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EMP 2.4.8 is not mandatory, but the risk assessment is

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#1 Scampi

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Posted 20 June 2018 - 05:25 PM

I just finished a webinar hosted by TraceGains on SQF V8 mid year review. I will post the slides once I get them as they include the top non conformities YTD

 

But today I wanted to pass this along;

 

2.4.8 is NOT mandatory but the RISK ASSESSMENT is

 

So if you assess away the risk as I have done (but only because of the nature of our finished good) you do not have to swab/test anything

 

However, if your risk assessment shows you may have an environmental pathogen issue, then you best get to swabbing!!!


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#2 SQFconsultant

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Posted 20 June 2018 - 06:12 PM

I like that Scampi -- "you best get swabbing!!!"  that is excellent, remind me of my years living in the south.

 

You best git to it!


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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
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to get certified and continue with on-going support thru our popular eConsultant program and we do
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#3 Scampi

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Posted 20 June 2018 - 07:05 PM

We vacationed in the southern states a lot when I was growing up.....y'all stuck like glue too!!


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#4 KBMB

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Posted 21 June 2018 - 12:35 PM

Hello Scampi,

 

That is great!

I am dealing with this as well and wondering how to accomplish.

Would you be willing to share your risk assessment?

Also,  what kind of product do you produce?

We produce dry baked goods.

 

Thank you!

BKMB



#5 Scampi

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Posted 21 June 2018 - 01:15 PM

What I did was evaluate the pathogens of concern (death curve etc) that may exist in our environment and contaminate our product against our process

 

Low pH shelf stable product

 

Even if I had listeria, it wouldn't survive our process so for us, swabbing is money out the door with no ROI

 

So you should start my ensuring you know what pathogens you're dealing with (for instance, e coli in the flour, salmonella in egg) and address each one supported by scientific papers on the effective kill of those pathogens; and then compare that to your kill step(s)

 

For instance, if you're using liquid pasteurized egg, the risk of salmonella being introduced to your product is very very low 

 

I hope this helps


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#6 KBMB

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Posted 12 July 2018 - 02:42 PM

Thank you Scampi,

 

This is helpful.

 

I guess I am struggling with how to start and approach.

I have information and an idea but the existing risk assessments I have are weak (they were implemented by a consultant).

 

I guess I am hoping for a sample or template I could work with and expand or build upon that someone could share with me please.

 

We met our auditor last audit and he was much more stringent and unreasonably demanding about what he wanted to see.

We are concerned our current program will not hold up and need ideas on how to make risk assessment more robust.

 

Thank you for your help!

 

KBMB



#7 Scampi

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Posted 12 July 2018 - 04:05 PM

Explanation of Risk Ranking

 If the consequences to this event/activity are LOW / MEDIUM, you should be OK to proceed processing as normal.

 

If the consequences to this event/activity are HIGH, it is advised that you implement corrective actions.

 

If the consequences to this event/activity are EXTREME, it is advised that you do not hold process any products until the state of the processing rooms(s) and/or raw materials can be brought into compliance

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

then the top of the risk assessment looks like this; and you would enter each incoming material. I hope this helps

List All Activities

 

Associated Risk(s)

Risk(s) associated with the activity

Severity

Level of impact finished products

Probability

The chances of that risk happening

Risk Score

Risk score, found by combining impact and probability on the risk matrix

Method(s) to Manage the Risk

A list of methods you will use to minimize the chances of the risk happening and/or the resulting damages of the risk


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#8 Charles.C

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Posted 12 July 2018 - 11:32 PM

Thank you Scampi,

 

This is helpful.

 

I guess I am struggling with how to start and approach.

I have information and an idea but the existing risk assessments I have are weak (they were implemented by a consultant).

 

I guess I am hoping for a sample or template I could work with and expand or build upon that someone could share with me please.

 

We met our auditor last audit and he was much more stringent and unreasonably demanding about what he wanted to see.

We are concerned our current program will not hold up and need ideas on how to make risk assessment more robust.

 

Thank you for your help!

 

KBMB

 

Hi KBMB,

 

Maybe post yr existing RAs +  inform as to the auditor's specific criticisms


Kind Regards,

 

Charles.C


#9 Scampi

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Posted 12 September 2018 - 01:01 PM

So even after all of this information, I was docked with 2 minors over this in my audit (I fought hard with auditor, they knocked it down from a major) and have consequently put a call out to SQFI.............clearly the information we are being given DOES NOT MATCH the information auditors have been given

 

Will keep everyone posted...................so infuriating that you have done your due diligence and done it well and still get a hit.................even when I showed auditor an SQFI document posted on the website dated May 17 2018 stating the risk assessment was the only mandatory section, I still received 2 minors!!!!!!!!!!!!


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#10 FurFarmandFork

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Posted 12 September 2018 - 01:58 PM

Thanks for making the thread Scampi, now we have something to link to every time this comes up :).


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.

#11 Charles.C

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Posted 12 September 2018 - 02:40 PM

Thanks for making the thread Scampi, now we have something to link to every time this comes up :).

 

Hi 3F,

 

You may be over-optimistic,

 

Also see this Post (Packaging/Food) -

 

https://www.ifsqn.co...e-2#entry126586

 

And this sort of parallel thread -

 

https://www.ifsqn.co...toring-program/


Kind Regards,

 

Charles.C


#12 Scampi

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Posted 12 September 2018 - 02:47 PM

I contacted the VP of technical for SQFI Americas and this is the response

 

"Environmental monitoring is not a mandatory requirement so exemption by a risk assessment is allowed.

 

Please let me know if you need further clarification or have additional questions."

 

 

Nothing makes my day more than being correct!


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#13 Charles.C

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Posted 12 September 2018 - 03:12 PM

I contacted the VP of technical for SQFI Americas and this is the response

 

"Environmental monitoring is not a mandatory requirement so exemption by a risk assessment is allowed.

 

Please let me know if you need further clarification or have additional questions."

 

 

Nothing makes my day more than being correct!

 

How about Packaging ?

 

Does the above mean that 2Minors should be deleted ? Or is it like US Open tennis ?


Kind Regards,

 

Charles.C


#14 Scampi

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Posted 12 September 2018 - 03:16 PM

I would "assume" that since this is the feedback on food manufacturing, that packaging would be the same

 

The wording is almost identical

Food

2.4.8.1 A risk-based environmental monitoring program shall be in place for all food and pet food manufacturing
processes.
 
Packaging
2.4.8.1 A risk-based environmental monitoring program, for known or expected concerns, shall be in place for all processes in the manufacture of food packaging.
 
I will caution, you better be sure your risk assessment is up to snuff..........I was told my auditor poor RAs were the reason for the code change

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#15 Charles.C

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Posted 12 September 2018 - 03:55 PM

Hi Scampi,

 

I deduce the 2Mi remained. Tough Crowd.


Kind Regards,

 

Charles.C


#16 Scampi

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Posted 12 September 2018 - 04:00 PM

2Mi?


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#17 Charles.C

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Posted 12 September 2018 - 04:06 PM

2Mi?

 

How about Packaging ?

 

Does the above mean that 2Minors should be deleted ? Or is it like US Open tennis ?


Kind Regards,

 

Charles.C


#18 Scampi

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Posted 12 September 2018 - 04:16 PM

Lol, who knew tennis would create such an uproar

 

They should be deleted from my audit


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