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Dealing with crisis management NCR from SQF Audit ?


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#1 Blossom

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Posted 29 August 2018 - 08:38 PM

I did a tornedo drill in my plant but but got Audit NCR stating   " it was not mentioned how will the business continue incase the facility shuts down due to this crisis" . Auditor wanted to see how will we fulfill our customer orders .

 

Next step I sent a drafted signed  (by CEO) letter stating we are having correspondence with one of the manufacturers which could be potential alternate manufacturers for our facility . 

Our CEO had also visited that facility but the contract has not been signed   yet as the correspondence is still in process.

 

This was not accepted  as well and I have to work more on it.Following are the reviewer comments I received:

 

Reviewer Commentst.gif"Please provide documented evidence that supports the Corrective, Preventive action plans and addresses the specifics of the NC.Evidence of completed Corrective and Preventive actions must be submitted for review and accepted in order to close this CAR. Please refer to the specifics of the NC.

 

 

Could anyone please suggest what can be done?

 

Thanks



#2 FSQA

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Posted 30 August 2018 - 12:51 PM

I did a tornedo drill in my plant but but got Audit NCR stating   " it was not mentioned how will the business continue incase the facility shuts down due to this crisis" . Auditor wanted to see how will we fulfill our customer orders .

 

Next step I sent a drafted signed  (by CEO) letter stating we are having correspondence with one of the manufacturers which could be potential alternate manufacturers for our facility . 

Our CEO had also visited that facility but the contract has not been signed   yet as the correspondence is still in process.

 

This was not accepted  as well and I have to work more on it.Following are the reviewer comments I received:

 

Reviewer Commentst.gif"Please provide documented evidence that supports the Corrective, Preventive action plans and addresses the specifics of the NC.Evidence of completed Corrective and Preventive actions must be submitted for review and accepted in order to close this CAR. Please refer to the specifics of the NC.

 

 

Could anyone please suggest what can be done?

 

Thanks

Blossom,

 

You should update your Crisis Management Plan to show the other manufacturer facility as an alternative facility to manufacture your products in case of crisis. You do not need to send the whole crisis management plan to the CB, instead you can just send a copy of the page that reflects the change in your crisis management plan.

This should be sufficient to your NCR, as this is the evidence of your corrective and preventive action. 

 

However, since the issue has been noticed, they might insist to see an actual copy of the contract (which you need to discuss internally with your management before sending it to them, as it is a proprietary document).



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#3 Scampi

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Posted 30 August 2018 - 01:30 PM

I'm playing devils advocate here..........because I personally have some issues with "GFSI" audits, and your auditor is another example of why I feel this way.

 

What does "a business continuity plan" or "fulfilling customer orders" have to do with food safety?????

 

If your auditor wanted to question you on something, it should have been how you will determine the safety of your product if say the roof of the plant was ripped off during a tornado

 

No where is the code does it talk about fufulling orders so I would remove that from your crisis plan altogether and send your revised crisis plan that ONLY speaks to the actual requirements. 

If your customers need an back up plan for production; that is a business decision and not a food safety decision at all (other than agreeing on a co packer if needed) but those decisions have nothing to do with your food SAFETY crisis plan

 

2.1.5.2 The crisis management plan shall include as a minimum:
i. A senior manager responsible for decision making, oversight and initiating actions arising from a crisis
management incident;
ii. The nomination and training of a crisis management team;
iii. The controls implemented to ensure a response does not compromise product safety;
iv. The measures to isolate and identify product affected by a response to a crisis;
v. The measures taken to verify the acceptability of food prior to release;
vi. The preparation and maintenance of a current crisis alert contact list, including supply chain customers;
vii. Sources of legal and expert advice; and
viii. The responsibility for internal communications and communicating with authorities, external organizations
and media.
2.1.5.3 The crisis management plan shall be reviewed, tested and verified at least annually.
2.1.5.4 Records of reviews of the crisis management plan shall be maintained.
 
 
I would push back hard on this one; the code does not ask for it, but in the auditing guidance it says
"Evidence may include:"
"Records of business continuity plan reviews and their corrective actions are available"..........................it says MAY include, so I would just remove it (it's none of SQFs business what your business plans are)

Edited by Scampi, 30 August 2018 - 01:37 PM.


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#4 FurFarmandFork

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Posted 30 August 2018 - 02:46 PM

Are you being audited under the quality code? Because the quality code does explicitly have alternate supplier requirements:

2.1.5.1 The crisis management plan prepared by senior management shall include the methods by which the site shall, in the event of a crisis, maintain continuity of supply that meets the customers' product and service quality requirements. 2.1.5.2 The site shall contact their customers in the event of a crisis that impacts their ability to supply quality product.

 

 

Otherwise I agree with Scampi, that's not a requirement in the Manufacturing code (module 2). But it is in the manufacturing code guidance:

 

What do I have to do?

 

The supplier is required to identify a crisis management team including a senior decision maker and ensure the team is trained in crisis management procedures. The team shall identify known threats to the business which could disrupt or impact its ability to produce and provide safe food and prepare a plan describing the methods and controls the supplier will implement to address these threats if they were to occur and how to maintain continuity of product supply during the crisis.

 

 

 

 

What does "a business continuity plan" or "fulfilling customer orders" have to do with food safety?????

 

 

 

 

They way I always choose to interpret it (and how I subsequently design my plan) is that there's an assumption that in times of crisis your company's willingness to follow all the food safety guidelines you normally would will be stressed/tested. E.g. there's flooding in the plant and it's going to be 4 weeks before the damage can be fully repaired...the equipment is still working however.... it's going to be harder in that situation for management to say "well let's just shut down and not ship anything to [national chain with private brand contract] for a month and eat the cost of the repair with no revenue stream."

 

Having a plan in place to get safe products and/or already have management agree in writing how they will communicate to customers that products will not be shipped in that situation will make those decisions easier and made in times of rationality instead of crisis.

 

Similar to having corrective actions prescribed in your HACCP plan so everyone already knows the product will be thrown away, rather than have a CCP failure and make management decide "in the moment" whether it's acceptable or not when they're staring at an outstanding order.


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#5 Blossom

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Posted 30 August 2018 - 03:31 PM

I was audited against SQF code 8 level II. I have also scanned the correspondence  emails  between us and the potential co -manufacturer  to give a proof that we are working on the pricing . As this is something which cannot happen overnight.

The worst thing is my request for extension for the CAR Submission was not accepted and today is the last day for submission.   :helpplease:  



#6 FurFarmandFork

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Posted 30 August 2018 - 06:17 PM

You don't need your entire relationship fleeced out. Submit your POLICY that states that you have established that manufacturer as your backup and consider them an approved supplier in the event of an emergency. A bunch of scanned emails isn't good documentation.

 

Put it in the SOP/Policy/Record you use to support your crisis management plan as the corrective action. As a preventive action indicate that you will review your backup supplier annually when you review the crisis managment plan and keep a record of doing so, and put THAT procedure in your SOP as well.


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#7 jcieslowski

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Posted 04 September 2018 - 08:07 PM

I was thinking along Scampi's line of thought.

 

What if you put in a program something like "In the event of catastrophic damage, all operations will cease until such a time as to repairs can be made and food safety is assured."  (maybe with reference to the emergency maintenance plan for how you're going to sanitize work areas).

 

Why isn't "We short our customers" an acceptable answer?  Or "we fold up shop and find new jobs" or whatever.  It's not really in the scope of SQF to care about the business / supply needs of the customer or the plant, only that produced food is safe.






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