NC for not listing our legal counsel and expert contacts

I have an NC for not listing our legal counsel and expert contacts. 

 

Do we have to have some retainer agreement with these individuals or can i just pick an attorney from the phone book? 

 

We do have legal counsel so i'm not worried about that one, however, I'm not sure executives want to list them. can we just say "yep we have an attorney and we know their phone number and the details are nunya!" 

 

Same question for expert contact. do i have to have an agreement in advance? do they need to know I'm listing them? We don't have one of those on retainer although it is probably a great idea. 

 

Finally my commentary. 

Why does SQF continue to insist on auditing this aspect?? They finally rebranded the business continuity as crisis management and rightfully shifted focus from continuation of supply to food safety assurance but they are still going well past their mission by insisting on having our legal counsel's contact listed. Im glad they are looking out for best practices of my company but none of their business in terms of assuring food safety. 

 

 

Does SQF have a clause that deals with service supplier approval?...BRC does (3.5.3.2) & is quite prescriptive on this:

 

 

Contracts or formal agreements shall exist with the suppliers of services that clearly define service expectations and ensure potential food safety risks associated with the service have been addressed

 

 

We would therefore quote our T&C, supplier's insurance & membership if any accreditation body to show suitability of supplier.

 

Maybe you could use whatever SQF says in the equivalent clause to justify how you address this?.. (did your auditor quote NCF against section of SQF?)

IKE

 

I couldn't agree more..............I have not tested my crisis plan....nor will I be and I was told by my auditor how would I ensure I could supply my customers in the event of a crisis...................I said that a is a business and has nothing to do with food safety.   The entire reference to the actual running of the business should be removed as it's not relevant

 

this is from the auditing guidance

"The crisis management plan shall include a crisis alert contact list, sources of legal and practitioner assistance which may counsel senior management in a crisis situation and designation of responsibilities for internal and external communication during a crisis"

 

So i guess technically it doesn't say you have to name your counsel you just need to list that you do have counsel to call?????

Your food safety plan and crisis management plan are confidential. If you list your legal counsel contacts, it's not as if you're listing them for the whole world to see, only pertinent employees and management. If a customer requests a copy, you can certainly redact that portion.

Just do it.

 

name, address, contact info.

Just do it.

 

name, address, contact info.

 

Hi SQFC,

 

Why so ? Unreasonable requests should not be challenged ?.

Charles, it is a,requirement under SQF to list them. Why argue the point.

Because it is a qualifying standard, the SQF standard holds an incredible amount of power over suppliers. I believe it is important for suppliers to make sure it stays on topic. That is just how I feel about it. If a requirement is actually helpful in protecting consumers from contamination, I am more than happy to adopt it into my program. The continuity of supply issue feels more like grocery is using the SQF standard as a means of offloading their own supply chain responsibilities by forcing suppliers to find alternative suppliers on their behalf. For that reason a lot of suppliers still have a bitter feeling about that section of code. In the end  it isn't a big deal to list the contact information, however, it is important to keep a fence around the code so that it doesn't veer into the weeds. I feel that if the request doesn't serve a food-safety purpose it is unreasonable. I know it is slippery-slope logic, I guess i'm just a bit of libertarian on this issue. 

 

 

FWIW - 

I did use the following wording and the auditor was agreeable. 

Expert Advisors

COMPANY NAME maintains access to competent legal and food safety advisors. Company policy restricts sharing of contact information, but the contact information is kept by executives and they can be reached in an emergency.

SQF is not purely safe food and quality. It’s also continuous improvement, company sustainability and customer confidence. I do not think this is that big of deal. Seems rather understandable. Your business has a problem, Recall for example, your legal advisors contact is right there in your plan. No guess work. BTW most companies, food industry or otherwise are going to have attorneys. It should not be seen as taboo.

We got a minor nc for this a couple years ago. We simply listed our attoney and the firms phone number, sent a copy in as our corrective acton and moved forward. The companys president didnt agree with the nr but luckily he is 100% comminted to the sqf program so he too just went with it.

Charles, it is a,requirement under SQF to list them. Why argue the point.

 

Hi SQFC,

 

I guess you are  referring to 2.1.5.2.(vii-viii) or perhaps 2.6.3.1(ii) in which case I agree with you.

 

Strange that clauses are  nowhere referenced in 10 Posts.