Technical Interpretation of the Code

We had our recertification audit recently, and a question came up with the auditor. I'm a bit surprised by his interpretation, but I guess I could just be misunderstanding the expectations of the code.  (Wouldn't be the first time.) 

Essentially, he stated that if there is a requirement in a section, it needs to be addressed in an SOP of the same name. 

So as an example: 2.4.1. - Food Legislation.

We have a few different SOPs - 1 for handling an on-site Regluatory inspection, a "Regulatory Requirements" SOP (Details the resources we use to keep up to date on both Regulatory changes as well as SQF, (even though I know SQF isn't regulatory), and a Product Recall/Withdrawl" SOP.

The final point of the section, 2.4.1.3 - SQFI and the certification body shall be notified in writing within twenty-four (24) hours in the event of a regulatory warning. Notification to SQFI shall be by email to foodsafetycrisis@sqfi.com.

So therefore, we considered there are two situations which might involve us getting a regulatory warning.  1) A Warning Letter from an inspection or 2) Product withdrawl and recall.  We therefore have the contact information for SQFI and our CB listed in the Recall and the handling of a regulatory audit.

It's considered a minor for not having the contact information (or the instructions to contact) in our "Regulatory requirements" SOP, because that's the section it's listed under in the SQF code. 

While I see his point and it's easy to fix, I guess I was just surprised that was the literal expectation of the code.  Has this been other's experience?  Was this just my mistake in not having a good understanding of SQF expectations? 

Quoted in part:

"It's considered a minor for not having the contact information (or the instructions to contact) in our "Regulatory requirements" SOP, because that's the section it's listed under in the SQF code. 

While I see his point and it's easy to fix, I guess I was just surprised that was the literal expectation of the code.  Has this been other's experience?  Was this just my mistake in not having a good understanding of SQF expectations? "

.........................

I've never seen this happen before and I did a couple of hundred SQF Audits when I was with a CB and over the past twelve years as an SQF Consultant.

This is a miss-call and this does represent the proper expectation for this section of the code.

If the point is important to you I would challenge it - frankly whether it is important or not I challenge anything that is out of left field from an Auditor.

Hey Xoinks,

I had a similar situation during an SQF audit a few years ago. We weren't given a minor but it was listed as an observation. Our auditor informed us he would most likely determine it to be a finding if not added for the next audit. I'm not sure if I fully agree with it, but it is something I've heard of before. Depending on the auditor, I would think you should be able to have a discussion with them and have the minor dropped.

I've always had them get hung up on making sure the CB and SQF are notified in the event of a recall, and that their contact information and this step is specifically listed in our recall plan. That's always been a specific "gotcha" that I assume they're telling auditors to verify.

I've never had it mentioned in the regulatory requirements stuff, which I've always just folded into our management commitment SOP's. I agree with Glenn, I can see their point but I also haven't had someone go after it that way before. It does seem like something actually worth putting in the procedure, as I would totally forget to notify SQF in the event of a warning letter (would be busy lol). And a good reminder to management of the extent of the consequences of those actions e.g. if you have a customer that requires you to notify them in your contract as well, worth putting in the SOP as a reminder.

On this - that Austin just said " It does seem like something actually worth putting in the procedure, as I would totally forget to notify SQF in the event of a warning letter (would be busy lol). "

Yes, I forgot about that one, we do slug in at the bottom of the regulatory letter/written warning SOP that both the CB at such and such # and SQFI at the email address must be contacted.

I think we all know of 1 or 2 companies that got suspended because they failed to give notifications to SQFI and their CB, so I put it in a number of docs to ensure all four corners of the bread is covered with butter or peanut butter.

Thank you all for your discussion on this!   We didn't have many minors but we did have quite a few 'observations', so to speak - so in this case I'll just let it be.  It's been a few years since my SQF Practitioner training and frankly some of these kinds of "interpretation" things are what made me jumpy about SQF certification to begin with.  Though thankfully I've come to understand from the auditors I've had that most (or at least some) are more concerned that you're effectively managing food safety risks and meeting the key objectives of the code versus triggering surveillance audits due to 'nitpicky' points that can be difficult to infer from what's in writing.

I won't prioritize going through our other programs then to make sure that they all meet his interpretation - I'll just keep it on the internal audit schedule as I review programs.  

Thanks everyone!  

We address this by referencing in the scope section which part of the SQF requirements is being addressed.