3 replies to this topic

[Foodman98]

Hi, my company, a small facility, has recently successfully completed an SQF audit. I am new to the industry and do not have much experience with SQF and though we passed the audit, our auditor criticized many of our module 11 GMPs as being too broad and not specific enough to the facility.  We are reluctant to make them specific as we are regularly changing production processes and even the structure of the facility as we grow. For example for things like storage plan, how specific are you? Do you include specific products and where they are stored, do you include how the allergens are separated or do you just say allergens are separated? Do you include where processing tools are kept or do you reference a procedure that already specifies it? Thank You

[SQFconsultant]

When you say the auditor criticized your 11 section docs did he/she mark you up for these items or it was advice/suggestions?

This is an area where a broad approach will get you into trouble.

I would do a forensic review of this section and funnel things down to those that are a bit more specific.

This is an area where changes are often made - oh well that is life.

I won't get into your specific questions only to say that alkergen programs must be top notch - you can not do that by simply saying we separate these.

[Scampi]

You will probably find that managing an SQF program/facility is unlike anything else you've ever done in your life

 

NOTHING is written in stone, some of us may be on version 101 of a procedure due to changes, even subtle ones, that need rewording

 

Yes, you need to be specific-not so specific you paint yourself into a corner, but specific enough so that FOOD SAFETY is protected and you simply cannot do that with broad terms AND this relaxed approach is what leads to withdrawls and recalls

 

Your mention of tools-yes by all means you can refer to another procedure, in fact i recommend it HOWEVER, when making changes, you have to remember to check both programs

 

The heart of and GFSI audit is:

SAY WHAT YOU'LL DO AND DO WHAT YOU'VE SAID

 

So if you've said nothing--you simply are un auditable 

[Spidey]

It also helps when you are training personnel to be able to give them a detailed procedure that describes what you are training them to do.  As part of my training documentation, I have trainees sign the SOPs I've trained them over.

 

In response to your questions about specifics of storage and allergen separation, your site map is your friend.  In my allergen program I detail the allergens in our facility, how we control them, and the color code assigned to each allergen and it's dedicated equipment.  On my site map, I have all of the allergen specific storage locations marked.  I also have all of these locations clearly marked in my facility.  I have placards that describe the different allergen specific color-codes posted in various locations throughout my facility.

 

I find that being specific and detailed is extremely helpful in understanding and controlling the various aspects of my food safety system.  I also agree with Scampi's advice of not backing yourself into a corner, that is a line that you will have to find and define for your facility.

Edited by Spidey, 09 April 2021 - 03:08 PM.