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Training Record Requirements in SQF


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#1 Brothbro

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Posted 18 September 2018 - 02:37 PM

Hi Everyone,

 

I have a few questions about SQF's requirements for a training program, and more specifically their documentation requirements for training records. I am currently head of training for the QA department at a Broth/Beverage plant in the US. Unfortunately when I came into this position we had no cohesive training records or training plan in place. My record system I've developed document's a QA staff member's training/understanding of each individual procedure/SOP, along with signoffs from the trainer, trainee, and supervisor. Because of the lack of records for our existing employees, I'm working to get both the veteran staff and newly hired staff documented on training at the same time. Obviously it's been a pretty tedious process! We have hundreds of SOPs, so it's become a massive spreadsheet that requires hundreds of signoffs. After reviewing the SQF code some more, it looks like SQF does not require training documentation on every single SOP or task that an employee performs. It seems to me that it implies that records are required for general duties related to CQP monitoring and FQP-related material. 

 

So here are some questions I'd like to pose for advice from everyone:

-How should I handle retroactively signing off veteran employee's training on their duties? Everyone is performing well and is obviously proficient (we conduct proficiency testing). Should the date of signoff be their hire date?

 

-Does SQF require training records for -all- SOPs that a company has written? For instance, we have an SOP on how to test protein using our benchtop equipment. We also have an SOP for -when- to test protein depending on the product. Protein testing is a CQP, so naturally the SOP for how to test protein requires documentation. But the SOP related to when in the process protein testing is required, would this require documentation as well? Additionally, what about non-testing procedures, like how to clean a pH meter, or what to do when finished goods packaging material is expired?\

 

Apologies if this belongs in the Training & Documentations subforum. As I'm specifically asking about SQF, I figured I'd post here! If moderators disagree, please feel free to move my topic to the appropriate subforum.



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#2 Tony-C

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Posted 19 September 2018 - 04:00 AM

Hi Brothbro,

 

:welcome:

Welcome to the IFSQN forums.

 

I would prioritise your training based on the requirements of the SQF Code:

 

SQF Code 8 - SQF System Elements for Food Manufacturing

2.9.2 Training Program (Mandatory)

2.9.2.1 An employee training program shall be documented and implemented. It shall outline the necessary competencies for specific duties and the training methods to be applied for those staff carrying out tasks associated with:

i. Developing and applying Good Manufacturing Practices;

ii. Applying food regulatory requirements;

iii. Steps identified by the hazard analysis and/or other instructions as critical to effective implementation of the food safety plan and the maintenance of food safety; and

iv. Tasks identified as critical to meeting the effective implementation and maintenance of the SQF System.

2.9.3 Instructions

2.9.3.1 Instructions shall be available in the languages relevant to the staff, explaining how all tasks critical to meeting regulatory compliance, the maintenance of food safety and process efficiency are to be performed.

2.9.4 HACCP Training Requirements

2.9.4.1 HACCP training shall be provided for staff involved in developing and maintaining food safety plans.

 

SQF Code 8 Guidance - What do I have to do?

This is a mandatory element.

The following programs are considered the minimum required elements for employee training. They can be offered as classroom training or on-the-job training by qualified personnel. Sometimes training can be offered through team meetings. Type and depth of training will depend upon the employee’s work designation. Requirements may include:

-      Job/task performance

-      Company food safety policies and procedures

-      Good Manufacturing Practices, including regulatory compliance

-      Cleaning and sanitation procedures

-      HACCP overview, and specific roles within the HACCP plan

-      Bio security and food defense

-      Chemical control

-      Hazard communication

-      Foodborne pathogens

-      Allergen management

-      Emergency preparedness

 

You will probably want to add your CQP procedures and records training to this list.

 

For veteran staff I would log when you believe they were trained initially but sign off the training during your proficiency review (after confirming competence).

 

Testing frequency could be included in the protein testing procedure or a ‘global testing schedule’

 

Attached File  Sample Plan.pdf   256.97KB   373 downloads

 

You are talking a lot about Quality, are you looking to certification to the SQF Quality Code as well?

 

Control of expired finished goods packaging material is important because most food recalls are caused by incorrect labelling, with many of these recalls being caused by the use of obsolete packaging/labels, so I would include that in your training.

 

Kind regards,

 

Tony



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#3 Brothbro

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Posted 19 September 2018 - 03:51 PM

Thank you Tony!

 

That's a good idea on how to handle veteran employee signoffs, and I really like your idea of a global testing schedule!

 

You're right, I should have mentioned from the start, I'm speaking to the Training requirements of the SQF Quality Code 8th Ed. The training requirements of the baseline SQF Code (which you have referenced) are actually already well recorded and implemented in our plant. An overview of HACCP and the HACCP plan specific to our plant is thoroughly trained and documented, as well as routine GMP courses complete with refreshers. I'm more concerned with the training documentation for basic laboratory tasks and checks that fall outside of our CCPs.

 

 

Excerpts from SQF Quality Code 8th Ed.:

2.9.1 Training Requirements

2.9.1.1 Appropriate training shall be provided for personnel carrying out the tasks critical to the effective

 

implementation of the SQF Quality System and the maintenance and improvement of quality requirements.

2.9.2 Training Program

2.9.2.1 The employee training program shall include the necessary competencies for specific duties and the training
methods to be applied for those staff carrying out tasks associated with:
i. Process control and monitoring of critical quality points (CQPs);
ii. Steps identified as critical to effective implementation of the food quality plan and the maintenance of food
quality, and
iii. Product inspection and testing.
2.9.2.2 The employee training program shall include applicable statistical process control training for line operators,
quality inspectors and supervisory staff responsible for operating and inspecting key manufacturing processes.
2.9.2.3 The training program shall include training, calibration and proficiency testing of internal laboratory
personnel.
2.9.7 Training Skills Register
2.9.7.1 A training skills register describing who has been trained in relevant skills shall be maintained. The register
shall indicate the:
i. Participant name;
ii. Skills description;
iii. Description of the training provided;
iv. Date training completed;
v. Trainer or training provider; and
vi. Supervisor’s verification the training was completed and that the trainee is competent to complete the
required tasks.

 

A big part of my question really boils down to the requirements of 2.9.7 in the SQF Quality Code. The code talks of "skills" rather than procedures or methods. Would an adequate training skills register list "Production Quality Monitoring" as a single skill/signoff, rather than 10 different signoffs for pH, Brix, Moisture, Protein, etc testing? For instance, training on "Production Quality Monitoring" would include how to perform certain relevant laboratory tests, but also how often to pull samples from the line for testing and corrective actions to take should the quality be measured outside of spec. An employee trained and signed off on "Production Quality Monitoring" would be expected to be able to handle all routine QA checks during live production. It would be great to handle that entire concept as one signoff, rather than dozens of signoffs for each individual procedure that this process incorporates.

 

I appreciate your feedback!



#4 Scampi

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Posted 19 September 2018 - 04:58 PM

I would lump like tasks together for lab employees............make sure however, that someone is verifying annually that they are following the SOPs! That is the "proficiency" subsection covered off..........if you shadow them once/year for each SOP and found they are following said SOP that you have verified proficiency


Edited by Scampi, 19 September 2018 - 05:00 PM.

Please stop referring to me as Sir/sirs


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