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SQF 8 meeting FSMA requirements NC


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#1 The Food Scientist

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Posted 19 October 2018 - 04:09 PM

So we recently been through an SQF 8 audit. One of our non-conformances was that there is no evidence of FSMA implementation is present. I am a little confused on this one, since we do have a supplier approval program, sanitation, CCPs and a HACCP program. Would the first step to implement it be taking the PCQI course? I mean we do have only a few days to have a corrective action. Would proof of registering for PCQI be sufficient? Thanks


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#2 FSQA

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Posted 19 October 2018 - 05:32 PM

A little more description would be required to your product/process, to determine if you require further programs to comply (FSVP/Preventive Control and others).

SQF, as like other major GFSI schemes, requires to be complaint to regulations pertaining to the site.

 

Starting up with a a PCQI course is a good idea as you will require a minimum of an individual who is a qualified individual to setup your programs (aligned with FSMA regulations).

https://www.ifsh.iit...rols-human-food

 

Following is a good webinar, that was presented through IFSQN, related to FSMA and HACCP:

https://www.ifsqn.co...compliance-r153



#3 mgourley

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Posted 21 October 2018 - 04:18 PM

I'm not SQF, but as FSQA states, your NC was probably because you are not in compliance with "regulations". BRC requires much the same thing.
Registration for a PCQI course may or may not be acceptable to the CB, since registration for a course is not the same thing as actually having a PCQI, which is a requirement of FSMA.

 

I guess the bigger question would be, since you are in the US, why you don't already have one or more people certified as a PCQI?

 

Marshall



#4 MsMars

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Posted 22 October 2018 - 05:02 PM

HACCP does not equal Preventive Controls. Yes - your first step will be to register for the PCQI program, but you will also need to heed the information given to you during the course and modify your programs accordingly so that you can be in compliance with FSMA requirements when the FDA comes knocking.  If you only have a limited time span before your CA are due for SQF certification, outline your plan for attending the course and getting your food safety program in line with FSMA requirements. 






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