10 replies to this topic

[Microbiologist Scientist]

Hi everybody!
Should we have a FDA (FSMA) food safety plan in place to comply with 2.4.1 Food Legislation (SQF standards)?????
I know that FSMA applies to our facility and we need to develop a food safety plan under FSMA requirements.
Thanks!!!!!!!!!!!!

[Scampi]

You need a plan that complies with FSMA because that's the LAW which comes first way before complying with SQF

 

Look at it this way

 

You don't NEED SQF to manufacture food for sale 

 

You DO need FDA approval

 

Most folks do not have separate plans.......One plan that complies with regulations that is prepared in a manner that an SQF auditor can follow will suffice

 

Your question is confusing........you know you need an FDA plan.....but you don't know if SQF demands it?  V8 was made to match FSMA and meet the FDA requirements

[MsMars]

I believe in a previous post you had created a preventive controls risk assessment, but called it your HACCP plan... Have you taken the SQF practitioner and/or PCQI courses yet?

[Microbiologist Scientist]

Thanks, Ms. Mars and Scampi, for your comments.

Ms. Mars, I have not taken any SQF Practitioner or PCQI courses. I have an AA in Food Safety. In addition I have read a lot of literature regarding to food safety including the SQF Code 8,. I also have 6 years of experience in food packing facilities, including Sanitation Supervisor.

The company where I work is small, 6 employees. The boss has no idea about food safety. My boss thinks that with just copy and paste I will be able do developed the  food safety management system plan. I told him to buy the temples that you guys told me and he told me that he had sent me the documents that he already had (food safety plan) and that I only had to use the SQF checklist and make the missing documents. He had told me that he already had 80% of the food safety plan. The reality is that he does not have not even have 4%. He only sent 4 documents (copy and paste) that do not make sense because they can not be applied to our food safety plan.

My boss wanted me to do and implement the food safety plan in 1 month, I told him that was not possible. My boss does not want to invest money. I've only been working with him for a month. I'm doing the food safety plan on my own.

P.D. I'm fixing the HACCP. I used the wrong procedures (HARPC) Thanks Ms. Mars for telling me.

[Microbiologist Scientist]

Ms. Mars  I realize that my assertion is confusing.

My boss does not want to do the food safety plan related to the FDA (FSMA) because for economic reasons it is better to do the SQF Code first. But according to what I understand, the FSMA, besides being a government requirement, is also a SQF requirement.

The Code say:

2.4.1

Food Legislation (Mandatory)

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.

[MsMars]

Carmelo, 

Your experience in packing facilities and your sanitation experience is certainly valuable in a food safety role, but the SQF/PCQI/HACCP courses will help you put your knowledge in the right place and know what is expected of your programs -  and for your career, it is a necessity.  Not to mention that SOMEONE needs the SQF and HACCP courses at your facility as the SQF Practitioner.  If that person is not you, then I would highly recommend it to you still if you are writing the programs.  Your particular experience would possibly qualify you as a PCQI without the course, but the PCQI course is SO helpful, and you seem to have a lot of questions about hazard analysis and such that I think you could have answered if you took that course.

 

For your boss to say that he does not want to "do the food safety plan" is IMO, completely idiotic as you must be compliant with federal programs (it's required by LAW) before considering third party certifications. This is why federal compliance is a requirement of all of these programs. Your boss has priority for customer requirements over federal compliance, and that is a big red flag. 

 

I am not sure of your situation and what led you to take on a food safety role under your current boss.  Food safety and quality is a rewarding career with the right training and support. However, it appears that your boss has taken advantage of your (forgive me, but I have no other word) slight naivety and has given you a task that is not easily accomplished by even an experienced food safety professional, and for an amount of money that is lower than a line worker's pay.  Forgive me again for being forward, but my professional advice to you would be to fulfill whatever obligations you may have with him/her, then run away. Quickly.

[Microbiologist Scientist]

Hi everybody!!!

Thanks Ms. Mars for your advices.

 

My idea of being in this company is to learn (on my own). This is my first time developing a Food Safety Plan. This company has given me the "opportunity" which is rare since I have helped in the past to develop a Food Safety Plan (SQF 2000), but I  haven't developed my own food safety plan from scratch by my self.

 

I do understand perfectly that with out the owner's support it will not be possible. I have to talk to my boss so he can understand a little more what it takes to make a food safety plan.

 

In my opinion, my boss thinks that a food safety plan consist of 6 documents which I can copy and paste from the internet. And then the auditor (SQF) will come and he will read the 6 documents and he will give us the SQF certification. Another thing that I believe my boss thinks is that he will not have to invest money to meet the requirements (SQF).

 

I am not a fortune-teller, but I dare to bet that nobody has been able to certify without first having invested money (ATP test, Environmental Swabs, CCP (eg metal detector), PCQI certification, HACCP certification, Product Analysis, Internal Audits certification, SQF Implementation certification, Sanitation Equipment and Chemicals, and much more.

​

​What do you guys think about this situation.

 

​P.D.

Excuse my English, it's my second language.

 

Thanks!!!

[Fishlady]

 

Hi everybody!!!

Thanks Ms. Mars for your advices.

 

My idea of being in this company is to learn (on my own). This is my first time developing a Food Safety Plan. This company has given me the "opportunity" which is rare since I have helped in the past to develop a Food Safety Plan (SQF 2000), but I  haven't developed my own food safety plan from scratch by my self.

 

I do understand perfectly that with out the owner's support it will not be possible. I have to talk to my boss so he can understand a little more what it takes to make a food safety plan.

 

In my opinion, my boss thinks that a food safety plan consist of 6 documents which I can copy and paste from the internet. And then the auditor (SQF) will come and he will read the 6 documents and he will give us the SQF certification. Another thing that I believe my boss thinks is that he will not have to invest money to meet the requirements (SQF).

 

I am not a fortune-teller, but I dare to bet that nobody has been able to certify without first having invested money (ATP test, Environmental Swabs, CCP (eg metal detector), PCQI certification, HACCP certification, Product Analysis, Internal Audits certification, SQF Implementation certification, Sanitation Equipment and Chemicals, and much more.

​

​What do you guys think about this situation.

 

​P.D.

Excuse my English, it's my second language.

 

Thanks!!!

 

Hi, Carmelo

 

You are correct that achieving any third-party certification is going to require quite a bit of money for the training, additional record keeping requirements, programs, and infrastructure upgrades.  Many small companies also bring in consultants to help them through the certification process.  You will definitely need more than one month to prepare, and any decent auditor will know when you have done a copy-and-paste procedure that does not match with how your plant is actually functioning.

 

If you plan to continue to work with this company, please remind them of their obligation to comply with FDA regulations first and foremost.  That is the law.  Also remind them that the audit costs money, which will have been wasted if the plant fails the audit- very likely to happen under the circumstances you describe. 

[SQFconsultant]

It costs money to go from zero to SQF certification.

As I said in the beginning your boss is an idiot (putting it nicely.)

Cheap seat companies always think they just need to do enough to get by. Then all of a sudden they fail an audit, kill someone with their cheap practices etc and then they find out very quickly that the penny pinching had not produced a good food safety culture and the failure has cost them 50 times + in loss of business or new business in comparison to doing it right the first time.

As a long time and full time Consultant and one of the first SQF Auditors I am happy to say that based on experience and observation many "experienced" people in food manufacturing need to get their ego's put of the way when it comes to education.

Take the courses, get the completion certificates.

I know that even after 50 years in the food industry (I strated cooking at 10) I take the courses and they always teach me new things - I would also like to think I'm all that, but I got oUT of my own way and saw the need for continuous training.

[Scampi]

Carmelo

 

I suggest you head Mrs Mars advice..........leave this company as quickly as your able..........it's you who's going to get thrown under the bus, and as I mentioned before....paperwork with your signature on it that relates to the production of food or packaging are legally binding documents so it' won't just be mr. boss man who gets charged it will be you too

 

Put your personal integrity at the top of the heap and leave

 

You are not responsible for your bosses moronic interpenetration of food safety, but you are responsible if you continue to work there without the $$$$, training and support this job requires.

 

Then you can start at the bottom in food safety with a reputable company who really puts an emphasis on food safety and understands it is what is required to keep the business going.......not just something the "have to do" that they believe has no value

 

Save yourself

 

I once called the ministry of labour, and the health unit on an employer, and company was shut down for 2 weeks to get it up to minimum code (not food)----------------never ever sacrifice your personal standards for a job

[Microbiologist Scientist]

Thanks Scampi
That's true.