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SQF CB raised Minor to Major 2 weeks after audit

SQF Major NC Pest Control

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goswamiripan

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Posted 13 September 2021 - 09:55 PM

Our facility was audited and we had 9 minor NC at the closing meeting. The draft of Corrective Action Report (CAR) was signed off by both parties, week after audit an official Corrective Action Report was sent to us by CB stating there has been 1 major and 9 minors identified after the technical review by CB. The 1 additional major was straight off incorrectly reported so we simply brought it to their attention and CB manager agreed to fix it in the portal understanding that it was their mistake. 

 

However following week, we receive another email this time from our auditor sharing copy of revised draft CA Report stating that there has been a change in non-conformities after technical review by CB. This time one of the minor has been raised to major. ugghh. 

 

Now about this minor - It that was for some live pest activity found in the warehouse full of green coffee beans during audit tour, the plant hazard analysis identifies the risk and mitigates it by pre-requisite programs and processes of the raw material downstream and this was understood to be a minor and not major at the end of the audit in agreement with the auditor. Because this raw material is a direct agricultural product coming in burlap bags and sometimes some pest (meal moths) are inherent to the burlap bags in warehouse.  

 

Need some advise on this situation and if we can dispute this change from minor to major. We'd need solid basis for this contest/dispute. Some advice from experts here is super highly appreciated!

 

 



Evans X.

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Posted 14 September 2021 - 07:58 AM

Greetings goswamiripan,

 

You should argue it a lot with the CB about this minor turned major. No matter how strict and robust your pest control is, when you get "live" raw material straight from the field you are bound to have insects, even with the pesticides or whatever practice your suppliers use. What's more, it isn't even your fault (if you can call it a fault at all) since that's how it is sent to you and since you have identified it and taken measures downstream it shouldn't even be a minor in my opinion.

It would be a N/C if the pests that were found during the audit were not inherent to the raw material (eg mice or spider webs on the building etc). Practice beats theory in this case hands down and your auditors showed a bit of a lack on it.

 

Bottom line argue the nature and origin of the raw material and the distinction between inherent/non-inherent pests and add there, again, the hazard identification pointing out the measures you have to prevent it from passing down to the end product.

 

And if they still want to stick with this, I would tell them something childish like "Ok, we will start using pesticides directly on the raw material during reception and you will not raise a N/C for chemical hazards on your next audit" or "We will employ a 100 people to check the beans one-by-one", because how else do you make a point about the obvious?

 

Hope it gets resolved soon,

Regards!



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TylerJones

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Posted 14 September 2021 - 12:25 PM

I would argue that Indian Meal Moths are inherently active in summer months in raw green beans. I am sure that you have pheromone traps set out to get a baseline of how active they are? Is this in your IPM program?  Can you post your IPM program on this forum? If so you can state your trends and customer complaints. Honestly this is a quality issue. Indian Meal months start off as eggs that you cannot detect even by visual inspection at receiving . They hatch into larva then morph into Meal Moths. Im employed at a coffee roaster, this is a bad call on the auditor- I'd be finding another CB for next year one that has done a coffee roaster in the past. I wouldn't go down the road of pesticide argument there are plenty of pesticides that you can use (VAP-8 fogger, phosphine gas both pills and pellets as well as pheromones that trick the males into not finding females thus reducing reproduction that are widely used). 


If you don't like change, you're going to like becoming irrelevant less. 


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Scampi

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Posted 14 September 2021 - 01:43 PM

I would argue the point with the CB as raw agricultural commodities always have inherent issues that processed ingredients do not.

 

This is the wrong call . Period---------------that's right up there like saying live chickens shouldn't have feces on their feet

 

You can also reach out to SQFI directly----I have done this in the past with great success.............they have a brand that needs protecting, if a CB has enough complaints, they lose their certification


Please stop referring to me as Sir/sirs


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goswamiripan

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Posted 23 September 2021 - 03:24 PM

Great points Evans X., TylerJones, Scampi. Thank you all. 

 

We submitted an appeal in regards to this minor to major change but it got denied...it's ridiculous!

 

Right before the audit, due to summer season moths rising we made all our suppliers fumigate their green coffee loads coming into our facility from their warehouse (which are also fumigated frequently) to prevent addition of moths in our warehouse. But like you all agreed it's super hard to have zero moth in any green coffee warehouse. With this appeal we also provided all evidences of the measure/corrective actions we have in place in addition to our mitigation plan per hazard analysis- in response to some green coffee loads that were rejected this summer due to super high moths findings at our receiving inspections. 

 

Now we've scheduled a call/meeting with the Technical Manager of the CB on Monday. Let's see how that goes. You'll added valid points, like them I'll use them on this call with CB. also I don't know if any denied appeal has ever been turn around. 

 

I'll also look into option to contact SQFI like Scampi mentioned. Hopefully we should have legit answers and resolutions, or else we don't really know what else can be done for an effective corrective action on this major. We've done all that could be done!  It's such a pain!  

 

Again thank you all.. I'll keep you all updated on the final outcome! 



goswamiripan

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Posted 23 September 2021 - 03:35 PM

I would argue that Indian Meal Moths are inherently active in summer months in raw green beans. I am sure that you have pheromone traps set out to get a baseline of how active they are? Is this in your IPM program?  Can you post your IPM program on this forum? If so you can state your trends and customer complaints. Honestly this is a quality issue. Indian Meal months start off as eggs that you cannot detect even by visual inspection at receiving . They hatch into larva then morph into Meal Moths. Im employed at a coffee roaster, this is a bad call on the auditor- I'd be finding another CB for next year one that has done a coffee roaster in the past. I wouldn't go down the road of pesticide argument there are plenty of pesticides that you can use (VAP-8 fogger, phosphine gas both pills and pellets as well as pheromones that trick the males into not finding females thus reducing reproduction that are widely used). 

We do have IPMS and per that program we have pheromone traps all over warehouse and we added few more prior to the audit, but they were added few weeks before the audit per PC service schedule so unfortunately they were found full .. again summer season isn't great in Texas.. BUT according to PC service schedule they were changed on the same day of the finding..so right on time when they should be. We also fired our pest control service provider recently due to other issues with them. 

 

I'll keep the trends and customer complaints records handy for our call with CB on Monday. I think that's a great call. Anything else can you think of to be added our list of defense? I'm glad to find out you're employed with coffee roasters, I'd appreciate to learn more from you in this same regards. 



goswamiripan

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Posted 23 September 2021 - 03:40 PM

I would argue the point with the CB as raw agricultural commodities always have inherent issues that processed ingredients do not.

 

This is the wrong call . Period---------------that's right up there like saying live chickens shouldn't have feces on their feet

 

You can also reach out to SQFI directly----I have done this in the past with great success.............they have a brand that needs protecting, if a CB has enough complaints, they lose their certification

I totally agree with you. Thank you. I planning to contact SQFI directly as well. Do you mind sharing some details on this contacting SQFI, which dept. or who (just the title) exactly were you able to discuss this issue with? It'll help our case I think. 



TylerJones

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Posted 23 September 2021 - 04:29 PM

This might sound a little crazy and backwards thinking but honestly the more pheromone traps you have the bigger headache you will have. We store thousands of burlap sacks of green coffee beans here at my facility. I know we are going to have a problem with humidity and temperature as we are a concrete building and everything is kept at ambient storage. Code calls out that you must trend these things so why make it difficult on yourself? I placed a pheromone trap at the receiving bay, one on a storage rack, one near production, and one at the shipping bay. All a pheromone trap tells you is that you have identified a pest, it is not a means to get rid of the pest. Keep your trap number down to a more manageable number. Also pheromone traps are bought over the counter with no license needed something you can do yourself. Do yourself a favor and write yourself into your IPM program as the person responsible for replacing / monitoring, keep a bunch on hand and I replaced mine the morning of the audit (can easily write frequency of replacing meets a certain threshold caught, not just for instance monthly). In this industry or any raw ag commodity you know there will be flying pests, just find a way to adapt to the code and fix in-house going forward. No bugs in traps = no questioning.  I've done this both at a rice facility and coffee facility, this one bug is the biggest waste of time and money!!!!!


If you don't like change, you're going to like becoming irrelevant less. 


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Scampi

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Posted 27 September 2021 - 04:42 PM

Leanne Chubbof is who i spoke with at SQFI, i just used the contact us button on the site

 

https://www.sqfi.com...ist-contact-us/


Please stop referring to me as Sir/sirs


SQFconsultant

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Posted 08 October 2021 - 10:52 AM

Somebody does not understand the definition of a major finding.

You must challenge this.

And then find a new cb - they are idiots!


Kind regards,
Glenn Oster
 
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