SQF 8, Non Conformance during Audit for Allergen and Water Source Test

Hello all,

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. 

As to the allergen  - did the auditor tell you to put the allergen container on a top shelf?

That would make no sense - since that is a wrong procedure for storage.

If you decided to put it over other ingredients that is an error and there is no challenging this finding.

This infraction could be a major, if she is "nice" you may get by with minor.

Finding number 1. I was always under the impression you put the items with the most potential for contaminating other ingredients on the BOTTOM shelf.  That way, if it spills, it only contaminates what is directly below it.

You can't put Allergens and non-allergens together, better to segregate, ESPECIALLY having the allergen on top of the non-allergen! Unfortunetely she is right, that container may leak and you'll have allergen cross contamination. Don't understand why she told you to put it on top though..

Just one thing.

Choose your battles wisely.

And you may want to wait a bit today towards the end of the audit if you chose to battle these 3 findings above, maybe the auditor will re-calibrate her findings and will come to his/her senses.

But, you got an exciting auditor there.

Thank you everyone on the help with Allergens. 

Any advise on the Mgmt Review write up, or the source water write up?  Source water is a major, and she is said she had to decide if Mgmt Review would be a major or minor. 

#2 is a wrong finding by  the Auditor, fight that one.

as to review, my clients do a once a year in depth review of SQF and related, it seems quite time consuming to do one of these 1-2 day things once a month, yikes.

Save your challenges for the end of the audit, something found in-line during the audit can change to a non-issue by the end of an audit.

From what I can gather your audit will result in a failure - you may have some challenges to do later on as well directly with the CB and SQFI as a backup.

We are FSSC certified and a very small package manufacturing company.  We have our management review broken into segments starting in Sept.  We have taken a designated set of ISO and PRP programs and review the policies, procedures, forms, and records. Our last meeting includes; Haccp, follow up from previous meetings, internal/external audit findings, customer complaints, food safety objectives, quality issues, continuous improvement and corrective actions, KPI. I write a report culminating everything for the last four months.  

We have not had a problem thus far with the auditor, however we have a new auditor coming in 2020.  :unsure:

First I have to agree with the auditor as far as an allergen should never be above a non-allergen whether sealed or unsealed.

Second I am unclear if you are referring to the monthly SQF meeting or the annual SQF meeting with management?

For the monthly meeting we document the minutes and attendees from the meeting and for the annual we have a documented SOP which describes all topics reviewed which is signed by managers after it is completed every year.

Thanks!

Chris

#1) Agree with auditor and everyone else; it is valid.

#2) Agree with SQF Consultant, prepare to argue and if needed appeal it with the certification body.  Code is very vague so as long as you have justification for what your are doing and your results have been consistently acceptable you should be good.

#3) I was told when we first got into SQF that if the code lists an element as mandatory that you needed a program or at the very least a procedure for it on how you will meet the code; you can't just be doing what the code says.  I will admit that when we started we did not have programs addressing elements 2.1.1, 2.1.2, 2.1.3 or 2.4.1 so we had to develop them.  Basically we took the wording from the code and put it in the format for our programs.  

Thank you everyone for your input  We actually only ended up with 10 minors.  She still wrote the Allergen ( Coconut) on the top shelf  - which in retrospect you were all correct, but we had followed our policy and procedure and she did it as the procedure was not sufficient, rather than a major. 

We won the argument on the source water, and took the hit on Managment review. 

Congrats for passing the audit at least!