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SQF 2.5.1 - any suggestions on how to show validation for activities?


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#1 karlieh

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Posted 17 December 2019 - 03:15 PM

Does anyone have any suggestions on how to write/show validation for activities?

Does it need to be a write up or will a checklist suffice? 

Does anyone have any templates or examples of how you validated?

 

Thank you!



#2 TimG

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Posted 17 December 2019 - 07:45 PM

Validation and Verification have always been something that seemed to be contradictory. I believe "verification" is the activity taken to prove something. Verification could be Inspection, demonstration (for instance watch them perform and SSOP), testing, analysis. 

Proof of VALIDATION that a program is working would be the act of compiling all of the verification data points, along with other pertinent data points (Excerpts from current policy/procedure, random document review, customer complaint review, etc.).These data points would be the evidence showing program validation.

I wont send you my document, you will have to create your own. But here's an excerpt of validation for 11.2.12.8 from last years IPM internal audit

Column 1 is the clause ## (I broke each clause out individually), column 2 is the wording in the clause, column 3 is evidence of program validation. I used both current policy and review of the IPM manual to validate that this particular clause was being followed.  The XXX's are in place to protect the innocent.

 

 

11.2.12.8

Pest contractors shall be: i. Licensed and approved by the local relevant authority; ii. Use only trained and qualified operators who comply with regulatory requirements; iii. Use only approved chemicals; v. Report to a responsible authorized person on entering the premises and after the completion of inspections or treatments; and vi. Provide a written report of their findings and the inspections and treatments applied.

  • XXX“Integrated Pest Management Policy” states
    • All pesticides used shall be applied by a certified applicator that is an employee of the approved licensed contractor.  The Pest Control Operator (PCO) is the only contractors approved for pesticide application and shall be licensed, insured and familiar with the specific requirements prior to application.
    • A written and detailed report is to be left by Pest Control Operator (PCO) at the exit meeting following a discussion of the issues
    • Pest Control Contractors shall report to the SQF Practitioner or Designated Office Employee on entering the premises and after the completion of inspections or treatments.
  • XXXX Pest Management Manual
    • Review of all past service reports show 2 PCO’s have performed service on this site, XXXXand XX.
      • XX “Commercial Technician” license from Texas Dept of Ag is listed in manual, with an expiration of 1/31/2020
      • XX“Commercial Certified Applicator” license from Texas Department of Agriculture expires 1/31/2020
  • Review of XXX Pest Management Manual shows a page entitled “2018 Approved Product List”
    • This list has spots for Category, trade name, EPA#, Active, % active, and Formulation/Description
  • Review of XX Pest Management Manual shows documentation of written reports of findings, inspections, and treatments.

 



#3 Charles.C

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Posted 19 December 2019 - 02:31 AM

Does anyone have any suggestions on how to write/show validation for activities?

Does it need to be a write up or will a checklist suffice? 

Does anyone have any templates or examples of how you validated?

 

Thank you!

 

Hi karlieh,

 

I suggest you study the detailed SQF Guidance material.

 

@tgoss, thanks yr input. I might add that SQF does not require validation, per se, of PRPs.

 

As previously discussed here, SQF Code has  a contentious history regarding the interpretation of  "Validation". Less so for Verification.


Kind Regards,

 

Charles.C


#4 clindsell

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Posted 19 December 2019 - 02:54 PM

Verification - proving you are doing what you say you are doing

Validation - proving that what you are doing is working and effective - does it work?

 

For SQF, you have to validate your PRPs and CCPs in your HACCP plan.

 

Validation examples:

1.  Personal Practices - Review the floor audits to ensure that employees are meeting the requirements of the program

2.  Training - Interview employees to ensure job training has been effective and that key points are understood

3.  Cleaning & Sanitization - Perform environmental testing to ensure environmental microbial loads are acceptable

4.  Foreign Material Control - Review customer complaints for foreign material contamination

CCPS - Metal detector - consult the literature and ensure that the test pieces used will prevent foreign metallic material in the product  (refer to See CPG Sec. 555.425 Foods, Adulteration Involving hard or Sharp Foreign Objects)

 

you get the idea.



#5 Juribe

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Posted 19 December 2019 - 03:33 PM

Consistent verification over time is validation, assuming the verification is proven to work.

 

If you can prove your verification is effective and routinely perform the verification that is a validation. 



#6 Charles.C

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Posted 20 December 2019 - 03:55 AM

Consistent verification over time is validation, assuming the verification is proven to work.

 

If you can prove your verification is effective and routinely perform the verification that is a validation. 

 

Some texts may agree with above, possibly(??) even including SQF despite Guidance/statements to the contrary, but Codex chronologically definitely does not.

 

SQF is a well-known shambles on the topic of Validation.

 

Nonetheless, for a nice example which may well have  never been exactly "valid" albeit SQF welcomed, and should, by now, be obsolete but probably isn't  see -

 

https://www.ifsqn.co...ams/#entry56545


Kind Regards,

 

Charles.C





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