SQF Level 2 - Areas of Exemption
Good Morning All,
We are still working our way through the modules for SQF Level 2 compliance for manufacture of food packaging.
One area we are very unclear on is what can we exempt in a low risk, non-food contact printed box.
So much of this seems to be written for high risk food contact. Has anyone else been able to exempt areas and still obtain certification?
All you can effectively try is to submit your exceptions to your CB and get their feedback.
We are a farm to fork operation and the entire farm (including one well) are exempt for our operations.
Perform a risk assessment of your operations and submit that to the CB to justify your position
It was explained to me that all items in Ed 8 marked "Mandatory" are just that, you don't get exemptions for those. That being said, some of them are easy to address with policy and HACCP plans that identify the risk levels as extremely low or no risk identified, typically no CCPs identified for food packaging manufacturers. When the guidance document for Module 2 specifies "for food manufacturing", focus less on those by addressing the risk level in policy / procedure. Some of the (M) elements in Ed 7.2 were marked as "Not Applicable" by our auditor, going forward though is a little more unclear. Hope some of this helps.