Jump to content

  • Quick Navigation
Photo
- - - - -

SQF Ed.8: Management Responsibility (2.1.2.10 and 2.1.2.11)

SQF Edition 8 Management Responsibility 2.1.2.10 2.1.2.11

  • You cannot start a new topic
  • Please log in to reply
4 replies to this topic

#1 That Guy

That Guy

    Grade - AIFSQN

  • IFSQN Associate
  • 48 posts
  • 14 thanks
13
Good

  • United States
    United States
  • Gender:Male
  • Location:Western New York
  • Interests:I'm a nerd, enough said.

Posted 26 January 2018 - 12:57 PM

I am having trouble interpreting parts 2.1.2.10 and 2.1.2.11 of the SQF code, both parts are new to Edition 8

 

We recently went through our unannounced re-certification audit and we received a Non-Conformance because "The documented 'Management Responsibility' does not exist outlining the control measures in continued operation in the event of organizational or personnel changes within the company and the 'Black-Out' dates were not documented."

 

---------------------------------------------------

 

The SQF code:

2.1.2.10 Senior site management shall ensure the integrity and continued operation of the food safety system in the event of organizational or personnel changes within the company or associated facilities.
2.1.2.11 Senior site management shall designate defined blackout periods that prevent unannounced re-certification audits from occurring out of season or when the site is not operating for legitimate business reasons. The list of blackout dates and their justification shall be submitted to the certification body a minimum of one (1) month before the sixty (60) day re-certification window for the agreed upon unannounced audit.

 

The SQF 2.1.2 Implementation Guidance:
"What does it mean" section of the guidance
Blackout periods are defined as blocked out seasons or time periods during the year where a site is not in full
operation and therefore, unable to have a fully comprehensive unannounced audit conducted.

 

"What do I have to do" section of the guidance
For defining these blackout periods where an unannounced audit is not viable at that particular time, a site must
submit dates and justification for their desired black out period at least one (1) month before the sixty (60) day recertification
window of an agreed upon unannounced audit.

 

--------------------------------------------------------

 

I am not certain if 2.1.2.11 is requiring specific dates that we will blackout or if all we need to do is make some sort of statement like 'Senior Management shall designate defined blackout periods. The list of blackout dates and a justification shall be submitted 30 days prior to the 60 day unannounced audit window.'

 

I am reluctant to put specific dates in a policy statement because they do not stay the same every year (Christmas is on December 25th but that isn't always a weekday and may not need to be blacked out), we are not having another unannounced audit this year so the blackout dates are not applicable and would just require additional and unnecessary document revisions in my opinion.

 

Thanksgiving  (and Black Friday), Christmas, New Years and our annual inventory fell within our 60 day audit window this year (only 7 days were open after January 2nd, all other available dates would have audited to edition 7.2) When we scheduled the unannounced audit we submitted these specific dates to the certification body. The confirmation page we received for our CB listed the blackout dates and justification on it but the auditor did not accept this as fulfilling the requirements of this element.

 

--------------------------------------------------------

 

The guidance does not specifically address 2.1.2.10  and I am at a lose as to what is required for it. Do specific control measures need to be adopted and documented?

We have an org. chart and job descriptions that include a provision for alternate/backup coverage in the event of an employees absence as required in other elements of 2.1.2 but that was not what the auditor was looking for.

 

-------------------------------------------------------

 

We received a 95 on the audit even though we were expecting it to occur before the change to edition 8 :happydance:


Chive On.


#2 wave

wave

    Grade - Active

  • IFSQN Active
  • 5 posts
  • 1 thanks
0
Neutral

  • United States
    United States

Posted 26 January 2018 - 03:05 PM

Probably your company has not specific dates. But, for examples, Jewish companies have specific dates when they are don't work, or companies which have seasonal work.



#3 Timwoodbag

Timwoodbag

    Grade - MIFSQN

  • IFSQN Member
  • 74 posts
  • 28 thanks
5
Neutral

  • Earth
    Earth

Posted 26 January 2018 - 05:03 PM

I read 2.1.2.10 more like "If your Regulatory Officer and SQF Practitioner were both arrested tomorrow, what would your company do to ensure the food safety system is not affected?"  Maybe they wanted you to provide documentation that your Back-Ups are trained to take over their new responsibilities, that they are ready to be the next person up.  

 

I have NOT had an audit under SQF ed.8 yet, but I have updated my manual as follows - 

 

2.1.2.10.               Alternatives for all positions directly responsible for food safety implementation are defined in the Staff Responsibilities Document.  Multiple personnel have already received HACCP training.

2.1.2.11.               Management will ensure that requested blackout periods will allow unannounced re-certification audits to occur while the site is operating.  Blackout Dates and the Justification will be submitted to the certification body at least one (1) month before the sixty (60) day re-certification window.  



#4 FurFarmandFork

FurFarmandFork

    QA Manager/FS Blogger

  • IFSQN Fellow
  • 1,091 posts
  • 490 thanks
92
Excellent

  • United States
    United States
  • Gender:Male
  • Location:USA

Posted 26 January 2018 - 06:08 PM

Yeah, I call BS on the finding. All the requirement says is that you must notify your CB formally within the allotted time period. You did that and kept a record of it. There's no requirement to include it as a policy statement (though you might if it had been missed int he past), unless it missing led to the requirement not being fulfilled. Not true in your case.

 

If it was an actual minor, our CB is supposed to help you identify an appropriate corrective action if you need guidance. They aren't allowed to give "advice" during the audit, but once it's an actual NC they're supposed to help you out.

 

Honestly I'd challenge this one based on the fact that you provided a provision for coverage in your Org chart and (presumably) in your crisis management plan.

 

If you end up having to include it as a policy statement, maybe include it in your documents for contract service providers where you have your CB. I've been "caught" before not including the CB in there (That was a separate argument :) ) but now since they are, I basically include the code which has the guidance we are required to follow including blackout dates.


QA Manager and food safety blogger in Oregon, USA.

 

Interested in more information on food safety and science? Check out Furfarmandfork.com for more insights!

Subscribe to have one post per week delivered straight to your inbox.

 


#5 That Guy

That Guy

    Grade - AIFSQN

  • IFSQN Associate
  • 48 posts
  • 14 thanks
13
Good

  • United States
    United States
  • Gender:Male
  • Location:Western New York
  • Interests:I'm a nerd, enough said.

Posted 09 February 2018 - 05:10 PM

The following policy statement was sufficient to close out the N.C.

 

 

Senior Management has designated 'employee name' as the SQF Practitioner with the responsibility and authority to oversee the development, implementation, review, maintenance and continuous improvement of the SQF System including Food Safety Fundamentals and Food Safety Plans.

 

Senior Management shall ensure that the SQF Practitioner holds a full-time position of responsibility within the company in relation to the management of the SQF System, has completed a certified HACCP training course and have the understanding and competence to implement and maintain the SQF System and HACCP based Food Safety Plans. The SQF Practitioner shall take appropriate action to ensure the integrity of the SQF System and communicate to relevant personnel all information essential to ensure the effective implementation and maintenance of the SQF System.

 

Senior Management shall designate defined Blackout Periods to ensure unannounced SQF re-certification audits will occur during regular business operations. The list of Blackout Periods and justifications shall be submitted to the certification body 30 days prior to the 60-day unannounced audit window.

 

Senior Management shall ensure the integrity and continued operation of the Food Safety System in the event of organizational or personnel changes. Alternatives for all positions directly responsible for food safety system are defined in the Job Description documents.


Chive On.


Thanked by 3 Members:




Also tagged with one or more of these keywords: SQF Edition 8, Management Responsibility, 2.1.2.10, 2.1.2.11

0 user(s) are reading this topic

0 members, 0 guests, 0 anonymous users

EV SSL Certificate