Exemptions in SQF certification

Hello all I have a huge issue.

Forgive me if this is a dumb question.

We are SQF Food Safety certified for categories 19 and 31, (essentially a bunch of dry blends, and some dietary supplements). We have our yearly audit in the immediate future.

As a co-packer, we also make some personal care products. These items are made in dedicated rooms with dedicated machinery. The raw materials for the personal care products are stored with separation as well. This did not come up as an issue in  past audits to my knowledge however, I wanted to ask you all for your professional insight. Doe the situation I describe mandate that I request an exemption?

As of this moment, none of our clients claim our SQF certification. And obviously, I would only allow those cable of doing so via categories 19 and 31 following proper procedures. 

Do I have to request exemption in this situation?

Thank you for your help

PD

It may not have come up in past audits, however you need to have an exemption in place - these areas are still subject to inspection during an audit, however it is primarily to determine if those areas will impact your scope.  We have several clients that put exemptions in place for various areas and products that had nothing to do with the SQF certification.  Exemptions need to be requested in writing to your CB and noted on your Scope document.

Yes, we do not have our Instant Coffee under the scope of our audit, but we report it ahead of time as an exemption, and double check they are only coming in for Roasted Beans.