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If 11.2.13.4 CIP does not apply do I need to seek an exemption?

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#1 Quality elf

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Posted 26 February 2018 - 03:43 PM

Question: SQF 8.0 says " All applicable elements of Module 11 shall be implemented. Where an element is not applicable a request for exemption must be appropriately justified, and submitted to the certification body in writing before the audit."

 

Does that mean that if I don't use a CIP system that I then have to submit to the CB in writing that I do not have a CIP system and therefore 11.2.13.4 will not be applicable?

 

Thanks!



#2 Quality elf

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Posted 26 February 2018 - 03:47 PM

For more clarity, the guidance doc references cold storage and if there is no cold storage then section 11.6.2 is not applicable. however 11.6.2 is a full section with several sub-elements. So I guess what I am asking is do we need to ask for exemption only if a section is not relevant or for every sub-element that is NA?



#3 adamperry2235

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Posted 26 February 2018 - 08:35 PM

I don't believe you have to request and exemption for that. In the clause itself it says "where used" so if you aren't using it then you wouldn't have to worry about it.



#4 Quality elf

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Posted 26 February 2018 - 08:48 PM

the guidance says "It is recognized that not all elements of module 11 are applicable to all food production facilities. Some elements can be exempted if they are not relevant, and as long as the site has submitted a written request to the certification body prior to the audit, to exclude that element. For example, if the operation has no cold storage facilities then elements under 11.6.2 would not apply. There are no mandatory elements in module 11."

 

so I just want to make sure that if I dont have CIP I dont have to have prior notification to the CB. I think for the lack of labs and contract manufacturing I do have to bc those are full sections, like cold storage in the example.



#5 Charles.C

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Posted 26 February 2018 - 08:53 PM

the guidance says "It is recognized that not all elements of module 11 are applicable to all food production facilities. Some elements can be exempted if they are not relevant, and as long as the site has submitted a written request to the certification body prior to the audit, to exclude that element. For example, if the operation has no cold storage facilities then elements under 11.6.2 would not apply. There are no mandatory elements in module 11."

 

so I just want to make sure that if I dont have CIP I dont have to have prior notification to the CB. I think for the lack of labs and contract manufacturing I do have to bc those are full sections, like cold storage in the example.

 

Hi QE,

 

Text in the Code over-rides text in the Guidance.


Kind Regards,

 

Charles.C


#6 FurFarmandFork

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Posted 26 February 2018 - 10:42 PM

Hi QE,

 

Text in the Code over-rides text in the Guidance.

Same here. I never had refrigeration before this year and never formally asked for an exemption. I simply said "I have management review provisions that will re-evaluate our policies and procedures in the event that refrigeration becomes part of our process."

 

I would ask for the exemption if for some reason I had coldrooms but they weren't necessary for my product's safety or quality. But I don't really see that situation coming out except in a rare shared building circumstance.


Austin Bouck
Owner/Consultant at Fur, Farm, and Fork.
Consulting for companies needing effective, lean food safety systems and solutions.

Subscribe to the blog at furfarmandfork.com for food safety research, insights, and analysis.

#7 SQFconsultant

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Posted 27 February 2018 - 01:47 AM

Charles is correct. 

 

There would be a boatload of problems if everyone starting issuing exemption requests.


Kind regards,
Glenn Oster
 
GOC Group | +1.800.793.7042 | Serving the Food, Food Packaging & Food Storage Industries
SQF Development, Implementation & Certification Consultants 
 
In a nutshell we help small to large businesses to get their act together (as needed), help them to co-develop
entire SQF documentation systems, make recommendations as to installations and repairs in order
to get certified and continue with on-going support thru our popular eConsultant program and we do
all in about 30 days so your staff can implement with our assistance to retain and get new business!
 
Serving the new Republic of the United States of America & Alliance Countries

http://www.GlennOster.com






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