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SQF Element 2.5.4.2 (Edition 8)

proficieny test SQF 2.5.4.2

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fozzy

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Posted 17 July 2018 - 07:49 PM

Hi Everyone,

 

I have a question regarding this topic.

 

The element reads as follows: 2.5.4.2 On-site personnel that conduct environmental or product testing shall participate in an applicable proficiency testing program at least annually to ensure accuracy of results.

 

One of the plants that I oversee, received a non-conformance against this element. I did not agree with the auditor and of course he did not even give me the opportunity to argue/debate the issue. Basically he said, that is what the code says, therefore we must comply. 

 

The point I was trying to make: we are certified for the food safety part of the code and not quality. So, all of our testing, environmental, peanut testing, allergen verification is being tested by accredited external labs. The only testing we complete in house are: moisture and bricks. They are strictly for quality and not food safety. I should say the product is hard candy with a very low water activity.

 

This was not mentioned in any of our other plants because there are allergen tests that we actually do in house and they are being validated annually via proficiency test. I don't believe this should have been a non-conformance due to the fact it is a quality test and we were not going after the quality certification. Truth be told, to correct this non-conformance would have taken likely less time than it took me to write this message but it is the point and I am interested in other opinions.

 

Any insight anyone can provide would be appreciated.

 

Thank-you,
Frank



Scampi

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Posted 17 July 2018 - 08:13 PM

Frank

So you still need your employees to gather the swab sample correct?  Auditor wants to know how you know they are doing that correctly............think of it like a CCP monitoring verification. The only way this wouldn't apply is if you contract out the actual swabbing

 

 

SOP generic ecoli swab procedure....training record.............visual observation yearly that they are following the SOP

 

Voila you're done

 

The theory is that if swabs are not collected correctly, food all over the place could have false negatives and make someone sick 

 

Hope that helps


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fozzy

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Posted 18 July 2018 - 09:30 AM

Thanks for the reply Scampi.

 

I understand what you are saying but the swab samples are taken correctly and verified internally - training records, visually, etc. All swabs collected are sent to an external lab to perform the analysis. These swabs are collected for environmental, allergen, and micro testing. Internally, the only tests we complete are for quality: moisture and bricks. The auditor was adamant about the proficiency test being completed on these tests (moisture and bricks). I didn't think it was necessary. 

 

Thanks,
Frank



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Posted 18 July 2018 - 12:47 PM

There still part of your program and the code says "product testing" it doesn't specify what kind

 

And the brix test could qualify as a reason to hold your product would it not? I mean if your reading is way way low, you could have spoilage organisms take hold (theoretically) so isn't it important that it be done correctly?  Are you still verifying that they are performing it as per the SOP?


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Charles.C

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Posted 18 July 2018 - 02:09 PM

Hi Frank,

 

from the Manufacturing Guidance -

 

The supplier shall document a procedure outlining the methods established to test finished product, work-in-progress and/or raw materials to ensure they meet specification in relation to food safety

 

 

The supplier must ensure that staff is qualified, trained and competent to complete sampling inspection and analyses.

 

Actually the Guidance makes no mention of proficiency testing. However the Code will take precedence.

 

So i agree with Scampi's comment re sampling.

 

Otherwise i agree with you. I would have challenged the auditor as to the basis of NC, ie where does it say "non-safety related Measurements"

 

PS - The Quality Code is equally, textually, ambiguous in a reverse way, eg clause 2.9.2.1(iii) and 2.9.2.3


Kind Regards,

 

Charles.C


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fozzy

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Posted 18 July 2018 - 02:47 PM

There still part of your program and the code says "product testing" it doesn't specify what kind

 

And the brix test could qualify as a reason to hold your product would it not? I mean if your reading is way way low, you could have spoilage organisms take hold (theoretically) so isn't it important that it be done correctly?  Are you still verifying that they are performing it as per the SOP?

Thank-you again for your response. I guess at the end of the day, we would have to complete the proficiency tests. Answering your question, yes, it is being performed as per the SOP.



fozzy

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Posted 18 July 2018 - 02:52 PM

Hi Frank,

 

from the Manufacturing Guidance -

 

 

 

Actually the Guidance makes no mention of proficiency testing. However the Code will take precedence.

 

So i agree with Scampi's comment re sampling.

 

Otherwise i agree with you. I would have challenged the auditor as to the basis of NC, ie where does it say "non-safety related Measurements"

 

PS - The Quality Code is equally, textually, ambiguous in a reverse way, eg clause 2.9.2.1(iii) and 2.9.2.3

 

Charles, thank-you as well for the response. I did try to challenge however, the auditor didn't want to engage in any challenge and he was quick to say: "you have the right to appeal, so let's move forward...." I didn't quite like that answer. I guess at the end of the day, I chose not to pick this as my battle to fight. Just thought it was not right and wanted to see what others thought. Thanks again!

 

Frank



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Posted 18 July 2018 - 02:59 PM

Frank, I am all for fighting and will (maybe too often) when auditors make statements that are NOT BASED on the code as written............just because an auditor says "well it means X" when it says Y doesn't make the auditor correct...and I wouldn't have liked that answer either

 

I've stated on this forum before that we ALL need to start pushing back on the auditors and CBs

 

I'm biased because I DO NOT LIKE grocery stores telling me what "safe" food is........has anyone ever seen the back room of a grocery store?  Grocery stores created the codes so reduce shrink on their shelves, and I will argue that til the bitter end

 

I also have an issue with auditors being certified to all commodities............really over your 50 year life you've worked in every area and become proficient?? Um ok

 

 

HACCP was here a long time before GFSI and yet look! the # of recalls/withdrawls has not changed!  Yep, thats $5000 well spent each and every year


Edited by Scampi, 18 July 2018 - 03:00 PM.

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fozzy

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Posted 18 July 2018 - 03:18 PM

OMG!! Scampi, you hit the nail on the head!! I am with you on all that. I do try to debate but it does depend on the auditor and he's demeanour. Some challenges I have won one, some have lost. At times, as I am sure others do, I pick my battles. I SO agree with you on the fact that auditors need to be challenged. At times, I was told: "well, it's says so in the code"...... ok, well, what does that mean? It's an interpretation after all. 

 

Grocery stores.... hmmm.... I personally have been in the back room of a grocery store and other stores for that matter. So, yes.... interesting point. I have often raised that point, how they dictate our food safety systems, yet they can be terrible at following any code. :)

 

Thanks for the comments. It sounds like we share a few of the same thoughts.

 

Frank



Dr Vu

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Posted 19 July 2018 - 12:14 AM

It's not a matter of food safety or quality but it's either you put brix or moisture in your program (ie.you not following your own regulations )or its a customer requirement  (and you can be your own customer)..

nice to know must not part of the program otherwise its going to appear under management commitment...

 I don't believe this one you would have won..

 

That's just my 2 cents on this.

 

.take sample....grind it...have the lab guy (inhouse) do brix /moisture-- send same sample to third party lab .have your target pass /fail range...

compare the results of lab vs your guy ..do a write up and conclude that your sop makes sense and your guy can do test.

 

you are done.. close the issue


Edited by Dr Vu, 19 July 2018 - 12:27 AM.

A vu in time , saves nine

Charles.C

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Posted 19 July 2018 - 01:27 AM

It's not a matter of food safety or quality but it's either you put brix or moisture in your program (ie.you not following your own regulations )or its a customer requirement  (and you can be your own customer)..

nice to know must not part of the program otherwise its going to appear under management commitment...

 I don't believe this one you would have won..

 

That's just my 2 cents on this.

 

.take sample....grind it...have the lab guy (inhouse) do brix /moisture-- send same sample to third party lab .have your target pass /fail range...

compare the results of lab vs your guy ..do a write up and conclude that your sop makes sense and your guy can do test.

 

you are done.. close the issue

 

Hi Dr Vu.

 

Surely it's just a matter of compliance with the (ambiguous) clause of the Code ?. And the Guidance.

 

Over to SQF IMO.


Kind Regards,

 

Charles.C


fozzy

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Posted 19 July 2018 - 10:58 AM

Thanks everyone for your opinions. Like I said in the beginning, It would have taken less time correcting the problem than it was to debate or even go through these posts. However,

 

I am going to say this though: we received a non-conformance on something that is somewhat not worth mentioning, rather than looking at other issues that are more pressing. What I mean by that is that I find auditors spending 2, 3, 5 days, however many days and the focus remains on the paper work rather than looking on the production floor a little deeper. I believe we shifted our focus on the documentation rather than the practical. If we asked companies: who was on the room with the auditor for the entire time? The answer will be: QA. But they all come when lunch is served. :)

 

Not to mention auditors are not calibrated and it makes it hard for the manufacturer. I find with auditors, for example, that if their experience and studies are around Regulatory, they will certainly find issues around that. They focus more on that rather than the rest. I have had some really good auditors but I've also had some not so good. What makes a good auditor? That depends on who you ask.

 

Anyhow, we are always at the hands of the auditors.



Cathy

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Posted 23 July 2018 - 12:14 PM

This situation would have been much smoother if you had used the opportunities represented under 2.4.2.1.  That section advises that if you are not following the code, you can and should write a risk assessment to explain why you are exempt or why your alternate methods are effective. A well written risk assessment often can be used to address these debates. Without that, an auditor can take away a point much more easily.  It may have helped to discuss with the auditor the definition of a minor - it produces unsatisfactory conditions that may lead to a risk.  If you are able to discuss it, and the auditor cannot identify a risk, you might not loose a point.


Cathy Crawford, HACCP Consulting Group
http://haccpcg.com/

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fozzy

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Posted 23 July 2018 - 12:57 PM

Thank-you Cathy. Good point! Agreed.






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