30 replies to this topic

[majoy]

Are they going to update the manual, or this is just to clarify the clauses affected?

 

Most of the amendments are effective Aug 1st and Aug 16th, I checked the SQF download site monthly but did not found these amendments on Aug 2nd or missed it as it was on the bottom and not even highlighted (a bit sneaky).

 

 

[jalex194021]

Here they are.

 

 

 

 

 

Attached Files

•  Code-amendment-summary-1 (2).xlsx   12.83KB   267 downloads

Edited by jalex194021, 16 September 2021 - 03:59 PM.

[ESuttmiller]

Thank you. 

 

After seeing this and forwarding it to some higher ups, I'm able to justify a change I have been wanting to make for a few months. Now I won't have any arguements.

[Scampi]

Ok- super confused here

 

Where exactly did this list of amendments come from???  can you paste a link?

 

This is the most recent item i can find regarding the issue date, and is written by Leanne Chubboff at SQF and there is no discussion of these "amendments"

https://blog.safetyc...-code-edition-9

 

When i compare the code 8.1 against 9 I am not seeing these "amendments"  

For example from the code re: approved suppliers ---------- no mention of "approving" emergency suppliers, just that you should verify the materials

2.3.4 Approved Supplier Program (Mandatory) 2.3.4.1 The responsibility and procedure for selecting, evaluating, approving, and monitoring an approved supplier shall be documented and implemented.
A current record of approved suppliers, receiving inspections, and supplier audits shall be maintained. 2.3.4.2 The approved supplier program shall be based on the past performance of a supplier and the risk level of the raw materials, ingredients, processing aids, packaging, and services supplied, and shall contain at a minimum:
i. Agreed specifications (refer to 2.3.2);
ii. Reference to the level of risk applied to raw materials, ingredients, packaging, and services from the approved supplier;
iii. A summary of the food safety controls implemented by the approved supplier;
iv. Methods for granting approved supplier status;
v. Methods and frequency of monitoring approved suppliers;
vi. Details of the certificates of conformance, if required; and
vii. Methods and frequency of reviewing approved supplier performance and status. 2.3.4.3 Verification of raw materials shall include certificates of conformance, certificates of analysis, or sampling, and testing. The verification frequency shall be identified by the site. 2.3.4.4 The receipt of raw materials, ingredients, processing aids, and packaging from nonapproved suppliers shall be acceptable only in an emergency situation and provided a receiving inspection or analysis is conducted and recorded before use. 2.3.4.5 Raw materials, ingredients, and packaging received from other sites under the same corporate ownership shall be subject to the same specification requirements (refer to 2.3.2), approved supplier requirements, and receiving inspections as all other material providers. 2.3.4.6 Supplier audits shall be based on risk (as determined in 2.3.4.2) and shall be conducted by individuals knowledgeable of applicable regulatory and food safety requirements and trained in auditing techniques. 

 

 

Need a link to SQF or it didn't happen

[ESuttmiller]

Scampi, I got you.  See below:

 

https://www.sqfi.com...ode-amendments/

[TylerJones]

SQF is turning into BRC.... I guess I can write up my policy to have ALL visitors submit a negative COVID test 72 hrs prior to being at the plant, thus negating a unannounced audit. 

[Scampi]

Thank you for posting the link!!!!!!!

 

What a schmoggle-----------um how many of you know who your emergency suppliers are? Come on-----back ups, sure, approved, you bet. but emergency??????

 

Money grab and nothing else

[Setanta]

Such garbage.

I am signed up for their emails, but all I get are sales on training that isn't appropriate. 

[TimG]

Thank you for posting the link!!!!!!!

 

What a schmoggle-----------um how many of you know who your emergency suppliers are? Come on-----back ups, sure, approved, you bet. but emergency??????

 

Money grab and nothing else

 All approved and emergency suppliers shall be registered.

 

I think just registering the emergency supplier at the time of purchase would be sufficient, wouldn't it?

So for ex. primary supplier (already registered) is down for covid outbreak, back-up (already registered) is swamped because they are filling the shoes of the primary for 30 other plants and your ToT isn't acceptable, you find an emergency supplier, run your emergency back-up supplier program approval, register them (toss em on your approved supplier register and get the approved receiving docs updated or whatever other hoops you need to jump through), and you should be golden.

At least that's my interpretation. It kind of sounds like they are trying to close the loophole of people using 'emergency' suppliers while not running them through their approved supplier program and registering/documenting them like they would any other supplier.

[Scampi]

I object to the amendments wholeheartedly (and already cover all of them--we can't have emergency suppliers in my commodity)

 

Then allegedly spend months and months nitpicking the code prior to release.............only to turn around and amend

 

As soon as retailers got involved in food safety it's been a rapidly downword spiral, and no appreciable reduction in recalls see link http://blog.globalfo...mber-of-recalls

 

If these "schemes" worked, there would be a direct reduction............instead they revise the code in ridiculous ways, and the bad actors still pass and still infect consumers 

 

End rant

[ESuttmiller]

TimG hit the nail on the head regarding the suppliers (thats what my thoughts were too). The medical thing seems to be a more specific requirement enacted due to COVID-19. Simple enough to adjust to. 

 

I know whom my primary, backup and in some cases, secondary backup are on critical items. Only thing I needed (and its already done) was to add the phone number of the location on the register associated with my ASP documentation. (unhide a column on the spreadsheet). 

[majoy]

OMG you guys made my day! I almost had a heart attack when i saw the amendment!

 

They should've highlighted this amendment on their email blast! and not snuck it into some page of their website. Really terrible.

[sqflady]

Unbelievable!  I also was unaware.  Thank you for sharing this.  SQFI needs to be more upfront with these types of changes.  Why has this not been included in the e-mail blasts?  I agree with Scampi - money grab and nothing else.  The bad actors still pass the audit because ultimately they are paying the CB.

[queenb]

So am I understanding the Code Amendment #1 correctly?

I need to have any and all of my team who handle our food contact labels do a medical screening. Can this be an internally created form asking them medical questions?

Edited by queenb, 22 September 2021 - 06:32 PM.

[TimG]

'Medical screening' is pretty broad in my opinion. Heck, most places (at least here in the USA) already do this upon new hire. Has anyone found anything in the code for what to 'screen' for? Do they give a definition of 'medical screening.'

[Spidey]

So am I understanding the Code Amendment #1 correctly?

I need to have any and all of my team who handle our food contact labels do a medical screening. Can this be an internally created form asking them medical questions?

 

I've read where some people implemented questionnaires as a COVID screening technique, I think that is an effective method for medical screening.

 

My facility has taken a slightly different approach.  In April 2020, we started taking employee temperatures as a way to screen for COVID.  You get sent home if your temperature is at or above 100.0'F.  This started out as a voluntary action and then became required by my state 2 months later.  We've never stopped taking temperatures of employees and visitors.  Since this system was developed for the express purpose of medical screening, I'm going to use that program to show compliance with the code.  We also train employees to stay home if they are sick or have been exposed to a communicable disease.

[queenb]

Good question Tim. We do have a standard form that we "screen" visitors, out of town service techs, etc. but other than the standard: Any signs of sickness (pretty broad!), Cold, Runny nose, Diarrhea for our employees who are working on food contact labels we don't ask any further. Employee answers are not recorded on a form. It is a written rule than no one who shows signs of sickness can work on this production line, in fact, they volunteer this information before work. I'm not sure we can ask about a COVID test or vaccine!

[Scampi]

queenB, your facility ,your rules  PARTICULARLY visitors

 

our visitor policy asks if they are a known carrier of communicable diseases  AND the usual COVID related questions. 

 

If you do not want any outside people without a double vax or a negative test within XX hours, you are within your right to do so, its a private establishment

 

As for your employees, you can request that they voluntarily submit vaccine status       We have daily screening that is recorded (protects the company and proves the duty to protect). 

[TimG]

OK, is there anything saying this 'medical screening' is COVID related, or is that just assumed or implied in there and I missed that? 

[queenb]

I just re-read it and there is no specific reference to COVID-19. The Benchmark requirements reference (industry sections BIII, C0, Cl-CIV, D, G, I and K). Not sure what they are about.

[Scampi]

No, no reference to covid 19----but there has always been a sort of medical evaluation required anyway, so why amend the code?

 

Personnel who are known to be carriers of infectious diseases that present a health risk to others through the packing or storage processes shall not engage in the processing or packing of food or enter storage areas where food is exposed. The site shall have measures in place to prevent contact of materials, ingredients, food packaging, food, or food contact surfaces from any bodily fluids, open wounds, coughing, sneezing, spitting, or any other means.
In the event of an injury that causes the spillage of bodily fluid, a properly trained staff member shall ensure that all affected areas, including handling and processing areas, have been adequately cleaned, and that all materials and products have been quarantined and/or disposed of. Personnel with exposed cuts, sores, or lesions shall not engage in handling or processing exposed products or handling primary (food contact) packaging or touching food contact surfaces. Minor cuts or abrasions on exposed parts of the body shall be covered with a colored, metal-detectable bandage or an alternative suitable waterproof and colored dressing.

[queenb]

Scampi do you record that you have asked these questions/made observations, etc. as a pre-operational check or are you just doing it verbally. That's my concern. We ask our employees before start of shift and it is only recorded on one pre-operational document that they have none of the symptoms.

 

I hope we do not every have to ask the COVID test questions! I find it's such a controversial subject in most workplaces.

[Scampi]

We have a mandatory text that arrives everyday, it is a link to a browser page that you must complete. The company receives email for those you do not complete it

 

We also have paper copies available      AND we have temperature/mask  monitoring before you're allowed in the building (it's tied to the turnstiles)

 

Voluntary disclosure of vaccine status is where we are at, that goes directly to human resources though

[TimG]

Right, I guess that's what I'm getting at Scampi. What was the amendment addressing? It already has its version of FDA cGMP 21 CFR Part 110.10  Personnel Disease that you linked, what more is it asking?

 

Maybe it's just that it includes visitors and contractors who handle exposed product or food contact surfaces.

Previously it could be assumed it was just employees? I've always assumed it was anyone that handles or is in close proximity to the food, period. In my facility that would not include the typical visitor, they don't go near exposed product...

[Spidey]

 

 

SQFI recently had their GFSI review, and there were 4 areas identified where the SQF Code Edition 9 did not match the intent to the GFSI requirement.

 

This is likely why SQF is awkwardly publishing requirements out of synch of the new Code Editions.  It's also likely why SQF is starting to sound more like BRC.