Backup SQF Practitioner Question
Does the Backup SQF practitioner also have to be a PCQI?
Does the Backup SQF practitioner also have to be a PCQI?
PCQI is a FSMA requirement, not an SQF requirement. SQF requires that the back-up practitioner have HACCP training and appropriate training to understand the applicable code and how it applies to your specific operation. It does not require PCQI training. That being said, it's not a bad idea to also have a back-up PCQI.
As per new edition HACCP training is mandatory, PCQI certification is also good to have but as per below mentioned clause, HACCP is mandatory:
page 13 of Part A (Manufacturing code): SQF practitioners are required to successfully complete HACCP training that is a minimum
Does the online HACCP training acceptable for SQF practitioner back up?
From the edition 9 guidance
"On occasions where the primary SQF practitioner is on extended absence due to vacation, training or illness, the substitute practitioner takes responsibility for the daily operation of the SQF System. The substitute practitioner is required to have the same qualifications as the primary practitioner and have a close working knowledge of the site’s SQF System."
^ Spidey here is spot on! PCQI is not necessary for the back-up SQF practitioner.
From the edition 9 guidance
"On occasions where the primary SQF practitioner is on extended absence due to vacation, training or illness, the substitute practitioner takes responsibility for the daily operation of the SQF System. The substitute practitioner is required to have the same qualifications as the primary practitioner and have a close working knowledge of the site’s SQF System."
Is it yes or no? The SQF Practitioner and back up have been completed the ONLINE HACCP training. is it acceptable? as the requirement is a minimum two-day duration.
Thanks,
Neda
Good morning Tresa! It's a bit confusing since we're crossing two different standards (FDA/FSMA and SQF). SQF will require that you follow the FSMA standard (or any governmental food standard depending on country). So your research should be with the FSMA requirements on this one (PCQI is a FSMA thing). Here are a few quotes from the FAQ for FSMA:
If no exemptions apply to you, then you are required to have a PCQI develop and implement your facility’s food safety plan...
..In general, FDA will assess the adequacy of a facility’s food safety plan rather than an individual’s documented qualifications. Deficiencies in the food safety plan indicate that a PCQI may need additional training specific to the rule, irrespective of documented training and experience. https://www.fda.gov/...te by FDA or be
I would think an SQF auditor would be hard pressed to give you a finding if your back up SQF practitioner does not hold a formal PCQI certification, as even the FDA doesn't require that.
HOWEVER, two things to take into consideration:
- Your SQF auditor might interpret The substitute practitioner is required to have the same qualifications as the primary practitioner as they need to have the exact same certifications (I don't think this would be hard to push up to the CB and have overturned)
- If your own policy/procedure lists certification requirements your SQF practitioner has to have and then says the backup shall hold the same certs, you've just hung yourself by not doing what you say you do
So the answer comes down to your interpretation. For me, my backup got PCQI training for animal and I already had it for human food(we produce both at this plant). Eventually, I want to get the animal PCQI class under my belt, but my backup having it satisfies our requirement for SFSF (a feed standard) as well as the FDA and my PCQI class works for our food grade standards.
The SQF auditor has ZERO right to ask about a back up PCQI person and/or whether or not you have one, that is a REGULATORY requirement
Do not confuse the 2