Monthly Audits and Monthly Management Meetings

Hi all, 

I have a scenario for you. Please give any feedback you have.

A company's SQF Practitioner quit in January. Because of this and COVID-19 the monthly internal audits and management meetings were not completed for the months of February  - August.  The company was not able to hire another SQF Practitioner until September. Once hired, the SQF Practitioner picks up the meetings and audits again for what was missed per the company schedule starting with February. These meetings and audits are being conducted on a weekly basis instead of a monthly basis in order to be ready for the SQF Recertification Audit in December. Is this acceptable or will the company be issued a nonconformance for not following the monthly schedules when there was no SQF Practitioner on site?

Company will be issued a non-conformance.

Hopefully someone informed the CB that there was not an SQF Practitioner.

The question is, where is the cover person - did that person leave too?

What type of non-conformance would they be issued? Minor, Major, or Critical?

Unfortunately, the guidelines do not allow for missed meetings and internal audits during time of turnover. The best you could do, would be to document a corrective action and explain the situation. During times of turnover, companies may be encouraged to outsource these special projects to assure year-round compliance with the SQF code.

Glenn would know better, but I believe this would be a Major bordering on Critical. SQFI has strongly suggested (I think required?) that the facility have a back-up practitioner who maintains familiarity with the locations FSP for just this type of occurrence. If you follow Danny's suggestion of documenting a corrective action, having a back-up practitioner should be one of the corrections.

AFAIK...you are required to have a backup SQF practitioner, or at a minimum a backup plan in case the SQF practitioner is incapacitated.  As someone else mentioned best to have a corrective action to ensure it does not happen again.

Not having an adequate, qualified back up could indicate a critical system failure. Your procedures should include the Practitioner / Food Safety / QA's responsibilities and SOPs for how those functions are carried out so, even not having a trained Practitioner on site wouldn't necessarily mean non-conformance, even for a few months. You can't go back and make up missed meetings or IAs, so having the weekly meetings doesn't cover lost meetings or IAs. The accelerated IA's can't catch anything that has already happened 6 or 7 months ago. I also don't buy the "Because of this and COVID-19 the monthly internal audits and management meetings were not completed for the months of February  - August." The meetings could certainly have gone on in the absence of the Practitioner had there been any back-up at all at least virtually or by email. When we absolutely can't meet as a management team for updates, I gather findings from inspections and IAs into an email and send it "Read Receipt". I create a PDF of the email and all of the Read Receipt responses form the team and save them as that month's management meeting.

This is where your Continuous Improvement comes in: You've identified a gap, what are you going to do to assure it doesn't happen again?