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Implementation Date Question

SQF

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#1 FSQguy

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Posted 26 June 2018 - 05:29 PM

Hey all, 

 

Long story short I was selected last minute to take care of our SQF audit this year. There hasn't been a dedicated practitioner since before January so I'm needing to figure out how the implementation date of January 02 will affect our audit this year. 

 

Take Management Review for example, when we have our audit will it be expected that we have been doing management reviews monthly since January? Since we haven't had a practitioner to take care of our policies these meetings haven't happened monthly. Is it sufficient to start them now or will we be held accountable for meetings that should have happened since January? 

 

 

I appreciate all of your help! 



#2 Scampi

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Posted 26 June 2018 - 05:34 PM

I would write a non conformance on this sort of thing with a corrective action starting today.

 

You cannot go back and make up records, but you must recognize that the operation was out of compliance and show steps to prevent it from happening again

 

Exact same boat here, but I only had 4 months worth of stuff to write off.......however have not had this years audit yet


Because we always have is never an appropriate response!


#3 FSQguy

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Posted 26 June 2018 - 06:48 PM

So we wouldn't get any marks off our score as long as we show that we recognized the nonconformance and corrected course? 

 

That makes me feel better about the situation. 

I would write a non conformance on this sort of thing with a corrective action starting today.

 

You cannot go back and make up records, but you must recognize that the operation was out of compliance and show steps to prevent it from happening again

 

Exact same boat here, but I only had 4 months worth of stuff to write off.......however have not had this years audit yet

 



#4 Scampi

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Posted 26 June 2018 - 06:51 PM

It's all that you can truthfully do. You may still get a minor on this because part of SQF is ensuring that there is a dedicated SQF staff member who's employed full time.

 

Who reviewed all the records while they were without someone?  Are there any records of conversations regarding SQF/HACCP between then and now?


Because we always have is never an appropriate response!


#5 FSQguy

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Posted 26 June 2018 - 06:54 PM

We've had a huge turnover in people who were going to be the practitioner and I've always been the backup. They just barely let me know that this was going to be on my plate and that records haven't been maintained.

There were definitely conversations, I would just need to scour for some documentation. Nothing really official, unfortunately. 

It's all that you can truthfully do. You may still get a minor on this because part of SQF is ensuring that there is a dedicated SQF staff member who's employed full time.

 

Who reviewed all the records while they were without someone?  Are there any records of conversations regarding SQF/HACCP between then and now?



#6 Scampi

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Posted 26 June 2018 - 07:28 PM

Gotcha, what a yucky situation to be in.

 

The other thing you can do is reach our to your CB and explain the situation and ask their opinion. But I really think the NCR, particularly for this element, should suffice, but you're going to need buy in from management (get them to sign the NCR) for the preventative measures so it doesn't happen again.


Because we always have is never an appropriate response!






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