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noahchris97

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Posted 30 October 2018 - 05:14 PM

Afternoon,

                Just finished with SQF 8 audit...I ran out of bandaids, anyone have some.  :crying:  For 2.4.1.1 PCQI certification. I am 3 months new at a chocolate facility. I am the new QA Manager. Time before this was a plant manager and now back into the QA world. I have gone through a course at GFTC in Ontario, Canada in 2013. The Course US FDA Food Safety Modernization Act - FSMA Preventive Controls For Human Food. Now would this be sufficient / qualify for PCQI certified.. What was trained on is listed in the link below.. Just looking to see if I would be compliant with this clause..Thanks. 

 

 

www.fda.gov/Food/GuidanceRegulation/FSMA/ucm334115.htm  



SQFconsultant

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Posted 30 October 2018 - 06:00 PM

It's an interesting thing - to be a PCQI -- means you must have a through knowledge of FSMA.

Do you?

 

It doesn't mean one must have a certificate saying they attended a 2 day class and therefore they are good to go.


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noahchris97

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Posted 30 October 2018 - 08:01 PM

SQFconsultant:

                      We have received a minor for 2.4.1.1 - The site shall ensure that, at the time of delivery to its customer, the food supplied shall comply with the
legislation that applies to the food and its production in the country of use or sale. This includes compliance with
legislative requirements applicable to maximum residue limits, food safety, packaging, product description, net
weights, nutritional, allergen and additive labeling, labeling of identify preserved foods, any other criteria listed
under food legislation, and to relevant established industry codes of practice.

 

                         Auditors notes: The facility was not complying with the FSMA regulation with no current designated PCQI certified person.  



SQFconsultant

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Posted 31 October 2018 - 12:07 AM

That's a stretch.

 

Find the requirement for PCQI Certified in the SQF Code.


All the Best,

 

All Rights Reserved,

Without Prejudice,

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http://www.GCEMVI.XYZ

http://www.GlennOster.com

 


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mgourley

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Posted 31 October 2018 - 09:37 AM

That's a stretch.

 

Find the requirement for PCQI Certified in the SQF Code.

The site shall ensure that, at the time of delivery to its customer, the food supplied shall comply with the
legislation that applies to the food and its production in the country of use or sale. This includes compliance with
legislative requirements
applicable to maximum residue limits, food safety, packaging, product description, net
weights, nutritional, allergen and additive labeling, labeling of identify preserved foods, any other criteria listed
under food legislation,
and to relevant established industry codes of practice.

 

FSMA requires someone at the site to be a PCQI (whether certified or via demonstrable experience).

Site does not have a PCQI.

 

Site gets a NC.

 

Marshall
 



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MsMars

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Posted 01 November 2018 - 01:53 PM

How brief was your course in 2013? DId you receive a certificate? I would say it may be a little outdated to qualify for PCQI.  Since you would not be able to justify PCQI on experience alone (since you are new to the role and to QA), you need to demonstrate more in-depth training on the Preventive Controls for Human Foods Rule in order to qualify as PCQI.  The 2-day course is the easiest way to fulfill this and it provides a lot of useful information, but I would also encourage you to pursue more than just the 2-day class training if you have not worked much with a hazard-analysis based program.  



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noahchris97

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Posted 01 November 2018 - 06:40 PM

                Everyone thank you for your input. MsMars I have been in the food world for over 20 years and have experience in all walks of life concerning Food processing. QA;  I have been on and off, Sanitation Management, QA Management, Ops Management, Plant manager & etc. I have accoumulated many certs in all areas, HACCP, SQF Practioner, FSMA, Food Safety and etc. 

                I just wanted to get a few things straight as I was told on one hand you don't need to be certified, just knowledge / understanding of. Then on the other hand you need to be certified.



noahchris97

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Posted 01 November 2018 - 06:56 PM

Also I took the SQF Practitioners Course - Implementing SQF 2000 Systems in 2013.  Also on another note I was it with a minor (2.5.5.2 for no training record availble for staff conducting internal audits. Wouldnt these courses certs be good enough? The SQF Practitioner course had internal auditng for SQF Program. When I asked the auditor after audit by email his response was:

 

"I am not sure as usual SQF certification course does not include internal auditor training unless you were issued two separate certificates?"

To be a practitioner you also would need to know how to audit the program, which was in the course. Your thoughts on this please.... 



MsMars

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Posted 01 November 2018 - 07:46 PM

                Everyone thank you for your input. MsMars I have been in the food world for over 20 years and have experience in all walks of life concerning Food processing. QA;  I have been on and off, Sanitation Management, QA Management, Ops Management, Plant manager & etc. I have accoumulated many certs in all areas, HACCP, SQF Practioner, FSMA, Food Safety and etc. 

                I just wanted to get a few things straight as I was told on one hand you don't need to be certified, just knowledge / understanding of. Then on the other hand you need to be certified.

 

Forgive me for my assumptions, sounds like another case of a mis-informed SQF auditor. You should DEFINITELY be able to justify education/experience-based PCQI in this case.  No where in FSMA or the SQF code is it written that the 2-day course is required to be a PCQI. Did you list yourself specifically in your policy documents as the PCQI for the site? If so, then I would definitely fight that one.



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MsMars

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Posted 01 November 2018 - 07:51 PM

Also I took the SQF Practitioners Course - Implementing SQF 2000 Systems in 2013.  Also on another note I was it with a minor (2.5.5.2 for no training record availble for staff conducting internal audits. Wouldnt these courses certs be good enough? The SQF Practitioner course had internal auditng for SQF Program. When I asked the auditor after audit by email his response was:

 

"I am not sure as usual SQF certification course does not include internal auditor training unless you were issued two separate certificates?"

To be a practitioner you also would need to know how to audit the program, which was in the course. Your thoughts on this please.... 

 

IME the auditors want to see documentation of specific training for internal auditing.  It could be as simple as a Powerpoint and a knowledge test of its contents, there are a few free resources floating around for that. I don't believe you would need to have SQF-specific internal auditor training, at least I've never been asked for it.  They just want to see that your auditors have been trained to properly audit your system, whether that's by you or by external means.  Did any of the courses include sections on performing internal audits? 



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FSQA

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Posted 01 November 2018 - 08:05 PM

 Did you list yourself specifically in your policy documents as the PCQI for the site? If so, then I would definitely fight that one.

IMO: the NC is not for certification or not... but it is regarding his name (or anyone else) not listed as the PCQI for the facility in the FSP for the facility.


Edited by FSQA, 01 November 2018 - 08:08 PM.


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