10 replies to this topic

[Food Police]

"2.5.4.2 On-site personnel that conduct ENVIRONMENTAL or product testing shall participate in an applicable proficiency testing program at least annually to ensure accuracy of results"

 

Does this mean personnel doing environmental testing (like doing yeast and mold plates in-house) have to have some special training once a year? OR does this mean we have to challenge our accuracy by (for example) placing two identical yeast and mold plates at each test site, and send one set of plates to the lab for counting in order to compare our in-house count?

 

Thank you for the help in interpreting this clause

[SQFconsultant]

It is for your personnel.

[Charles.C]

"2.5.4.2 On-site personnel that conduct ENVIRONMENTAL or product testing shall participate in an applicable proficiency testing program at least annually to ensure accuracy of results"

 

Does this mean personnel doing environmental testing (like doing yeast and mold plates in-house) have to have some special training once a year? OR does this mean we have to challenge our accuracy by (for example) placing two identical yeast and mold plates at each test site, and send one set of plates to the lab for counting in order to compare our in-house count?

 

Thank you for the help in interpreting this clause

 

typical SQF confusing semantics.

 

Previous threads seem to primarily  support the latter option of above although I suppose the latter if unsuccessful might ultimately involve the former, eg -

 

https://www.ifsqn.co...ng/#entry121355

https://www.ifsqn.co...42/#entry119863

https://www.ifsqn.co...ng/#entry123204

https://www.ifsqn.co...42/#entry120017

 

(the 2nd link of above 4 seems popularly cross-referenced in some of the others, its quoted paragraph is from the SQF Guidance)

[RDM_Rep]

To piggy back on this, can anyone confirm if this process is necessary for a manufacturer of food packaging and plastics? We don't work with any organic material, we simply manufacture the packaging and sell plastic supplies. Per my understanding, 2.4.4 seems to apply to work with organic matter?

[Charles.C]

To piggy back on this, can anyone confirm if this process is necessary for a manufacturer of food packaging and plastics? We don't work with any organic material, we simply manufacture the packaging and sell plastic supplies. Per my understanding, 2.4.4 seems to apply to work with organic matter?

 

I assume by "process" you mean "Proficiency testing".

 

The relevant/equivalent clause in SQF9 Packaging is presumably 2.4.4.2  ie -

 

2.4.4.2   Product analyses shall be conducted to nationally recognized methods, company requirements, or alternative methods that are validated as equivalent to the nationally recognized methods.
Where internal laboratories are used to conduct input, environmental, or product analysis, sampling and testing methods shall be in accordance with the  applicable requirements of ISO/IEC 17025, including annual proficiency testing for staff conducting analyses.
External laboratories shall be accredited to ISO/IEC 17025 or equivalent international standard and included on the site’s contract service specifications list (refer to 2.3.2.7)

 

 

Seems reasonably explicit, ie to the same degree as same numbered clause in SQF9 Food Manufacturing (offhand only difference seems "analysis/analyses"). ?

[Scampi]

If you're doing ANY inhouse testing like allergen swabbing or ATP you need annual proficiency testing, which in my examples would be similar to annual CCP monitoring retraining.......observation that the SOP and methods are correct. Then you would sign off for the year

[Charles.C]

If you're doing ANY inhouse testing like allergen swabbing or ATP you need annual proficiency testing, which in my examples would be similar to annual CCP monitoring retraining.......observation that the SOP and methods are correct. Then you would sign off for the year

 

Hi Scampi,

 

As I understand the above, yr opinion is opposite to the (primary) interpretation of "proficiency test" as indicated in Post 3 ?

[Scampi]

You are correct, I disagree wholeheartedly

We correctly have a sanitation team I wouldn't dream of giving even an ATP metre too and they do not have the required PROFICIENY 

 

You need to be able to PROVE that the employee is proficient in the task

 

Lets assume Billy is the sanitation employee who performs allergen testing -rapid result  And that result determines whether or not the line is ready to run the next product.........the SQF facility has to ensure she displays the required proficiency to do that testing......e.g. has she been properly trained and does she understand what the test is trying to achieve

 

Not all employees have the required PROFICIENY to do this task ergo the SQF site is required to determine PROFICIENCY annually

 

"Where internal laboratories are used to conduct input, environmental, or product analyses, sampling and testing methods shall be in accordance with the applicable requirements of ISO/IEC 17025, including annual proficiency testing for staff conducting analyses." 

A rapid test for allergens or ATP or even e coli requires proficiency. The test in itself is a mini lab and done incorrectly can have huge implications

 

 

To answer the OP-this clause is to test PROFICENCY, NOT accuracy........although that is covered when the code tells you what standard in house lab testing must meet

[Charles.C]

You are correct, I disagree wholeheartedly

We correctly have a sanitation team I wouldn't dream of giving even an ATP metre too and they do not have the required PROFICIENY 

 

You need to be able to PROVE that the employee is proficient in the task

 

Lets assume Billy is the sanitation employee who performs allergen testing -rapid result  And that result determines whether or not the line is ready to run the next product.........the SQF facility has to ensure she displays the required proficiency to do that testing......e.g. has she been properly trained and does she understand what the test is trying to achieve

 

Not all employees have the required PROFICIENY to do this task ergo the SQF site is required to determine PROFICIENCY annually

 

"Where internal laboratories are used to conduct input, environmental, or product analyses, sampling and testing methods shall be in accordance with the applicable requirements of ISO/IEC 17025, including annual proficiency testing for staff conducting analyses." 

A rapid test for allergens or ATP or even e coli requires proficiency. The test in itself is a mini lab and done incorrectly can have huge implications

 

 

To answer the OP-this clause is to test PROFICENCY, NOT accuracy........although that is covered when the code tells you what standard in house lab testing must meet

 

Hi Scampi,

 

I don't disagree yr comments are relevant but as far as interpretation of "proficiency" goes, maybe also consider the (2017) SQF8 post/thread linked earlier, eg -

 

https://www.ifsqn.co...42/#entry119863

 

The SQF8 Packaging Guidance also includes this specific Audit Guidance -

 

Documented training records of staff conducting testing showing understanding of tests performed, as well as records to show proficiency;

 

Perhaps it's about time SQF included "Proficiency" in the Glossary.

[Scampi]

LOL.  There are lots of definitions that SQF should include!  And they could probably clean up the audit "guidance" as it mostly muddies the waters!

[RDM_Rep]

Thank you all for the information you've provided. On this, it's my understanding that 2.4.4 is not mandatory, though I am preparing a document to address it. However, sections 2.4.4.3-5 make reference to onsite laboratories, which we do not have. Do I still need to make mention of these in our document? It's my understanding that I wouldn't since it is not applicable.