Employment requirement for SQF Practitioner ?

Hello all,

In edition 8 for SQF packaging, I noticed that it asked for the SQG practitioner to be on a full-time employment with the site.

In edition 9, I saw that it only states that this role need to be employed by the site.

I looked deeper into this in old posts and I am getting a common answer and that it is not needed for the practitioner to be on site at all times, just someone to oversee the program.

However, I am on the SQF site and it says "Be employed by the site as a company employee on a full-time basis".

My questions is, what is the requirement for this role in terms of employment status?

Any information would be helpful! Thank you.

Here is the section from Food Safety Code: Manufacture of Food Packaging Edition 9 with the specific requirements:

 

Here is the section from Food Safety Code: Manufacture of Food Packaging Edition 9 with the specific requirements:

 

"2.1.1.5 The primary and substitute SQF practitioner shall:

i. Be employed by the site;

ii. Hold a position of responsibility in relation to the management of the site’s SQF System;

iii. Have completed a HACCP training course;

iv. Be competent to implement and maintain HACCP-based food safety plans; and

v. Have an understanding of the SQF Food Safety Code: Manufacture of Food Packaging and

the requirements to implement and maintain an SQF System relevant to the site’s scope of

certification."

 

 

No where in the code (searched Practitioner throughout) does it say full-time. I think "employed by the site" could be interpreted to mean one per site but I don't think that's what it is actually indicating and I have heard of packaging companies with multiple sites but one practitioner being audited to Ed 9 and not looked at as suspect. In fact one is a manufacturer with two buildings about 100 yards (91.44 meters), separate properties so different "sites" with one Practitioner. We have 3 sites, one manufacturing and two finished goods / shipping buildings and I am one of two Practitioners (myself and a backup).

 

Exactly. They changed the wording on this but I did not want to assume. However, does that part time employee need to be at the actual audit? If that employee does not work during the time of the unannounced audit, then how would that work? Would the back up practitioner do all the talking? 

Exactly. They changed the wording on this but I did not want to assume. However, does that part time employee need to be at the actual audit? If that employee does not work during the time of the unannounced audit, then how would that work? Would the back up practitioner do all the talking? 

I think if you know the part time employee's schedule, you would block out any dates they would not be on site or make sure the back up is present during those times.

SQF Guidance Document might be helpful here:

https://www.sqfi.com...ce-Document.pdf

"The role of the SQF practitioner is to represent senior site management and ensure the SQF system is working and effective 24/7."  If your site can demonstrate the practitioner is able to ensure the program is working and effective 24/7 in a non-full time position, then you may satisfy the requirement.