9 replies to this topic

[Bingo67]

I received a nonconforming for "Lack of Validation of the Food Defense Program" in an SQF Audit 2.5.5.2.  We have completed a Food Defense drill and use the FDA Food Defense Plan builder - so I am not sure what they are looking for?

 

 

[mahantesh.micro]

Dear Tavish

I think you need to conduct self inspection and validate mitigation plans in case of failure of your food defense system for that u need to prepare checklist and validation protocol. and also refer the below link that may help u.

 

https://www.qualitya...s-verification/

[Bingo67]

Thank you! We did a Food Defense self inspection/challenge  like the one in the article ( I incorrectly called it a drill).  I thought this was the Validation of the program - but not so? Would it be a statement of these checks working?

 

Sorry... I am still confused.

[SQFconsultant]

Don't do a "self" inspection.

 

We do food defense breach exercises - the people at the target company don't know who we are at all.

 

That is what you need to do - go out and get a friend or someone that no one at the company knows.

 

Have that person attempt to enter and breach  --- they need to chronicle the event, how they got in, etc.

 

You need to document everything, including the bads, your corrective actions, etc. 

 

This is not about making sure all the check boxes are complete - you actually want someone to breach your security controls that you have in place and document that information - yes, the bad stuff.

 

The Auditor doesn't want to look at a sheet of paper that shows that everything was wonderful, they want the truth of what happens in this kind of situation - aka "no snow job" "no sugar coating."

[The Food Scientist]

Have you done a Food Defense challenge? Is the program being reviewed during annual management review meetings?

[Bingo67]

Yes we did a Food Defense Challenge and it is reviewed annually. We are a rural small company less then 10 people. 

[The Food Scientist]

I am really confused actually. The code clearly states it needs to be challenged and reviewed at least annually.  

 

Perhaps your auditor saw something around your facility that shows lack of validation to your food defense plan. 

[Leila Burin]

Hello, when challenging remember also:

• personnel uniforms
• informatics system
• any closed TAG on RM or FP to be assessed

best regards,

Leila

[bob schap]

I was hit with a NC for a Food Defense meeting not occurring.  Does this fall into Lack of Verification?  How does everyone record their meetings.  apologies for being a noob here

[pHruit]

It'll depend a bit on what the nature of the meeting is, and possibly on the expectations of the certification standard involved.

For annual reviews for BRC purposes, we record in almost exactly the same way as for HACCP - the plan contains a defined topic list for the meeting, and the minutes detail the discussion and conclusion under each section. A printed copy is signed by all of the team members and filed with the plan.