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2.1.3 Implementation Guidance
What does it mean?
This element is closely linked to 2.1.2 and is one of the tangible actions which demonstrate management commitment and involvement.
The supplier must review their SQF System when any changes occur that impact food safety. This may include changes to product formulations, raw or packaging materials, processing or packaging equipment or changes to personnel. The SQF practitioner is responsible for managing such changes, but senior management is responsible for authorizing and approving these changes.
The SQF System shall be reviewed and update changes communicated (at a minimum) monthly to senior site management as part of the review of all operational activities. Additionally, a full review of the SQF System must be completed annually by senior management.
What do I have to do?
This element is mandatory. This (at a minimum) annual review, including monthly updates for site management, shall include the policies outlined in company’s policy statement, findings from the regularly scheduled internal and external audits, customer complaints, test records, deviation reports and outcomes of corrective actions.
A procedure documenting how the review of SQF System is conducted shall be included in the food safety manual. The review must be conducted by senior management with the objective of ensuring the continued integrity of the food safety management system.
The review shall measure the effectiveness of the SQF System against the food safety objectives established by senior management and the effectiveness of corrective actions taken in response to deficiencies in the System. The focus shall also be on the effectiveness of pre-requisite programs and the ongoing accuracy and validation of the Food Safety Plan (s).
All reviews and major changes to the SQF System shall be recorded by the SQF practitioner, including the reasons for any changes and the actions taken as a result of changes or reviews.
Major changes to a process, a process control or any changes that could impact on the ability of the System to deliver a safe food shall trigger a review of the Food Safety Plan in addition to the annual review. Any major changes to Food Safety Plans shall be validated and verified before implementation.
2.1.3 Auditing Guidance
The auditor will seek evidence of the existence of a management review procedure at the desk audit and compliance to this requirement through a review of records and interviews with senior management and the SQF practitioner. Evidence may include:
- Review of the management review procedure.
- Records of SQF System reviews by senior management and the depth of coverage of the review meetings (e.g., food safety objectives, food safety measures, customer complaints, test records, product and process changes, etc.).
- Identified actions from review meetings, and follow up on progress and outcomes of corrective actions.
- Changes to the products and/or operational processes since the last audit, and the extent to which these changes are reflected in the food safety manual.
- The extent to which changes in materials, process or products have been validated.
- Records of product and process changes and their validation.