finished product is labeled to regulatory requirements in the country of origin and country of destination;
All operational staff understands and uses the product identification system.
Did you approve an SOP/work instructions for changeover that your "authorized personnel" have been trained on and can you demonstrate that this has been sufficient to create proper changeovers via incidence? Requirement has now been met. Applicable records are training records, the actual SOP/work instruction, and your incident log demonstrating that few/no issues have occurred under this system.