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SQF 2.3.3.3 - Third Party Storage and Distribution

Distribution SQF 9.0 Contracted Services Warehousing Frozen Warehouse Storage

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Xoinks

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Posted 13 July 2021 - 08:15 PM

We are working through the new requirements for 3rd party storage and Distribution Businesses, and I'm stuck on one part. 

2.3.3.2 - "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".  

2.3.3.3  Contractural agreements with third party storage and distribution business shall inculde requirements relating to customer product requirements and compliance with clause 2.3.3.2. of the SQF Food Safety Code: Contractual agreements.  The site shall verify compliance with the SQF Code and ensure that customer and regulatory requirements are being met at all times.

 

We have our staff at our portion of our main frozen warehouse, which we rent from the owner of the property that runs a multi-site warehouse operation.  (We consider it a contracted service and up until 8.1 handled it that way with an audit required). This warehouse gets an audit that meets the requirements of ISO 9001:2015, FDA GMPs, and FDA HAACP and there's no way they are willing to get some kind of GFSI audit.  Thankfully our product is low risk (we freeze for quality, it's shelf stable bakery) - so we should fall under "Requiring that they meet the requirements of the SQF food safety codes" without needing an audit.  This has me scratching my head. At a high level, I can understand major programs.  Pest Control, Building Maintenance.   But - getting into details - for example, they aren't going to have an SQF practitioner (Why would they if they're not SQF?), etc. Any thoughts on how I can go about this?  Switching warehouses is not an option - we have a mailorder operation that we run out of there as well, so it's tough finding a frozen space (especially in one that's GFSI), close enough to drive to daily, with a lot of dead room to bring our crews in.  The warehouse is well run, Food Defense solid, well maintained - so I don't have a food safety concern.  The code seems to basically say "They need to be SQF compliant" even if they're low risk, but we just have to verify that they meet the requirements. I'm considering having them fill out a survey hitting the main requirements at a high level.  Records, Food Safety Plan, etc, and leaving out the nitty gritty (like the SQF practitioner).  Maybe backing it up with a risk assessment acknowledging they aren't GFSI and otherwise hoping they look at our other places out of state that are GFSI. Thanks for anyone who made it through my wall of text! 



Evans X.

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Posted 14 July 2021 - 08:12 AM

Greetings Xoink,

 

Your solution sounds solid. Audit them against SQF or other GFSI standard accompanied with the risk assessment and even a mention in your Annual Review that you have searched for other 3rd party storages and they too are not certified against the above mentioned standards and/or other reasons that you prefer the current one.

Also other GFSI standards don't require a practitioner, so prepare a solid "GFSI" audit questionnaire and focus on the main things that revolve around food safety/ PRP/ management/ food defense/ food fraud etc.

Your auditing is actually a 2nd party audit and the goal is to prove they are compliant with your requirements as set in your SQF, so having as an example the SQF practitioner, you won't be asking for the same thing from them but you could ask for the credentials of their Quality Manager (is his background relevant? does he have any HACCP or other recognized training? does he have experience on Safety-Quality positions? etc)

 

In my experience I have never seen an auditor not accepting a, let's say, "deviation" if you can provide solid proof, backup documentation and reasoning for your choice.

 

Maybe other SQF guru's can provide more insight, but until then, hope this helps!







Also tagged with one or more of these keywords: Distribution, SQF 9.0, Contracted Services, Warehousing, Frozen Warehouse, Storage

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