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Document Control Urgent - in the middle of an audit

SQF Doc Control

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#1 springsangel

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Posted 21 September 2018 - 02:25 AM

I tried finding this answer - but I was finding conflicting information.    I am in the middle of our first SQF Audit- to Version 8. 

 

My Document Master List, has the Doc Number, Revision Number, Desc.  Dept  Person Responsible, Date of Issue, and reason for change

 

The auditor has has written us so far for 6 Doc Control issues and days we HAVE to put the Date of the last change and the reason for the  change and the person approving the change ON the document. 

 

We are using an online Doc Control program that will save and record all that information.  I even showed her. She told me to either put it on every document, or print out the screen from the software and attach it??? 

 This basically defeats the entire purpose of the software

 

Please help!!

 



#2 Tony-C

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Posted 21 September 2018 - 04:48 AM

Hi springsangel,

 

Don’t panic!. So, it appears that you are compliant with the SQF Code requirements and the guidance supports this:

 

The SQF Code, Edition 8 SQF System Elements for Food Manufacturing

2.2.2 Document Control (Mandatory)

2.2.2.1 The methods and responsibility for maintaining document control and ensuring staff have access to documents shall be documented and implemented.

2.2.2.2 A register of current SQF System documents and amendments to documents shall be maintained.

2.2.2.3 Documents shall be safely stored and readily accessible.

 

2.2.2 Implementation Guidance

What does it mean?

Documents can be stored electronically or be paper-based, or a blend of both. However the current copy of the relevant documents must be available to staff and employees that need to use them. A list of documents and amendments to documents must be maintained to identify the current documents in use.

What do I have to do?

This element is mandatory. To comply with this requirement, the supplier must designate a staff member who is responsible for document storage and security and how documents are controlled; distributing current versions to relevant employees; and ensuring that documents are up-to-date. Worn, illegible or out-of-date documents must be replaced. A written procedure describing how documents will be maintained, updated and replaced must be developed and in place.

A register of all documents must be maintained including when they were issued, updated and who has a copy of each document. Documents referred to include, for example, pre-requisite programs, food safety plans, SSOPs, SOPs, other work instructions and raw material and finished product specifications, etc.

 

2.2.2 Auditing Guidance

The auditor needs to seek evidence of the existence of a document control procedure at the desk audit and compliance to this requirement by observation, interview with the responsible person and interviews with staff to ensure they have current documents available. Evidence may include:

- Review of the document control procedure;

- Review of the document register and list of amendments, and their accuracy;

- Availability and currency of documents in use;

- Security and storage of documents;

- All personnel who need access to specific documents such as food safety plans, procedures, customer specifications and applicable food regulations have such access.

 

Point all this out to the auditor, if they still persist you can take this up with the certification body (they will remove the non-conformance if you have evidence that contradicts the auditor findings).

 

Finally don’t get into a heated exchange with the auditor, merely present the facts.

 

Kind regards,

 

Tony



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#3 Tony-C

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Posted 21 September 2018 - 05:01 AM

Further to my previous post, see SQF Code 5. Obligations of Sites and Certification Bodies 5.10 Complaints, Appeals and Disputes

 

Kind regards,

 

Tony



#4 springsangel

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Posted 21 September 2018 - 09:11 AM

Thank you!  I believed I was right, but she was so adamant.   And I had already tried to explain it.   



#5 TN JK

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Posted 22 September 2018 - 03:08 AM

All the best. Time and again it goes back to issue of calibration of auditors' auditing competencies.



#6 SQFconsultant

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Posted 23 September 2018 - 02:48 AM

There is unfortunately a lot of fallout in auditing these days. The standards getting tougher and more and more complex puts a tremendous amount of pressure on the Auditors and getting miss-informed (as in the auditors sometimes creating things that are not standards) due to all the new stuff creates these kind of issues.

 

You will need to challenge this - it is clear from what you indicated that you meet the requirements of 8.0 and the Auditor did miss-calls.


Kind regards,

 

Glenn Oster
 
 
GOC GROUP / +1.800.793.7042 / Food - Food Packaging - Food Storage/DC

SQF, BRC & IFS System Development, Implementation & Certification Consultants

Serving Small-to-Mid-Size Businesses | International Cross-Border C-CUR Acceptance

Internal Auditor Training | eConsultant | SQF, BRC & IFS Pre-Development or Pre-Audit GAP

http://www.GlennOsterConsulting.com  -- 

 

 

URGENT - We need your help...

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#7 Charles.C

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Posted 23 September 2018 - 03:13 AM

I tried finding this answer - but I was finding conflicting information.    I am in the middle of our first SQF Audit- to Version 8. 

 

My Document Master List, has the Doc Number, Revision Number, Desc.  Dept  Person Responsible, Date of Issue, and reason for change

 

The auditor has has written us so far for 6 Doc Control issues and days we HAVE to put the Date of the last change and the reason for the  change and the person approving the change ON the document. 

 

We are using an online Doc Control program that will save and record all that information.  I even showed her. She told me to either put it on every document, or print out the screen from the software and attach it??? 

 This basically defeats the entire purpose of the software

 

Please help!!

 

Hi springsangel,

 

Having seen this "clanger", I am curious as to any other fall-out in the rest of the audit ?

 

My guess is yr auditor was an extreme "newbie"  however i can still recall being somewhat shocked/depressed when a Lead Auditor of a group of three requested me to validate that maintaining  a temperature of less than 4degC was a typical  objective for deterring  microbiological growth in chilled raw materials.


Kind Regards,

 

Charles.C


#8 springsangel

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Posted 23 September 2018 - 12:19 PM

Well, she wrote this an other things I do not agree with.  She is coming back in November for our onsite portion.   If I challenge her now, is it going to make her more aggressive or unfair on the next audit?  I know it shouldn't, but will it?

She wrote up Document Control for this, and because we didn't start all documents at Rev 00 ??  Our software will not let you start at 00-  I explained this to her, and she said no, it must start at 00?  Is this a FMSA or HACCP principle that I am missing?

 

Also - we are doing SQF Quality at the same time, so I found where 2 of her minors were because we met SQF 8, but not Quality.  

 

She also wrote us for missing "documentation".  We argues repeatedly, because we have it documented in work instruction, but not in 1 policy, or 1 procedure that outlines ALL the procedures.  She kept saying I want to see it in 1 place and reference the other procedures.   For Example  11.6.1 - ( we have no cold storage)  it is outlined in 3 Procedures - and she wouldn't accept it.  

 

She did the same for 11.9 ( same thing in 3 procedures)

and for 11.10  ( its in our building maintenance and GMP and our monthly GMP audit)

 

and 11.2.13 - and there is over 20 procedures for this.  

 

 

 

 

 

Any guidance would be greatly appreciated.   We only have 13 people total and she is adding so much work. ( Not just for above.. I didn't list everything she wanted)



#9 SQFconsultant

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Posted 23 September 2018 - 05:05 PM

OK, I must admit I thought when you said you were in the middle of an audit you meant the cert audit and not a desk audit - that is what I am getting now.

 

All things considered I'd ask for a new Auditor explaining to the CB why you feel that way, etc.

 

If this is your first SQF audit series how is it that you are going for the quality level without stopping at what was level II before?

 

And, also if this was just a desk audit (that is not graded, scored, etc) I'd ask for a re-do with a different auditor - it will cost you some change but will be worth it.


Kind regards,

 

Glenn Oster
 
 
GOC GROUP / +1.800.793.7042 / Food - Food Packaging - Food Storage/DC

SQF, BRC & IFS System Development, Implementation & Certification Consultants

Serving Small-to-Mid-Size Businesses | International Cross-Border C-CUR Acceptance

Internal Auditor Training | eConsultant | SQF, BRC & IFS Pre-Development or Pre-Audit GAP

http://www.GlennOsterConsulting.com  -- 

 

 

URGENT - We need your help...

https://bit.ly/3kBj997

 

 

 

 

 

 

 

 

 
 
 
 
 
 
 
 
 

#10 springsangel

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Posted 23 September 2018 - 10:06 PM

Sorry,  I wasn't clear, yes it was the desk audit.  

You are apparently allowed to do both at the same time, and ownership decided 30 days before to add it.  We knew would be hit on the quality side a bit.  Those I am ok with.  

 

Am I correct that the word "document" does not mean policy, and that multiple procedures to cover it, is sufficient?

 

And what about the version 00 thing?  One of the older guys at the plant says that is how they used to do it where he came from, but wasn't sure it was a requirement. 



#11 Scampi

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Posted 24 September 2018 - 12:46 PM

it is YOUR plan YOU decide how to number/classify documents in a way the is consistent and easily explained

 

It sounds to me like auditor has come from a HUGE company background, I have worked in places where a Policy does list all of the records, SOPs etc that are associated with it, but for most companies that kind of complexity doesn't make sense.

 

The whole premise of auditors is that they are to audit to the standard...............not what they would do or have seen before

 

 

When you are being audited, have a copy of the code AND the guidance with you............if something sounds fishy, reference the code etc. and ask for a specific mention in those SQFI generated docs, particularly at the desk audit when you are still in the prep phase

 

I agree with PP, ask for a new auditor


Because we always have is never an appropriate response!


#12 sqflady

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Posted 28 September 2018 - 01:03 PM

As others have said, request a new auditor.  You are paying the certification body for their service.  You do not need that kind of auditor.



#13 FurFarmandFork

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Posted 28 September 2018 - 11:30 PM

Agree with everyone above.  

 

She kept saying I want to see it in 1 place and reference the other procedures.

 

 

Your food safety system are in place to help your company produce safe food, not to be convenient for the auditor. Use this quote to demonstrate how this person is not auditing the standard, but instead their belief in how you should construct your system.


Austin Bouck
Owner/Consultant at Fur, Farm, and Fork.
Consulting for companies needing effective, lean food safety systems and solutions.

Subscribe to the blog at furfarmandfork.com for food safety research, insights, and analysis.




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