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SQF 2.7.1.3 Food Defense Challenge - all elements needed?

Started by , Nov 18 2019 03:11 PM
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Hello all,

 

I am confused about SQF 8.1 food defense challenge: 

2.7.1.3 The food defense plan shall be reviewed and challenged at least annually.

 

We have 6 elements in our Defense Program: inside security (motion sensor), outside security (fence), storage security (chemical), S&R security (seal), mail handling, etc etc... 

 

Do all elements have to be challenged annually? Or can we challenge 2 elements every year, and finish one round within 3 years? 

 

 

(Similar to Crisis management, it's tested annually, but only for one crisis scenario. I personally think 1-2 elements for Food Defense Challenge would be enough, but would like to discuss and confirm). 

 

 

 

Appreciate any help from you!

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We only challenge one aspect of our defense program annually.  It must be a true challenge though, really in-depth and detailed.  This past year we had an unannounced visitor try and break in and walk around the facility to test our employees knowledge.  I gave him some pointers on our weak spots, and he actually got inside unstopped!  Not my proudest moment, and despite the failed test we have never received a non-conformance due to our defense challenge.  

You are over thinking this.

 

Nowhere in the standard says what you have to do, it just says there should be an annual review and challenge. You just have to make sure you are compliant with an annual review and a challenge, however you do it, should be on your written procedure and should be acceptable to an auditor.

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I agree with Majoy. It doesnt need any overthinking. Just make sure your procedure is there (validated, reviewed) and come up with a written challenge of your choice. Like flooding, earthquake...etc Can also include a training to show your auditor everyone knows what they do during crisis.  

We had an employee's spouse walk into the plant to see if any of our employee's would stop them, we monitored the situation from a distance. Our employee's stopped the so called intruder, our challenge was a success and our auditor and the USDA accepted this as our challange.

For 2.7.1 Food Defense our test scenarios include:

 

A person attempting to gain entrance to our facility uninvited or a Break in. If he is successful we fail but identify the weak points and mitigate.

 

A person attempting to bypass our visitor policy - No badge or accompaniment. Or the one not signing in saying: "I just need to see so and so for 2 seconds. Can I just run back there really quickly? I'll just run out after I see them." Also, trying to ring in at a door other than the visitor's entrance. We had a person come to shipping, ring the bell and request to see the President (asked for by name). They were politely told they could not come in and had to go to the front office and sign in.

 

A person already in the building (We let them in for the test). This test measures how long it takes before he is seen AND reported. The longest time was about a minute and a half.

 

Your specific scenarios might be different for your facility / operation. Weather related and other disasters like flooding and earthquake need to be tested but that would be in 2.1.5 Crisis Management Plan / Planning.

Hi everyone,

Our food defense challenge was failed. I left a box with black tape and poison and a flammable sign on it in the common area, and all the employees passed by the box, saw it but no one reported it to the QA/management. Should I open a NON-CONFORMITY? What should be the corrective actions?

Hi everyone,

Our food defense challenge was failed. I left a box with black tape and poison and a flammable sign on it in the common area, and all the employees passed by the box, saw it but no one reported it to the QA/management. Should I open a NON-CONFORMITY? What should be the corrective actions?

Yes! No system is perfect, this should show the auditor that you recognize there is a gap in your procedures.

 

Write up a deviation on this, corrective action is re-training of relevant employees on your procedures.

 

Follow-up with another round of mock challenge and see if the employees are now able to recognize this and then close your deviation.

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Yes! No system is perfect, this should show the auditor that you recognize there is a gap in your procedures.

 

Write up a deviation on this, corrective action is re-training of relevant employees on your procedures.

 

Follow-up with another round of mock challenge and see if the employees are now able to recognize this and then close your deviation.

Thank you for your input. Do I need to open a non-conformity?

My recommendation is to open a Corrective Action and re-test your Food Defense Program.

We failed our challenge test and opened a Corrective Action, the auditor asked us for a second challenge to be sure the issue was addressed; we did a second challenge and record the result to close the CAR.

Thank you for your input. Do I need to open a non-conformity?

 

A team of people with the relevant knowledge and skills to review the outcome, propose and carry out a corrective action should do so.  If in your programs that means "opening a non-conformity", then yes.

 

The effect will mean the most, but "do what you say" will also be observed by the auditor.


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