28 replies to this topic

[Jean Carmona]

I am just starting to set up my organization's SQF Program and visited one of our sister plants this week regarding how they're currently maintaining their program - They recieved two excellents in a row. I asked about EMP and the Quality Manager stated that they perform random micro tests on finished goods product to prove that all their programs are working, in addition, this is also how they validate. An operation risk management assessment is also completed for this process. They have not had their audit on Ed. 8 yet, but I'll reply to this thread sometime in December after their audit if this sufficed the EMP.

 

Awesome Julie, Thanks! 

[Scampi]

an EMP isn't supposed to be performed on FG, it is for the plant itself where harbor points could affect the safety of your product.........so this will be a good one to get feedback from!

 

from the guidance

 

What does it mean? An environmental monitoring program must be in place for food processes that are handled, exposed, stored, processed or packed. This program should be included for food processes of all risk levels. This element outlines the specific conditions required in areas where foods are processed or handled. Conditions like these may contain pathogenic microorganisms and will support the formation of toxins or growth of pathogenic microorganisms, and has a likelihood of growth causing illness or injury to a consumer if not properly produced, processed, distributed and/or prepared for consumption. It may also apply to a food that is deemed high risk by a customer, declared a risk by the relevant food regulation or has caused a major foodborne illness outbreak (refer SQF Code, Appendix 2: Glossary).

[Charles.C]

It's amazing how so much confusion can be generated regarding something which most (Packaging) people seem to agree is almost always of minimal risk towards Food Safety.

 

SQF,  you have a lot to answer for !. And seemingly so far very little official response ?

[Scampi]

I have to say Charles.......I've read through ALOT of manuals over the years.........and SQF is one of the WORST

 

Part of me (a very very very small part) feels bad for the auditors..........like this EMP, code says a MAJOR for not having a plan..............but the guidance says nope, that's not right.........

 

The "technical managers" and i'm using that term lightly should be raising their collective voices and saying this isn't right

 

At least government regulations get reviewed repeatedly by lawyers so at the VERY least the intent is clear..............maybe these GFSI folks might want to think about adding a lawyer or two to the mix when codes are being revised.............but then they wouldn't have to force us to change every year when they issue another revison because "we're sorry, we didn't get it right the first time"