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Feeling Lost Regarding Scope

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nwine

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Posted 25 June 2019 - 12:11 AM

Hey All,

 

I'm the SQF practitioner for a coffee roaster preparing for our initial certification audit (modules 2 & 11) a few months down the line. Our facility is dedicated primarily to roasting and packaging coffee, but we also warehouse a large amount of syrups, tea products, alternative milks, and other cafe essentials that we supply to our own chain of cafes, as well as to our wholesale customers. I'm currently in the process of fleshing out our supplier approval program, and it's prompted somewhat of an existential crisis.

 

I've been working with our purchasing department to update our supplier register, and a previous consultant who worked on this project had included the manufacturers of the various cafe essentials we warehouse in the list of suppliers who need to be vetted through our supplier approval program. This didn't seem right to me, as these products aren't used in our manufacturing process; we just store and distribute them. However, it got me to thinking about the scope of our (eventual) certification. Since we're storing these products in the same location as our own finished products, do we need to vet these suppliers as well to have any chance of passing our audit? Is module 12 relevant to us since we're technically storing and distributing these products? 

 

Sorry for the rambling, I'm just a bit panicked. I greatly appreciate any insight y'all can offer.

 



SQFconsultant

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Posted 25 June 2019 - 12:49 AM

Your modules are NOT just 2&11 - because you pass thru (wholesale to your customers)  syrups, tea products, etc you must also qualify under SQF Food Safety Code for Storage and Distribution - You must add this and FSC # 26 and Module 12.

 

Your previous Consultant was CORRECT, 

 

Module 12 is absolutely relevant.

 

We have a number of client that do pass thru and must follow this as well.

 

This is a major undertaking to add the neccessary things for the storage and distribution code - I would highly suggest A. bringing in the same or another consultant and B. pushing your audit dates up = you need a longer time to get it together.


Edited by SQFconsultant, 25 June 2019 - 12:52 AM.

All the Best,

 

All Rights Reserved,

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Glenn Oster.

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SQF System Development | Internal Auditor Training | eConsultant

Martha's Vineyard Island, MA - Restored Republic

http://www.GCEMVI.XYZ

http://www.GlennOster.com

 


nwine

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Posted 25 June 2019 - 05:20 PM

Glenn, thank you for your reply.

 

Unfortunately, the previous consultant only addressed modules 2 and 11 in the work they did, and as my own SQF experience is only with manufacturing, module 12 didn't even cross my mind until yesterday. I'll be meeting with management later today to discuss how we want to proceed, but as there's little incentive for us to include our pass through distribution in the scope of our certification, they'll very likely want to request an exemption from our CB. This would be a significant undertaking from an organizational standpoint, but assuming that we're able to relocate the products that we pass through to another space (or at the very least restrict them to a controlled portion of the facility), do you think an exemption would be likely to be granted?



SQFconsultant

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Posted 26 June 2019 - 05:59 PM

Technically speaking - it is not an "exemption."

 

You do your scope without this.

 

And on the scope document put in that the following area is exempt.

 

Now, there are a bunch of catches.

 

If you co-mingle the pass-thru stuff with what is on the scope you can easily get disqualified.

 

What happens (and we have several clients that do have exemptions in place) is that all the pass-thru items need storage in their own area -- now even though they are exempt from scope those arears are still subject to inspection by the Auditor and seriously, they will be looking for anything that is stored in those areas that are on the scope or can impact the scope.

 

The flip side is that if you have customers that only get pass-thru stuff you can't tell them you are SQF certified and if you have customers that get a combo of scope items and pass-thru it creates an interesting situation.

 

I will say this, as an SQF Consultant we have found and most of pass- thru clients have found it better to add on storage and distribtion than not because what will happen is you will get a customer that wants you to be SQF certified for that purpose and you'll be ready to go instead of stalling and saying that while you are certified over there, you are not certified for this.

 

We have a new client coming on where we talked out of leaving storage and distribution out as for them it would create a big issue with their customers and future customers.

 

I don't understand why an SQF Consultant would not have addressed, too bad really - that's a bad reflection.

 

I really would tread lightly on this one, I don't know your operation, but if it were me, I'd go full-on and add it.


All the Best,

 

All Rights Reserved,

Without Prejudice,

Glenn Oster.

Glenn Oster Consulting, LLC -

SQF System Development | Internal Auditor Training | eConsultant

Martha's Vineyard Island, MA - Restored Republic

http://www.GCEMVI.XYZ

http://www.GlennOster.com

 




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