Introduction and a few questions.
Hello everyone!
I've just begun a position as a compliance specialist after spending 4 1/2 years as a tech (just under 3 as a lab tech, just under 2 as a QA tech). I feel my skills and knowledge are very under qualified for my role, and I'm hoping that I can pull from all of the knowledge from this community (pretty excited about it!). Also I'm 9 days in, my manager has been out last/this/and next week, and the day he gets back we have an organic audit, an internal audit the day after, and SQF 4 weeks after that. I'm only panicking slightly on the inside.
I'm trying to take as many courses/training as I can, but I was really left with only a bunch of spreadsheets to review the next three weeks, and not a lot of guidance. Any suggestions on training/classes is appreciate. I've got two questions also:
1. I'm trying to gather organic certs for our raw materials, and I don't know what is/isn't current/acceptable. I'm seeing organic certificates never expire, but they do have "anniversary dates". Wouldn't we need up-to-date certs with future anniversary dates? I don't exactly trust a cert with a 2012 anniversary date (I was barely out of high school).
2. We've put together an updated food defense plan using the FDA builder, and I have the task of updating our posted FDP for review. The document currently posted is a food defense/site security policy. I think I'm replacing these with the food defense plan, but the policy is a completely different doc (although I think it was put together prior to having the FDP). Does anyone know if having a separate policy is a necessity, or is the FDP typically all that's required? I should add we're transitioning from SQF to FSSC 22000 next year.
Hello everyone!
I've just begun a position as a compliance specialist after spending 4 1/2 years as a tech (just under 3 as a lab tech, just under 2 as a QA tech). I feel my skills and knowledge are very under qualified for my role, and I'm hoping that I can pull from all of the knowledge from this community (pretty excited about it!). Also I'm 9 days in, my manager has been out last/this/and next week, and the day he gets back we have an organic audit, an internal audit the day after, and SQF 4 weeks after that. I'm only panicking slightly on the inside.
I'm trying to take as many courses/training as I can, but I was really left with only a bunch of spreadsheets to review the next three weeks, and not a lot of guidance. Any suggestions on training/classes is appreciate. I've got two questions also:
1. I'm trying to gather organic certs for our raw materials, and I don't know what is/isn't current/acceptable. I'm seeing organic certificates never expire, but they do have "anniversary dates". Wouldn't we need up-to-date certs with future anniversary dates? I don't exactly trust a cert with a 2012 anniversary date (I was barely out of high school).
2. We've put together an updated food defense plan using the FDA builder, and I have the task of updating our posted FDP for review. The document currently posted is a food defense/site security policy. I think I'm replacing these with the food defense plan, but the policy is a completely different doc (although I think it was put together prior to having the FDP). Does anyone know if having a separate policy is a necessity, or is the FDP typically all that's required? I should add we're transitioning from SQF to FSSC 22000 next year.
Hi Steiny_A,
Welcome to the forums! It sounds like you have a hectic month or so ahead of you, so good luck.
To answer your first question, yes, you need up-to-date certs. Every organic certificate has the original date of certification, and an expiry date as well. Organic certificates last 1 year, so you will need to get the current certs from all your organic suppliers.
Not sure about question #2, since I never used the FDA builder.
Hi Steiny_A
I haven't used the food defense plan for my company but I have looked at it to compare against our plan and it seems more like the FDA Food Defense plan is and all in Food safety, quality, defense plan. I recommend having the policy separate unless you have a separate building security SOP.
HI Steiny, Welcome!
Looks like the above have answered your questions.
I just have one thing to add - if you are the one to lead the SQF Audit and it is only in 4 weeks I would suggest talking with your manager about postponing it for another month or slightly more, as preparation time is severly limited and also consideiing the change over to FSSC. There would be a charge for changing dates, however if you explain that you just joined the organization that should be enough for a change out.
Hello and welcome!
To answer your questions...I'm assuming you are in the US.
1. The requirement is 18 months. Typically, people say annually, but organic certifiers like QAI recognize there is a general lag in the audits / inspections to re-certification. So, any Organic Summary Plan (OSP) and Certificate (you need both from all of your ingredient suppliers) dated within 18 months of the date of your organic inspection is valid. Certificates will have an origination date, but there is a second date that shows "re-inspection" or "renewal". This is the date that needs to be within 18 months (the same applies to the OSP). The OSP needs to identify the ingredient you purchase and use from the supplier.
2. When I used the FDA Food Defense Builder I had a separate food defense "policy" which referenced the use of the Food Defense Builder and the outcomes from the builder and how we covered the gaps or exposed areas to contain or better defend the area of risk.
I won’t be the one leading these audits thank goodness. If I was I wouldn’t make it from the aneurysm I’d be having.
Hello and welcome!
To answer your questions...I'm assuming you are in the US.
1. The requirement is 18 months. Typically, people say annually, but organic certifiers like QAI recognize there is a general lag in the audits / inspections to re-certification. So, any Organic Summary Plan (OSP) and Certificate (you need both from all of your ingredient suppliers) dated within 18 months of the date of your organic inspection is valid. Certificates will have an origination date, but there is a second date that shows "re-inspection" or "renewal". This is the date that needs to be within 18 months (the same applies to the OSP). The OSP needs to identify the ingredient you purchase and use from the supplier.
2. When I used the FDA Food Defense Builder I had a separate food defense "policy" which referenced the use of the Food Defense Builder and the outcomes from the builder and how we covered the gaps or exposed areas to contain or better defend the area of risk.
I have never heard 18 months being valid for a certificate. In a past life, I worked with organic and to my knowledge it was 1 year, even with lag. We always had our inspection at least a couple months before the renewal date.
I have never heard 18 months being valid for a certificate. In a past life, I worked with organic and to my knowledge it was 1 year, even with lag. We always had our inspection at least a couple months before the renewal date.
Tis true...see below from QAI's website.
A certificate with a product addendum should be considered current if:
- The certificate was issued within 18 months.
- The product addendum was issued within six month.
- There is a future “anniversary date” or “annual monitoring date” on either the certificate or product addendum.
I would do all those audits and I only had 1 year of experience. Do not panic it will be okay. I did my first Organic audit 3 months into my position, I also did not have a manager or any relevant experience. All self taught and passed them first time around. For me the hardest thing was the mock recall which I trained for everyday.
For organic certs I would use https://organic.ams.....gov/integrity/ to double check. One time someone gave me a fake cert and if it weren't for double checking I wouldn't have been able to tell.
For SQF I would suggest pushing it further out if you are the lead, I believe you need to also be an SQF Practitioner to be able to complete this. Someone correct me if I am wrong, on this one.
I agree with previous post refer to USDA integrity data base to ensure the certificate is still valid. You should also check on https://organic.ams....SearchPage.aspx to ensure that the certification body If its not a well know one is actually recognized by the USDA as both are important.
In regards to expiry dates, On US issued organic certificates there is no official expiry date but there is a renewal annually for which they will be issued a new certificate. Each certification body accepts various difference as they recognize there is a delay between audit and issuance of a certificate. Sometime I ask for the closing meeting letter of the audit as evidence. Some CB's accept 14 months and some 18 months it depends on the CB.
The USDA database also sometimes attaches the certificate for the company on the site so thsi may be a great place to get the certificate if you are having trouble getting it front the supplier.
For the food defense the policy and plan are different a policy is signed by management saying that you have a plan in place but the plan provides step by step actions you take to demonstrate compliance.
Well that's something. I never knew a certificate was valid for 18 months. Thanks for the knowledge!