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

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!

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?

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.

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.

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.

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.

Charles is correct. 

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