Does SQF require a SQF Practitioner to be on-site at all times?
Does SQF require a SQF Practitioner to be on-site at all times? Does a second shift require a full time practitioner?
Yes.
Step 2: Designate an SQF Practitioner The SQF Food Safety Code: Food Manufacturing requires that every certified site has a suitably qualified SQF practitioner to oversee the development, implementation, review, and maintenance of the SQF System, including the system elements, Good Manufacturing Practices (GMPs), and food safety plans. The requirements for an SQF practitioner are described in the system elements, Part B: 2.1.1.4 and 2.1.1.5. You may choose to have more than one SQF practitioner to meet shift and operational requirements. An alternative staff member should also be identified to manage the SQF System in the absence of the designated SQF practitioner.
We have never had a Practitioner on site at all times. Our Practitioner oversees all of the programs, but is not on site all the time,
I do not think that has changed for the new version.
We have never had a Practitioner on site at all times. Our Practitioner oversees all of the programs, but is not on site all the time,
I do not think that has changed for the new version.
Very interesting, I (and our consultant) always believed the above quoted line to mean there must be someone on shift. Wonder if we were duped into training multiple people, or if our consultant truly believes there must be someone on site.
No, you just need a practitioner in your facility that oversees the whole program.
Refer to "Guidance for Developing, Documenting, Implementing, Maintaining and Auditing an SQF Food Safety System for Manufacturing SQF Code, Edition 8.1–SQF System Elements for Manufacturing" document page #13.
"The SQF practitioner is the individual designated by senior management to develop, validate, verify and maintain the company’s Food Safety Plans, and assume control of the daily operation of the SQF System"
I take daily to mean day-to-day, NOT all day. As in someone who works in the facility every day. A Practitioner should not be from another site.
This is what SQF 9.0 says:
I don't think that changes my thoughts on 24/7 coverage. Our plan calls for the QA Manager to be the Practitioner and the Plant Manager to be the back up. Neither one of us would be on vacation at the same time.
I've never been in a facility with a 24/7 coordinator whether its BRC/SQF/FSSC
Strictly speaking this is an admin positon (a technical one)
I would hope program changes are not being made at 2am without everyone around
No. I'm an SQFP and in my humble experience, the definition requires the practitioner "to oversee the development, implementation, review, and maintenance of the SQF System, including the system elements, Good Manufacturing Practices (GMPs), and food safety plans." That is more of an "oversight and management" function than an operations function... We have HACCP trained people on all shifts, if questions arise, but good planning and communication prevent the need for 24/7 SQFP.
Standards will always be interpreted differently by different people. The key is that you can defend your interpretation and operate accordingly.
If you have 24/7 SQFP, that's a bonus in my mind, but you should survey your external auditors over the next several years and see what they tell you.
Does SQF require a SQF Practitioner to be on-site at all times? Does a second shift require a full time practitioner?
Technically YES, however - you must have a backup (AKA Cover) person that can double as the SQF Practitioner - so, no the key practitioner does not need to be onsite, but a backup must be in that case.
As for a 2nd shift - same applies.
What about the ability to be available by phone?
For example, I'm offsite at a customer trial, but I'm still available by phone should the facility need me. And for the sake of being thorough, lets say my trained backup practitioner is also at the customer trial and also available by phone. Do I need another backup practitioner present at my facility, or is the availability of both practitioners by phone considered acceptable?
Technically YES, however - you must have a backup (AKA Cover) person that can double as the SQF Practitioner - so, no the key practitioner does not need to be onsite, but a backup must be in that case.
As for a 2nd shift - same applies.
Where is the code does it say this Glenn? As I mentioned before, worked in many facilities where this doesn't happen (nor would it). For 2nd and 3rd shift operations there will (most likely) be QA techs available to find and follow through on deviation procedures that have already been created-worst case scenario everything goes on hold pending investigation and/or release/disposal. Many companies would push back hard on the expensive if the code doesn't actually require it-lay it out plainly
I can't speak to what every auditor is looking for, however I have always been fine with 1 SQF practitioner and 1 backup on the payroll. I was SQF Practitioner at one location, and back-up at the other, and the lab manager was flipped. To reiterate, we did NOT have an SQF practitioner on weekends and midnights, this was never an issue with any SQF auditor.
I could imagine if an auditor were to push for that, the owner would laugh and ask me to find another auditing body or GFSI certification scheme.
No where does it state amount of time present, quantity of practitioners (beyond the primary and backup) or physical presence at multiple locations. The statement "Senior site management shall designate a primary and substitute SQF practitioner for each site" it doesn't state a separate person / practitioner for each site so you could interpret it to allow the same person to be designated at more than one site. Obviously the proximity of the sites is a consideration. Across the street, down the street or 100 miles away would all require different considerations and might require multiple SQFPs to effectively apply the FSMS at each site. That being said, handling more than one site, unless identical operations, would be very difficult and I would not want to be that person for certain! For instance, if one FS Manual would accommodate both locations and they were in relatively close proximity, you could see adequate effectiveness without requiring multiple primary SQFPs.