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2.5.4 Product Sampling, Inspection, and Analysis Question


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#1 Ops_Guy

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Posted 16 May 2019 - 08:25 PM

Hi everyone,

 

So I work for a 3PL (Third Party Logistics) Company. As a 3PL, we work with our clients and provide storage and distribution services, as well as other value added services. I run a facility that receives, stores, picks, and ships our client's product. The product would be considered low risk as it is a finished product that does not needed any added materials, packaging, labels etc. 

 

When I read the SQF Food Safety Code for Storage and Distribution Edition 8, I see that for 2.5.4 Product Sampling, Inspection, and Analysis it states that it is "Not applicable for Storage and Distribution". Does this mean that if you do any form of sampling or inspections you are not allowed to apply for a SQF site certification for Storage and Distribution? 

 

So a vague description about the product: It is NOT food, but will come in contact with food. Product comes to our facility sealed and ready to ship.

 

In my facility we also "gather data" about the product. We confirm artwork of product and confirm product labeling matches our client's specifications. This next part is where it gets a little on the edge... We also open the primary packaging and "gather data" on the actual product, in a sense we are verifying the manufacturer's work. The articles of product that we use to gather our data are destroyed and primary packaging is sealed and sent back for storage and shipping. 

 

The area where this "data gathering" takes places is sanitized and gloves are worn when opening primary packaging and handling of product. 

 

If there is a non-conformity, we report it and the client provides disposition (what to do) for the product. 

 

I have made work instructions on how to gather data, on sanitation and how frequently we "gather data" on product. 

 

When the auditor does show up will this fail me?

 

Thank everyone!

 

 

 



#2 MsMars

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Posted 16 May 2019 - 08:36 PM

I wouldn't say that this would prevent you from obtaining certification or cause an "automatic fail".  To me it sounds like you are going above and beyond your scope.  Is this a customer requirement? As long as you sanitation and sampling standards are robust and validated, I don't see an issue, but will let others weigh in who are more experienced in this sector of SQF. 



#3 Ops_Guy

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Posted 16 May 2019 - 08:45 PM

I wouldn't say that this would prevent you from obtaining certification or cause an "automatic fail".  To me it sounds like you are going above and beyond your scope.  Is this a customer requirement? As long as you sanitation and sampling standards are robust and validated, I don't see an issue, but will let others weigh in who are more experienced in this sector of SQF. 

 

Unfortunately, this is our client's requirement. At first it was not an issue, but when a client's customer required us to go from AIB to SQF, more questions and concerns were brought up. Based on my readings, I do consider AIB to be a less stringent quality system than SQF. Though i will say I am new to Quality Management and have not been through an SQF audit to confirm.



#4 SQFconsultant

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Posted 16 May 2019 - 09:07 PM

I would suggest a full understanding of SQF in how it works, how an audit is run, how the grading and scoring system applies, etc.

 

As to your doing something that is not a requirement of SQF for storage and distribution it doesn't mean you can't do something, technically speaking you are going beyond and I imagine this is a customer requirement anyway, no worries here.

 

Not fully understanding your going for SQF distribution and storage if product is not food - you mention that product is not food, so why going for a standard that is intended for storage and distribution of food, or did I miss something?


Warm regards,

 

 

Glenn Oster

Glenn Oster Consulting, LLC

 

SQF Full System Development & Implementation Consultant

You can DIY or Bring in the Professionals - We are done in 30 days

 

Small to Mid-Size Food, Food Packaging & Food Logistic/Storage 

Remote & On-Site/Analysis of Operational & Capital Needs

Internal Auditor Training Program / eConsultant w/annual review

772.646.4115 // glenn@glennosterconsulting.com

Travel Base: Orlando, Florida USA

Home: Boquete, Chiriqui Panama

www.GlennOsterConsulting.com

 

 

 

 

 

 

 

 

 

 

 

 


#5 Ops_Guy

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Posted 16 May 2019 - 09:36 PM

Not fully understanding your going for SQF distribution and storage if product is not food - you mention that product is not food, so why going for a standard that is intended for storage and distribution of food, or did I miss something?

 

The decision to move forward with SQF distribution and Storage was due to our client's customer requiring all their suppliers to get to a GFSI standard. Our options were SQF and BRC. 

 

We went through training through a Certified Body and they stated since our product was used to contact food in restaurants, kitchens, cafeterias, we had to treat it as food.

 

When we asked about section 2.5.4, they stated it was pretty gray and it would depend on the auditor and what SOP and WI we have in place to ensure opening up the primary packing would not cause a risk to the point it would be classified as a CCP.



#6 SQFconsultant

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Posted 16 May 2019 - 09:42 PM

Nope, sorry - what?  Some CB training informed you that your non-food had to be treated as Food.  No, no way.

 

I was an SQF Auditor for four years, now SQF consulting for the past 9 nines - never heard this before and I just checked with SQFI, I asked if this was something new and they informed me that 26-Storage and Distribution applies to food only -- no strange convolution from a CB.

 

Storage and Distribution code is for distribution of food.  

 

We just had a call from a company that informed us their customer required them to get SQF certified and they were a storage and distribution company that also did not handle food - we said we'd love to develop your system for you, however we only deal with either food contact packaging or food (manufacturing, distribution, etc), thus this potential client decided to go with a different type of certification - one I know of is from IFS.


Edited by SQFconsultant, 16 May 2019 - 09:52 PM.

Warm regards,

 

 

Glenn Oster

Glenn Oster Consulting, LLC

 

SQF Full System Development & Implementation Consultant

You can DIY or Bring in the Professionals - We are done in 30 days

 

Small to Mid-Size Food, Food Packaging & Food Logistic/Storage 

Remote & On-Site/Analysis of Operational & Capital Needs

Internal Auditor Training Program / eConsultant w/annual review

772.646.4115 // glenn@glennosterconsulting.com

Travel Base: Orlando, Florida USA

Home: Boquete, Chiriqui Panama

www.GlennOsterConsulting.com

 

 

 

 

 

 

 

 

 

 

 

 


#7 Ops_Guy

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Posted 16 May 2019 - 09:53 PM

Nope, sorry - what?  Some CB training informed you that your non-food had to be treated as Food.  No, no way.

 

I was an SQF Auditor for four years, now SQF consulting for the past 9 nines - never heard this before and I just checked with SQFI, no way.

 

My comment to the CB personnel, was that people don't eat gloves or pan liners or bags.

 

When I think of distribution and storage, i feel that it is more for finished food product or raw materials.



#8 Ops_Guy

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Posted 16 May 2019 - 10:00 PM

We just had a call from a company that informed us their customer required them to get SQF certified and they were a storage and distribution company that also did not handle food - we said we'd love to develop your system for you, however we only deal with either food contact packaging or food (manufacturing, distribution, etc), thus this potential client decided to go with a different type of certification - one I know of is from IFS.

 

I will look into this.

 

thank you,



#9 SQFconsultant

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Posted 16 May 2019 - 10:04 PM

My comment to the CB personnel, was that people don't eat gloves or pan liners or bags.

 

When I think of distribution and storage, i feel that it is more for finished food product or raw materials.

 

Yes, and that would be correct.  We do work with 3PL's that store and distribute food and also other products, but the core for the SQF Food Safety Code on Storage and Distribution is food.


Warm regards,

 

 

Glenn Oster

Glenn Oster Consulting, LLC

 

SQF Full System Development & Implementation Consultant

You can DIY or Bring in the Professionals - We are done in 30 days

 

Small to Mid-Size Food, Food Packaging & Food Logistic/Storage 

Remote & On-Site/Analysis of Operational & Capital Needs

Internal Auditor Training Program / eConsultant w/annual review

772.646.4115 // glenn@glennosterconsulting.com

Travel Base: Orlando, Florida USA

Home: Boquete, Chiriqui Panama

www.GlennOsterConsulting.com

 

 

 

 

 

 

 

 

 

 

 

 


#10 SQFconsultant

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Posted 16 May 2019 - 10:16 PM

And just one thing to add - get your money back from that CB for the so-called training, there is nothing grey about the requirement of 2.5.4 as it applies to storage and distribution of food - they should also be reported to SQFI.


Warm regards,

 

 

Glenn Oster

Glenn Oster Consulting, LLC

 

SQF Full System Development & Implementation Consultant

You can DIY or Bring in the Professionals - We are done in 30 days

 

Small to Mid-Size Food, Food Packaging & Food Logistic/Storage 

Remote & On-Site/Analysis of Operational & Capital Needs

Internal Auditor Training Program / eConsultant w/annual review

772.646.4115 // glenn@glennosterconsulting.com

Travel Base: Orlando, Florida USA

Home: Boquete, Chiriqui Panama

www.GlennOsterConsulting.com

 

 

 

 

 

 

 

 

 

 

 

 





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