8 replies to this topic

[MrsKingdom999]

For Reference...

2.3.3.3 Contractual agreements with third party storage and distribution businesses shall include requirements relating to customer product requirements and compliance with clause 2.3.3.2 of the SQF Food Safety Code: Food Manufacturing. Contractual agreements shall be approved by both parties and communicated to relevant personnel. The site shall verify compliance with the SQF Code and ensure that customer and regulatory requirements are being met at all times.

In section 2.3.3.2 one of the statements is that Contract Manufacturers need to be GFSI certified. My question is if 2.3.3.3 states that third party storage has to comply with section 2.3.3.2, does that mean that all third party storage facilities need to be GFSI certified? I just want to make sure I am reading this correctly. We have not required third party storage facilities to be GFSI certified before.Thanks in advance!

[Scampi]

No it does not

Contract manufactures are sites that you pay to make your product at their facility 

 

3rd party storage are locations that you pay to HOLD and/or SHIP your product. 

 

Hope that helps

[MrsKingdom999]

Thanks Scampi, I agree. My fear is that, with how it is written, it could be taken both ways because it says in 2.3.3.3 to comply to 2.3.3.2. 

 

No it does not

Contract manufactures are sites that you pay to make your product at their facility 

 

3rd party storage are locations that you pay to HOLD and/or SHIP your product. 

 

Hope that helps

[Scampi]

If you read the entire reference it states:

2.3.3.2 The site shall establish a method to determine the food safety risk level of contract manufactured product and shall document the risk. The site shall ensure that:

i. Products and processes of co-manufacturers that are considered high-risk have undergone an audit by the site or third-party agency to confirm compliance with the SQF Food Safety Code: Food Manufacturing and regulatory and customer requirements;

ii. Products and processes of co-manufacturers that are considered low-risk meet the requirements of the SQF Food Safety Code: Food Manufacturing, or other GFSI benchmarked certification programs, and regulatory and customer requirements; and

 

No where does it state they must be SQF certified and it specifically says co-manufacturers not DCs or warehouses

 

So the warehouse must have a plan in place for sanitation, allergens etc, that you've seen and approved

[majoy]

If you read the entire reference it states:

2.3.3.2 The site shall establish a method to determine the food safety risk level of contract manufactured product and shall document the risk. The site shall ensure that:

i. Products and processes of co-manufacturers that are considered high-risk have undergone an audit by the site or third-party agency to confirm compliance with the SQF Food Safety Code: Food Manufacturing and regulatory and customer requirements;

ii. Products and processes of co-manufacturers that are considered low-risk meet the requirements of the SQF Food Safety Code: Food Manufacturing, or other GFSI benchmarked certification programs, and regulatory and customer requirements; and

 

No where does it state they must be SQF certified and it specifically says co-manufacturers not DCs or warehouses

 

So the warehouse must have a plan in place for sanitation, allergens etc, that you've seen and approved

However, when you look into the appendix the definition of Contract Manufacturer (or co-man, co-manufacturer) is

Facilities that are contracted by the SQF certified site to produce, process, pack and /or store part of or all of one or more products included in the site’s SQF scope of certification. In some cases, a product may be manufactured interchangeably at the certified site and by the contract manufacturer. In other cases, a contract manufacturer may only be used intermittently to fulfill or supplement the certified site’s production. Contract manufacturers must follow the requirements outlined in the SQF Food Safety Code.

 

This is also an issue for our site as we never require 3rd party storage to have GFSI certifications. If an on-site audit conducted by the SQF certified site (using a SQF Food safety code patterned audit checklist) is conducted to the 3rd party storage, will this be sufficient to show compliance?

Edited by majoy, 19 March 2021 - 06:16 PM.

[Scampi]

Remember, by definition STORAGE only is NOT manufacturing

 

You sometimes have to make a flow chart just to work through the code!

 

You are correct, what you have been doing is sufficient for STORAGE only facilities

 

BTW, there is certified storage available, depending on where you are, but it's not cheap

[Mulan1010]

2.3.3.3 "...The site shall verify compliance with the SQF Code and ensure that customer and regulatory requirements are being met at all times." -  We are working to meet this new detail ourselves. 

  I agree with Scampi that Cold Storage sites are different from Co-Manufacturers. 

  From my perspective, if the cold storage site is not audited by a GFSI approved auditing scheme then I think you would need to do one of the following:

• have an audit on file done by your company (as Majoy suggests use the SQF Checklist as a guide for audit) to ensure you can support you meet the requirement. Unfortunately some companies do not have the resources for this or the company has not opened up travel yet.  or 
• at the very least have a copy of whatever 3rd party audit the cold storage site has and then you fill out the SQF Checklist based on the audit results.  You may need to ask to see some of the location's documents (if they do not want to send them they could share documents through Teams or other format) so you can check off they meet the SQF Code Requirements for Storage and Distribution.  

[Mightyquinn]

Yes in the US and for SQF, your 3rd party storage and distribution companies are required to meet SQF (GFSI) standards, regulatory and customer as well. If high risk, must have a GFSI audit. If low risk, you could audit them showing they meet the requirements or require them to get a 3rd party audit. Most 3rd party storage and distribution companies I have used recently are all audited by a 3rd party and most are now GFSI. The times have changed and they are required to meet this as well as your suppliers under FSVP.

 

2.3.3.3 Contractual agreements with third party storage and distribution businesses shall include requirements relating to customer product requirements and compliance with clause 2.3.3.2 (see below)of the SQF Food Safety Code: Food Manufacturing. Contractual agreements shall be approved by both parties and communicated to relevant personnel. The site shall verify compliance with the SQF Code and ensure that customer and regulatory requirements are being met at all times.

 

2.3.3.2 The site shall establish a method to determine the food safety risk level of contract manufactured product and shall document the risk. The site shall ensure that:

    i. Products and processes of co-manufacturers that are considered high-risk have undergone an audit by the site or third-party       agency to confirm compliance with the SQF Food Safety Code: Food Manufacturing and regulatory and customer requirements;

    ii. Products and processes of co-manufacturers that are considered low-risk meet the requirements of the SQF Food Safety Code:    Food Manufacturing, or other GFSI benchmarked certification programs, and regulatory and customer requirements; and

    iii. Changes to contractual agreements are approved by both parties and communicated to relevant personnel.

[Charles.C]

Apart (partly) from the 1st Line, I agree with Post 2 and, afai can see, so does all the available Literature. eg -

 

https://www.linkedin...ricardo-cordero

 

Seems that SQF have invented a new interpretation of Contract Manufacturer. I guess it saved texting another Clause to include external Storage Locations.

Edited by Charles.C, 20 April 2021 - 10:31 AM.
amended