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Do products not in SQF scope need to be in HACCP Plan?

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Best Answer , 12 February 2020 - 10:27 PM

But you will need to have food safety plans for FSMA that are HACCP based by a PCQI, even if they are out of scope for SQF.


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Jonco

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Posted 12 February 2020 - 02:29 PM

2.4.3.2 The food safety plan shall be effectively implemented, and maintained and outline the means by which the site controls and assures food safety of the products or product groups included in the scope of the SQF certification and their associated processes. More than one HACCP food safety plan may be required to cover all products included in the scope of certification.

 

Does this mean that products not in the scope of certification do not need to be included in HACCP?



Charles.C

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Posted 12 February 2020 - 04:23 PM

2.4.3.2 The food safety plan shall be effectively implemented, and maintained and outline the means by which the site controls and assures food safety of the products or product groups included in the scope of the SQF certification and their associated processes. More than one HACCP food safety plan may be required to cover all products included in the scope of certification.

 

Does this mean that products not in the scope of certification do not need to be included in HACCP?

 

Hi Jonco,

 

from the Guidance  -

 

1. ………..The scope of the HACCP Food Safety Plan must also be determined, e.g., the products included in the plan and the start and end points of the process under consideration.

4. Construct a process flow diagram that covers the agreed scope (see step 1 above) of the process and includes all process inputs (e.g., raw materials, packing materials, processing aids), and outputs (including second grade product, product for rework).  Every step in the process must be identified.

 

 

etc, etc >>> haccp plan

 

So, by (converse) Logic, Yes, not needed to be included.

(this assumes no haccp-related process interactions between included/excluded items)

.


Kind Regards,

 

Charles.C


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PQAManager

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Posted 12 February 2020 - 10:27 PM   Best Answer

But you will need to have food safety plans for FSMA that are HACCP based by a PCQI, even if they are out of scope for SQF.



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SQFconsultant

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Posted 12 February 2020 - 10:48 PM

 

 

Does this mean that products not in the scope of certification do not need to be included in HACCP?

 

Yes that is correct - but only for SQF.


All the Best,

 

All Rights Reserved,

Without Prejudice,

Glenn Oster.

Glenn Oster Consulting, LLC -

SQF System Development, Implementation & Certification | eConsultant | Internal Auditor Training

http://www.GCEMVI.XYZ

https://glennoster.website3.me/

 


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Posted 13 February 2020 - 12:08 AM

Yes that is correct - but only for SQF.

 

Hi SQFC,

 

I would guess it is generally true unless there is a possibility of situations such as noted in the BRC quote below ? (I did not see any specific reservations in SQF Code but I daresay they may be there somewhere ?)

 

BRC8 has the caveats below, some of which are obviously relevant to haccp considerations, eg especially the last comment -
 

 

The exclusion of products produced at a site will only be acceptable where:
•  the excluded products can be clearly differentiated from products within scope, and
•  the products are produced in a physically segregated area of the factory.

Where exclusions are requested, these shall be agreed with the certification body in advance of the audit. Exclusions shall be clearly stated on the audit report and certificate and the justification recorded on the audit report.

The certification of products must include an audit of the entire process from raw materials to end-product dispatch. It is not possible to exclude either parts of the process undertaken at the site or parts of the Standard.

 

Where exclusions are accepted, the auditor shall assess any hazards presented by excluded areas or products (e.g. the introduction of allergens or foreign-body risks) and non-conformities may be raised relating to the excluded area where this poses a risk to the products within the audit scope.

 


Kind Regards,

 

Charles.C


SQFconsultant

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Posted 13 February 2020 - 01:54 AM

Hi SQFC,

 

I would guess it is generally true unless there is a possibility of situations such as noted in the BRC quote below ? (I did not see any specific reservations in SQF Code but I daresay they may be there somewhere ?)

 

BRC has these caveats, some of which are obviously relevant to any haccp considerations, eg the last comment -
 

 

It is true - however, while I have seen companies exclude certain product lines I have never seen companies not include those excluded products on the HACCP plan.

 

For the OP and the question - I can absolutely say YES, that is correct - and I did not take it further than that - if I had I would say that I would not suggest doing so.


All the Best,

 

All Rights Reserved,

Without Prejudice,

Glenn Oster.

Glenn Oster Consulting, LLC -

SQF System Development, Implementation & Certification | eConsultant | Internal Auditor Training

http://www.GCEMVI.XYZ

https://glennoster.website3.me/

 


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Jonco

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Posted 13 February 2020 - 03:50 PM

Thank you all for the feed back!

 

 

But you will need to have food safety plans for FSMA that are HACCP based by a PCQI, even if they are out of scope for SQF.

 

It is true - however, while I have seen companies exclude certain product lines I have never seen companies not include those excluded products on the HACCP plan.

 

For the OP and the question - I can absolutely say YES, that is correct - and I did not take it further than that - if I had I would say that I would not suggest doing so.

 

That was my assumption, but try to avoid operating on what I assume.  I appreciate the confirmation.

 

The points made will help me explain it to my boss.  :cool:

 

 

 

Thank you all for the feed back!





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