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2.1.3 Management Review and 2.5.2 Verification Activities


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#1 kfromNE

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Posted 25 January 2019 - 06:33 PM

Just so I'm clear while writing our SQF program or someone please correct me if I'm wrong. 

 

Where I'm getting confused - my boss bought SQF templates for me to use for 2 and 11 from the company we plan on using to certify us in SQF. In the template for 2.1.3 it states

"This review also includes a review of records generated in the processing of the products, Pest Control reports, Traceability program, Recall program, etc."

 

To me it seems like this includes then my findings/records of my GMP audit, pest report findings, etc. However I feel these reports should be under 2.5.2 and verification activities. 

 

So am I correct and saying that 2.1.3.3 is referring to for example our GMP policy. While 2.5.2 is referring to records generated from my policies - for example my GMP audit findings.

 

Thanks in advance



#2 Scampi

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Posted 25 January 2019 - 06:56 PM

2.1.3.3 Food safety plans, Good Manufacturing Practices and other aspects of the SQF System shall be reviewed
and updated as needed when any potential changes implemented have an impact on the site's ability to deliver
safe food.
 
2.5.2.2 The methods, responsibility and criteria for verifying monitoring of Good Manufacturing Practices, critical
control points and other food safety controls, and the legality of certified products, shall be documented and
implemented. The methods applied shall ensure that personnel with responsibility for verifying monitoring
activities authorize each verified record.

 

So basically you are correct HOWEVER......you're ENTIRE program still needs reviewed on an annual basis so the template you have is also correct, but for PROGRAM review, not daily monitoring verification


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#3 MsMars

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Posted 25 January 2019 - 08:26 PM

2.1.3 - Usually for "management review", (which I consider to be a review of the whole program) I will pick just a few random records to review for completeness, proper recordkeeping practices, corrections, etc. This is in addition to reviewing the food safety plan, SOPs, policies, etc.  I usually do it in groups throughout the year by prerequisite program or categories. I have a form that gets completed while doing this, but it's not necessary. The form lists a random record review as part of the overall review of the program.  

2.5.2 - refers to the ongoing verification activities that you should be completing regularly and signing off on like review of production records that you do daily/weekly/etc. 



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#4 SQFconsultant

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Posted 26 January 2019 - 01:39 AM

I agree with everybody else, this part however bothered the heck out of me...

 

"my boss bought SQF templates for me to use for 2 and 11 from the company we plan on using to certify us in SQF."

 

I've never heard of a CB selling the templates they are then going to audit later on!?!

 

As they say here in Panama - this is MALO!


Kind regards,

 

Glenn Oster
 
 
GOC GROUP / +1.800.793.7042 / Food - Food Packaging - Food Storage/DC

SQF, BRC & IFS System Development, Implementation & Certification Consultants

Serving Small-to-Mid-Size Businesses | International Cross-Border C-CUR Acceptance

Internal Auditor Training | eConsultant | SQF, BRC & IFS Pre-Development or Pre-Audit GAP

http://www.GlennOsterConsulting.com  -- 

 

 

URGENT - Mission Critical - Returning to the Field...

https://bit.ly/3kBj997

 

 

 

 

 

 

 

 

 
 
 
 
 
 
 
 
 

#5 Scampi

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Posted 28 January 2019 - 01:55 PM

Here here Glenn.............templates are a really bad idea..........unless they are just for formatting and don't come pre populated............another example of BAD auditing........PISSPOOR CB's (who are robbing people blind and manufacturing ignorance that needs to people getting sick)

 

This whole thing bothers me so much, I've reached out to GFSI international to see if i can't participate 

 

The fact that an auditing company is selling templates speaks volumes about them just wanting to make $$$ with no care given to actually improving food safety

And hey, if you're a plant manager, and you've made widgets your whole career...........templates = saving $$$$ so the person making decisions who doesn't understand food safety says Yes Please!!! I'll take them all........oh, are your obviously guaranteeing I'll pass if I buy them right???


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#6 kfromNE

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Posted 28 January 2019 - 03:22 PM

I see both of your points, however I do disagree. I don't feel that just because we purchased the templates from the company, it guarantees an automatic pass - the substance/company specific material still needs to be there.  I see it comparable as templates the FDA put our for the food safety plan and food defense builder and examples/templates I received from the PCQI class I took.

 

Background - we are a small company ( family owned under 10 employees who work at the plant) who needs to stay competitive thus needing SQF certification besides our GMP 3rd party audit we do. Before me being hired 18 months ago, there wasn't a person whose specific job was food safety - the plant manager and other positions took care of it. When we were inspected by the FDA last year, the inspector was happy to see we had the training and our food safety plans in place/the company spent resources/money to hire a food safety person. Now I'm grateful for my position but I'm new to this field as well. I'm a trained registered dietitian who previously taught food service establishments food safety classes for the state food code (servsafe) and had spent a total prior to this job 2 summer breaks in 2 different USDA food plants. (If you're curious of why I was chosen then - I needed a career change and I live in a rural area so jobs are scarcer and many companies have a hard time finding qualified individuals or individuals with a close enough background to train). So with some help from my boss, it was my sole responsibility to write our food safety and food defense plan to be in compliance with FSMA. Now it is my sole responsibility to write our SQF policies with help from the other employees when I have questions on procedures.

 

So while I had some knowledge and learned fast - I don't have the knowledge that comes with time nor have seen any other SQF policies to know the language/material SQF is wanting. When I wrote our food safety plan last year in the 2nd month after I was hired, I used the FDA tool and the examples from the PCQI training to then personalize it. For our GMP audit, our policies are based upon the policy manual/code.  I took the SQF class but while trying to write the policies - I get confused on what is specifically be asked for. I still have a hard time even with the templates.

 

I did try to write our SQF policies without a template for 2 months but I was getting lost. So I'm the one that requested my boss buy them as a guidance of how to build our SQF policies. It was either the templates or my boss would have had to hire someone outside of the company to write them instead. From what I've seen of the templates I'm using, they are similar to the IFSQN SQF Code Implementation Package. I see these templates as a positive thing. A tool to help guide companies especially smaller ones to achieve certification and stay competitive.

 

The plan: Use the templates, the PowerPoint slides/notes from SQF training, this forum and other resources to write the policies. Once written, hire a company to do a GAP analysis to see what is missing. Fix mistakes then have our audit to become certified. Time line - be certified by 2021.



#7 Scampi

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Posted 28 January 2019 - 03:43 PM

KfromIA, with your background and your own implementation progress, and the overall commitment to food safety this company has (great news!) you probably won't need the GAP analysis performed by an outside vendor.

 

On SQFI there are checklists that function like the basis for an internal audit which should allow you to see areas that have been missed and/or not fully developed. Since you targeting next year, you've got plenty of time.

 

We're all here to help in whatever way we can.


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