We are in the middle of our recertification audit for SQF 8 Module 2 & 11 and Quality code as well. We are on day 2 and there are non conformances from yesterday that I am questioning.
1. We only have 1 Allergen- Coconut which is a liquid ingredient, fully enclosed sealed container. Last year she made us put it on a shelf by itself. Which we did. The top shelf, because you basically need a step stool to reach it. It is also labelled Allergen in BIG letters - hot pink the hole thing. We only use it on average of twice a year as well.
Part of our Mixing procedure it to very the container is intact. ( No leaks, broken seals etc)
She is writing the non conformance because it could leak from the top shelf onto the other ingredients. All the ingredients below it, are also sealed containers and checked again once used. Not to mention on the off chance it did actually bust a hole and start leaking, it would make an obvious sticky mess.
Thoughts on this? Is she right? What are my grounds to fight it on?
2. We are a bottled water plant. Our site license says Public Water Supply even though it is Spring Water, that is what it says. FDA Rules says you test it bi-weekly. Which we do. She is saying that IBWA says that source water must be tested weekly. We are not a MEMBER of IBWA - and she says that doesn't matter because the code says all regulatory and association requirements should be followed.
3. Missing Mgmt Review Policy/Procedure is requied. We have the form we use, it has been completed monthly. In 2 seperate Policies, Mgmt review is called out as '
" Site and departmental annual objectives and targets are agreed and documented in the Mgmt Review minutes form ( SSR0050-01) which outlines required topics to be covered, The managment review will cover at minimum Haccp, follow up from previous meetings, review of the policy manuals, Internal/External audit findings, Customer Complaints, resolutions and trends, Food Safety Objectives, Quality Issues, Continuous Improvement and Corrective Actions/KPI.
in the Food Safety & Quality Manual, it states Senior Mgmt team will ensure that the design and implementation of the FSMS is within the guidelines of the customers, statutory and regulatory documents and take into consideration - Varying needs of the Business and customer. Business enviroments, changes in the enviroments and risks associated, Company objectives, processes employed onsite, as any other topics deemed necessary and documented on the Mgmt review form SSR0050-01.
Does it really have to have its own Policy and Procedure to tell you to fill out the form? And the form does list all of the requirements that have to be covered annually or more frequently, with room to add anything deemed necessary or relevant.
She wrote 9 her first day, 3 of which are valid - stupid and minor, but valid. I already know my argument for 3 of them, then there is these 3.