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SQF Food, 2.5.2 Verification Activities

sqf food verification 2.5 audit

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#1 Brendan Triplett

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Posted 10 September 2018 - 03:13 PM

Hey all,

 

I am working through desk audit information and running into a bit of a wall with the verification.  Code reads:

 

2.5.2.1 A verification schedule outlining the verification activities, their frequency of completion and the person responsible for each activity shall be prepared and implemented

 

My questions are these.  Would we be doing this for every PRP and GDP and SQF System Element that we review in the SQF and the HACCP?  Will I need to have review sheets created at a lower level for each of these items so that they can be reviewed for verification?  How does this differ from the monitoring activities that are found in 2.5.2.2?  Are there any current examples out there (most of what I see in the forums is from some time ago and may no longer be accurate)?

 

Lots of questions I know but this is the first section that has me thinking that there may be dozens of sheets of inspections that should be attached for all of the functions.

 

Cheers!


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#2 Scampi

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Posted 10 September 2018 - 05:43 PM

This is the SQF definition of "verification"
 
A
system, which identifies, evaluates and controls hazards which are significant for food
safety. Essentially verification as applied to control measures seeks to prove that the
control measure was done according to its design.
 
So you should verify CCP's and any control points yearly that they still apply

Because we always have is never an appropriate response!


#3 FurFarmandFork

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Posted 10 September 2018 - 08:50 PM

I hate that particular clause. It inevitably leads to an auditor asking for a specific checklist of verification activities. I inevitably respond with "which program verification do you want to see". I refuse to maintain a separate list for the auditors benefit when each program has it's own schedule.

 

Defer to Scampi, know what the definition of a verification activity is, have the intervals defined and proof that they were completed, and be ready to speak to it/explain how your system works to the auditor.


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#4 Brendan Triplett

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Posted 11 September 2018 - 09:43 AM

I am of the same thinking, that the auditor will be asking for some sort of master list that will detail all of the information out for them.  I am guessing that each item will need to have its own monitoring program.. I can validate the programs annually but I think that I will invariably end up needing to create a separate program for each PRP, GDP or element that I bring attention to in my HACCP and/or SQF books.  Would you guys have any examples or anything that you could share to point me in the right direction?  Cheers!


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#5 Brendan Triplett

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Posted 12 September 2018 - 08:54 AM

FFF,

 

Do you find that not maintaining a list for the auditors benefit upsets them in any way.  I would hate to do this and then suddenly find myself in a combative relationship with the auditor.  Or worse I ask them which they want to see and they just say "give us everything."


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#6 Scampi

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Posted 12 September 2018 - 12:23 PM

I have a "verification schedule" that the auditor did ask for yesterday..........however it is a VERY vague list that is simply months of the year across the top and SQF elements down the left with a box saying which element is done when, but it would take 3 days to verify that alone so I don't expect it would ever get that far


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#7 Brendan Triplett

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Posted 13 September 2018 - 01:28 AM

Thanks Scampi,

I guess my worry was that they would be looking for some sort ofmincredibly detailed form that would reference a bunch of other programs. It all seemed redundant. Did the auditor like your sheet?


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#8 Scampi

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Posted 13 September 2018 - 04:07 PM

Auditor was satisfied..........you should also use it so that you know you've reviewed your entire program yearly, if you don't have a schedule, how would you know?

 

You also know if you have any down times when you are more likely to review the more challenging parts of your program

 

Also, any CCP's will have a separate validation/verification schedule.....make sure that is in place


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#9 Brendan Triplett

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Posted 03 October 2018 - 03:56 PM

Scampi,

 

I was just going back to this for review.  So I just need a schedule (something vague) that lets me know that elements are being verified, their frequency and the responsible party?  So I won't need a monitoring sheet that I have filled out everyday by employees on the floor?  It would create an incredible amount of paperwork if I need to have a lot of monitoring.  As of now I have what you mentioned - the spreadsheets with months, activities and checkmarks for every PRP and SQF System Element.

 

Secondly, I have validation programs for each one of my PRPs but not for anything else.  They look like this:

 

Attached File  Validation Summary Report - Allergen Control.docx   18.45KB   46 downloads

 

Should I be creating these for system elements such as Document Control and Product Trace?

 

Thanks!


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#10 Scampi

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Posted 03 October 2018 - 04:30 PM

Basically your validation schedule would be the same for HACCP, each section needs an annual review that's why I keep it vague, but each element has sub-elements that may also need re-evaluated

 

You should have a POLICY  for doc control and trace and in the policy it lists associated document so no, I wouldn't be creating a report for those (depending on how many fingers are in that cookie jar of course) but if it's just you and 1 other person who can issue docs than no

 

The product trace exercises are the yearly evaluation............just ensure your policy states that if there is a change to the HACCP system, another trace exercise will also be performed

 

Also, you may want to add the list of associate docs to your validation programs so that when you do perform it, you havn't missed anything. It sounds like a big job now,but you'll like come next annual review


Because we always have is never an appropriate response!


#11 Brendan Triplett

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Posted 03 October 2018 - 04:41 PM

That makes sense.  So I will be verifying all of the elements but that doesn't necessarily mean that I will need to validate every system element through a specific, signed-off form.  I found a verification schedule in the forums that looks like this:

 

Attached File  Monitoring & Verification Activities.pdf   325.42KB   65 downloads

 

Is this overkill?  The code does call for every item to be spelled out in the sense of who is doing the verification and how often it is done.  I like the one that I have now but it may need to be upgraded to something in between the vague of the current versus the complex of this form.

 

Thanks for the assist.


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#12 Scampi

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Posted 03 October 2018 - 04:53 PM

Looks great!!!!

 

at my PP we had actual reassessment forms for each sub-element. It would tell you to grab 5 random records etc and you wrote them all in (but this was in a complex poultry operation where 10 million things could go wrong) and that took 3 days/week of my time

 

You don't even need a separate record to VERIFY a CCP.........let's say you take the SOP out on the floor to verify employee A is performing task as per the SOP......you simply record the date time etc on that form. As long as it matches what you say you will do........so the nice file that you attached in pdf works perfectly and MAKES sense for your operations

 

as to the code it also says something really strange

 

2.5.2.2 The methods, responsibility and criteria for verifying monitoring of Good Manufacturing Practices, critical
control points and other food safety controls, and the legality of certified products, shall be documented and
implemented. The methods applied shall ensure that personnel with responsibility for verifying monitoring
activities authorize each verified record. ??????????????????  WTH does that mean..........to me that reads people should be checking their own work???

Because we always have is never an appropriate response!


#13 MsMars

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Posted 03 October 2018 - 04:55 PM

That makes sense.  So I will be verifying all of the elements but that doesn't necessarily mean that I will need to validate every system element through a specific, signed-off form.  I found a verification schedule in the forums that looks like this:

 

attachicon.gif Monitoring & Verification Activities.pdf

 

Is this overkill?  The code does call for every item to be spelled out in the sense of who is doing the verification and how often it is done.  I like the one that I have now but it may need to be upgraded to something in between the vague of the current versus the complex of this form.

 

Thanks for the assist.

 

I've used a similar form to this in the past, only slightly simpler with the who, how, and frequency.  Do what works with how you have your system set up and your history with your auditor.  If it helps you to include guidance and specific documents to reference, or if your auditor has suggested you use that format, then include those too. I think if you have the who, what, how, and frequency of verification documented in some useable way, they won't throw too much of a fit.  Our auditor had no qualms with ours.



#14 MsMars

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Posted 03 October 2018 - 04:58 PM

 

as to the code it also says something really strange

 

2.5.2.2 The methods, responsibility and criteria for verifying monitoring of Good Manufacturing Practices, critical
control points and other food safety controls, and the legality of certified products, shall be documented and
implemented. The methods applied shall ensure that personnel with responsibility for verifying monitoring
activities authorize each verified record. ??????????????????  WTH does that mean..........to me that reads people should be checking their own work???

 

 

I've always interpreted that as managers checking monitor's work and verifying then signing off on monitor's record, just with a very complicated wording.  I could be wrong.  :dunno:



#15 Brendan Triplett

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Posted 03 October 2018 - 05:05 PM

So you are saying that I can verify the activities/elements using this program, couple it with having "monitoring" documents signed or checked on the floor AND THEN validate only my PRPs in the format from my earlier post I will completely satisfy 2.5.1 and 2.5.2.  Basically running the whole process through Monitor, Verify and the PRPs through Validate.  I will need to create a bunch of extra documents but that doesn't necessarily mean that every single system requirement will require them all.  Am I on the right track with this line of thinking?


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#16 Scampi

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Posted 03 October 2018 - 05:06 PM

MsMars you and I both know that's what SHOULD occur, but if you're new to SQF how in gods name could you ever figure out what that is supposed to mean!!  I mean it's laughable.........and they wonder why facilities have a hard time????


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#17 Brendan Triplett

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Posted 04 October 2018 - 12:30 PM

So today I have resolved to do a verification and validation of every system element in SQF and every PRP in my HACCP Plan.  It will be a ton of paperwork but once it is done it will be done.  Stop me if this is overkill lol


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#18 Scampi

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Posted 04 October 2018 - 12:34 PM

It isn't overkill Brendan, it's what's required

 

Alot of items will only take a minute...........like a PRP for laundered uniforms.........your program says an outside vendor supplies the smocks........you didn't have any issue last 12 months, smocks always available..........you're done!

 

AND if this isn't done, how do you really know if A) all of it is required?  and B) any of it is actually working

 

 

This is where you usually find out some random (but important) process has changed and you didn't know  (i always blame maintenance and Ops lol)


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#19 Brendan Triplett

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Posted 04 October 2018 - 12:42 PM

Thanks Scampi,

 

I think the pain I was running into was whether or not everything needed to have a verification plan AND a validation.  I reread the manual and my gut told me to just do it.


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#20 Brendan Triplett

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Posted 04 October 2018 - 12:43 PM

I will post my reports once I have them finished.  maybe it will save someone else from the nightmare lol


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#21 Scampi

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Posted 04 October 2018 - 02:26 PM

sorry maybe I missed something...............you don't need to VALIDATE everything.......this is where SQF muddied the water with the incorrect definitions

 

CCP and CP should be validated, but you only ever need to do that once...........so let's say a blast freezer needs VALIDATED to ensure it can meet time/temp requirements under worst case scenario..........you would run data loggers all over the place, review the data and yep, blast freezer is capabale of above........that's a VALIDATION

 

 

Then once/year, you would look specifically at the program and records for that step (blast) to ensure it ALWAYS met the requirement...........you've VERIFIED that it is STILL working


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#22 FurFarmandFork

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Posted 04 October 2018 - 10:24 PM

FFF,

 

Do you find that not maintaining a list for the auditors benefit upsets them in any way.  I would hate to do this and then suddenly find myself in a combative relationship with the auditor.  Or worse I ask them which they want to see and they just say "give us everything."

 

Sorry for the late reply.

 

It has depended on the auditor. Typically I turn it against them and keep asking them what program they want to see verified. I have had them get testy so you have to be willing to stick it on this point. I have a list of things worth fighting about and ones not worth fighting about. I'd found this one to be worth it because it adds unnecessary documentation to my program for no benefit other than the auditor's. If I saw an additional benefit I would make another checklist.


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#23 dahna4me

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Posted 28 October 2018 - 10:06 PM

That makes sense.  So I will be verifying all of the elements but that doesn't necessarily mean that I will need to validate every system element through a specific, signed-off form.  I found a verification schedule in the forums that looks like this:

 

attachicon.gif Monitoring & Verification Activities.pdf

 

Is this overkill?  The code does call for every item to be spelled out in the sense of who is doing the verification and how often it is done.  I like the one that I have now but it may need to be upgraded to something in between the vague of the current versus the complex of this form.

 

Thanks for the assist.

Good work!!

Would you not also include pre-operational inspections (daily) as verification of the cleaning program, and that,  or other means, for verifying the effectiveness of waste disposal?                                                            See  SQF code " 11.2.13.5 Pre-operational inspections shall be conducted following cleaning and sanitation operations to ensure food processing areas, product contact surfaces, equipment, staff amenities and sanitary facilities and other essential areas are clean before the commencement of production. Pre-operational inspections shall be conducted by qualified personnel'  AND  " 11.9.1.9 Reviews of the effectiveness of waste management will form part of daily hygiene inspections and the results of these inspections shall be included in the relevant hygiene reports"



#24 Charles.C

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Posted 29 October 2018 - 04:52 AM

I note this thread focuses on "Verification"(Ve). However this unavoidably involves an appreciation of the difference between Validation(Va) and Ve. Otherwise a post tends to become unintelligible.

 

A, IMO, logical and readable explanation of Validation is the classic document issued by FSIS, ca 2014. Frequently posted on this Forum.

 

I assume the SQF/Va/Ve situation in Ver8 is unchanged from ver7.2.

 

It seems that the terms validation and verification are still being intermingled as arbitrarily as always.

 

This topic has been a SQF/SQF auditor, notorious headache for at least 10 years.

 

A few years back SQF changed their official viewpoint on Validation at the time of issuing ver.7.2. Unfortunately many of their auditors were (and possibly still are) unable to follow the change. Subsequently  SQF acknowledged the internal confusion and published a definitive statement as to the intended interpretation on their website. May even still be there.

 

Just as an example, PRPs were/are(?) definitively not required to be validated. Only verified. But some auditors will probably, adamantly, still disagree. Net result - for a quiet life, no choice but to provide what the auditor expects to see.

 

Verification is relatively less controversial but still open to conflicting viewpoints as to the data employed.

 

There are one or two quite comprehensively scoped attachments previously posted here (ver 7.2) on what SQF auditors typically  expect to see to represent "Verification". Notably, IIRC, one excel document from Marshall (mgourley).

 

I strongly suggest to do a little searching.

 

I cannot offhand imagine why SQF would want people to validate a control point. Is it specifically stated to be so required ?

 

Similarly, unless specifically stated to be required, Validations logically do not need routinely repeating unless some significant change has occurred to the specific item involved. Verifications maybe more likely to require updating  but depending on the item. In the case of a CCP, monitoring is presumably giving self-verification.


Kind Regards,

 

Charles.C


#25 Scampi

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Posted 30 October 2018 - 01:47 PM

I agree Charles

 

Everyone ought to follow Codex HACCP verification and validation systems and ignore the SQF confusion entirely (the definitions in SQF 8 do not clarify things at all)

 

 

2.5.1 Validation and Effectiveness (Mandatory)
2.5.1.1 The methods, responsibility and criteria for ensuring the effectiveness of all applicable elements of the
SQF Program shall be documented and implemented. The methods applied shall ensure that:
i. Good Manufacturing Practices are confirmed to ensure they achieve the required result;
ii. Critical food safety limits are validated, and re-validated annually; NO absolutely not........if your CCP has not changed (equipment, type, pack size etc) then you NEVER need to perform a VALIDATION again..........you're annual CCP review would require you to VERIFY all of the CCP including records and deviations to ensure the CCP VALIDATION is still controlling the hazard----if you were in constant deviation then you would want to perform a NEW validation with NEW parameters......................SQF has got this backwards completely
iii. Changes to the processes or procedures are assessed to ensure controls are still effective; and
iv. All applicable elements of the SQF Program are implemented and effective.
2.5.1.2 Records of all validation activities shall be maintained. You would only have VALIDATION activities that were NEW if a new process etc. had been implemented. The only documentation you should have otherwise is the ORIGINAL validation(s) that were performed.
2.5.2 Verification Activities (Mandatory) This would be ALL of the records used to VERIFY things.........so CCP records etc.
2.5.2.1 A verification schedule outlining the verification activities, their frequency of completion and the person
responsible for each activity shall be prepared and implemented.This schedule would be super high level broken down by frequency then I would just use the sub element and add no further detail
2.5.2.2 The methods, responsibility and criteria for verifying monitoring of Good Manufacturing Practices, critical
control points and other food safety controls, and the legality of certified products, shall be documented and
implemented. The methods applied shall ensure that personnel with responsibility for verifying monitoring
activities authorize each verified record.
2.5.2.3 Records of the verification of monitoring activities shall be maintained.
 
 
Below are well explained (correct IMHO) definitions of verification vs validation

 

 

https://articles.ext...dation-of-haccp

Verification

Webster defines verification as “To establish the truth, accuracy, or reality of.” The National Academy Committee on Microbiological Criteria further defines verification for HACCP for Foods (NACMCF, 1997) as “Those activities other than monitoring that determine the validity of and compliance with the HACCP plan.” Several tasks should be identified as verification activities for the HACCP system. These include verification of prerequisite programs, verification of the critical control points, and verification of the overall HACCP plan. In addition, the regulations in 9 CFR 417 identifies verification activities that which will be performed by the USDA inspectors. Companies may also consider involving outside experts in an audit or may send personnel to suppliers of food ingredients to verify HACCP and food safety plans.

 

 

Validation

Validation is also part of Principle 6, Establish Verification Procedures. Validation is defined as “to support or corroborate on a sound or authoritative basis” or to “establish validity of the HACCP plan by supplying factual proof.” Within HACCP, validation is “the element of verification focused on collecting and evaluating scientific and technical information to determine if the HACCP plan, when properly implemented, will effectively control the hazards” (NACFMF, 1997). Validation can be accomplished by conducting in-plant studies, providing literature citations, and conducting pathogen inoculation studies in controlled laboratory settings.


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