26 replies to this topic

[karlieh]

Does anyone have any suggestions on how to properly write an exemption for the SQF Food Safety Code: Manufacture of Food Packaging edition 9.0?

I need to exempt all non food grade related products/materials, and I am unsure of the proper way to write it into our program, that will be acceptable for the audit.

[Setanta]

Are these products used in any way on your food items?

What use do they provide?

[karlieh]

Are these products used in any way on your food items?

What use do they provide?

 

No, our non food grade products and materials are used in no way on our food safe items. 

We sell labels, and we have food grade and non food grade labels. And only the food grade stock and materials is what will be audited, and I need to exempt all of our non food grade products/materials.

[sqflady]

Personally, I wouldn't exclude the non-food contact items.  Regardless if you include or exclude, you need to include in your programs how you prevent contamination between non-food contact and food contact.  

[SQFconsultant]

You do not need to write exemption requests nor put anyrhing into writing for the audit.

Understand that your entire facilty will be insoected even if you did have extentions in place.

Auditors fully understand that packaging conpanies do duel manufacturing and when you sign uo for a CB you just tell them you also make non contact label as well

[SQFconsultant]

In addition with the CB when they ask what the inclusions and not included items are for the scope of certification you would indicate food contact/grade etc labels.

They will ask what items witll be exempted but that is it.

[queenb]

We just completed our Audit a week ago and our plant is the same. Very minor food contact production (15%) and the balance non-food contact. I have never requested an exemption on the non-food contact portion even though our program is based on the food contact  The first three audits concentrated on the food contact portion, but this year the Auditor seemed more interested in the non-food contact portion and that is where we received 6 of our 8 non-conformances. He also commented that the non-food contact portion of production should be sanitized, smocked and hair/beard netted the same as the food contact employees even though the food contact production is cordoned off and not accessible to any other production worker than those dressed and sanitized. I'm also considering an exemption on the non-food contact portion of production. 

[TimG]

Why the heck would he/she say your non-food contact portion should be sanitized, smocked and hair/beard nets? I guess I don't understand what the risk is? I seem to recall SQF being big on doing accurate risk assessments, so that seems a bit contradictory.

[queenb]

TimG

 

My thoughts exactly. Sadly Auditor seemed to want to finish off Audit Day 2 with as big a bang as possible by nit-picking any area he could. I feel a lot of the "suggestions" were unnecessary and unfounded but it gives us a bit of a scare for our next years "unannounced". Don't know if they can send the same Auditor three years in a row.  Fingers crossed they can't.

[TimG]

Were any of the NC's against written policy? Do you have it written in a PnP that the food grade line will follow a different set of policy/procedure than the non-food grade process line? 

[queenb]

I would say for sure one NC was but some more knowledgeable might disagree with me. 13.2.5.1 was some dust on a shelf by a digital press on the other side of the building not contained within the cordoned off food contact press area. I know that dust in one spot probably means that you're not following a rigid enough cleaning protocol but he seemed to spend more time in the non-food contact production areas than the food contact area. Six of our 8 NC's were all from the QM 13. section of our program.

[Scampi]

I would argue back with the certifying body. This is utter nonsense, you should not have been issued any NC on the non food grade end of things UNLESS those impacted your food grade

 

As for "suggestions" auditors are not to make suggestions, it opens them up to legal wrangling

 

Sounds like the audit was trying to justify 2 full audit days when one would have been sufficient

 

We make food and our SQF is 2 days.......something smells fishy

[TimG]

Ok, I 100% agree with Scampi. I actually started typing something similar, but backspaced it all because I haven't run an SQF certified facility in 6+ years so I didn't want to steer you wrong if there was something in the new codes that I wasn't familiar with.

[queenb]

That is sort of how I was feeling it at the end also. First day was about how far behind we were in conducting the Audit on the system elements (10 full hours, no lunch break!), than day 2 was quickly review GMPs and a lot of walking around for the 4 hours writing NC's. His hour of report writing started at 1:30 and he was out the door with closing meeting done at 3. I have appealed that NC and a consumer purchasable mouse bait we monitor that we were told we had to have a license to use. Our governing body (Provincial Minister) confirms consumer purchasable product, no license needed. Sure hope we don't get him next year.

[Ana_B]

TimG

 

My thoughts exactly. Sadly Auditor seemed to want to finish off Audit Day 2 with as big a bang as possible by nit-picking any area he could. I feel a lot of the "suggestions" were unnecessary and unfounded but it gives us a bit of a scare for our next years "unannounced". Don't know if they can send the same Auditor three years in a row.  Fingers crossed they can't.

 

I'm sorry to tell you this but yes, they can. In fact they can audit you three years in a row, the fourth you will have a different auditor and it is possible that the fifth you will have the initial auditor again. Is what happens to us...

[queenb]

UPDATE:  We have been informed that the same Auditor from two previous years will do our Unannounced Audit this year. I have prepared a Risk Assessment and Traffic Flow Risk Floor Plan.

 

Is the consensus, from those more knowledgeable, that I do not need to send this Risk Assessment and Floor Plan into CB to request a formal "exemption" on the non-food contact area?

 

Any advise is welcomed.

[Scotty_SQF]

You can ask for a different auditor.  It is in your right if you did not like the way the auditor conducted himself.  I have done it before.  No need to go into detail with the CB just tell them that you are requesting a different auditor.  Just wanted to throw that out there as I feel many people do not realize you are allowed to do that.

[queenb]

Scotty_SQF, thank you for the information. So I would just contact my Coordinator at the CB and request a change of Auditor and wait for the confirmation. That will take a lot of stress out of our workplace for sure.

[Scampi]

It is in everyone's best interests that the auditors do not repeated go back to the same facility year/year

 

queenb-who is your CB currently?

[queenb]

Scampi, our CB is NSF. We are in Canada also so I think we are limited on Auditors for Packaging but I will contact them today and request a different Auditor.

[Scampi]

This may help

https://www.exemplar...rchregister.php

 

It will at least allow you to be informed prior to contacting NSF

 

 

That's also our CB and there are only 3 certified auditors for our food type, but we do cycle through the 3 and never the same back to back

[sqfnewbie]

Can you request a specific Auditor if you are requesting a new one for your facility? Or do they not allow that?

[Scampi]

No, I don't believe they will let you do that.  

 

That form will allow you to see just how many auditors in Canada there are that can audit you-----it's not your problem if your say in Gander and 2 of the auditors live in Red Deer as an example

[queenb]

Scotty_SQF and Scampi thank you for the valuable information. I requested a different Auditor and was given one. It is a feeling of relief for sure.

[Scampi]

Fantastic result!!