6 replies to this topic

[wbourg]

Hello,

So I am working on certification for my bakery. In our facility though, the company added its commissary for its fresh RTE foods. This confusing me as management doesn't want the fresh commissary certified. Is there any issues with this? Do you have any sources that will help me work through this? We have to store our raw materials near their products.

Thanks

[SQFconsultant]

There are situations where exenptions can be made, however you first need to define what you mean by commisary and how that section of the facilty effects the balance of the facility?

On surface I doubt that an exemption would be poasible but you would need to provide clarity as to exactly what you are askimg.

[Tony-C]

Hi wbourgeois,

 

 

Welcome to the IFSQN forums

 

Your request for exemption needs to be submitted to the certification body prior to the certification audit. Refer to SQF Food Safety Code: Food Manufacturing, Edition 9, A2: Steps to Achieving SQF Certification (steps 1 – 10).

 

See Step 3: Determine the Scope of Certification

Note: The scope of certification specifies:

The site. SQF certification is site specific. The entire site, including all premises, support buildings, silos, tanks, loading and unloading bays, and external grounds are identified and included in the scope of certification.

 

Food sector categories (FSCs). SQFI has a list of food sector categories to classify product groups and ensure that the auditor who audits your site has the requisite knowledge and skills. You want to apply for FSC 13: Bakery and Snack Food Processing

 

The products. SQF certification is product specific. Within each applicable food sector category, you need to identify the products (e.g., frozen peas) that are included in your SQF System. The manufacture of all listed products will be audited for compliance to SQF and will be listed on the certificate of compliance unless you request an exemption (refer to Part A 3.1).

 

See 3.1 Exemptions

If you wish to exempt any products processed or handled on-site or part of the premises, the request for exemption needs to be submitted to the certification body in writing prior to the certification audit, detailing the reason for exemption.

If approved by the certification body, exemptions are listed in the site description in the SQFI assessment database and in audit reports. However, all parts of the premises and processes that are involved with the production, processing, and storage of products included in the scope cannot be exempted.

 

I think it would pay to discuss this with a suitable certification body now.

 

Kind regards,

Tony

[wbourg]

There are situations where exenptions can be made, however you first need to define what you mean by commisary and how that section of the facilty effects the balance of the facility?

On surface I doubt that an exemption would be poasible but you would need to provide clarity as to exactly what you are askimg.

 

We supply donuts to around 200 of the same named convenience stores and gas station throughout our region. The commissary provides milk, eggs, juice, sour cream, etc. to the same stores. In the scope of our business we are simply "selling" the commissary our donuts and they are transporting to the stores. The commissary and bakery are separate entities in our business and we do not share anything besides being in the same building. The higher management does not want  retail SQF certified, but we share the same site.... which makes it a weird gray area. They were located at a different SQF site previously but were just moved here last week and started operations. 

Thank you for your time. 

[wbourg]

Hi wbourgeois,

 

 

Welcome to the IFSQN forums

 

Your request for exemption needs to be submitted to the certification body prior to the certification audit. Refer to SQF Food Safety Code: Food Manufacturing, Edition 9, A2: Steps to Achieving SQF Certification (steps 1 – 10).

 

See Step 3: Determine the Scope of Certification

Note: The scope of certification specifies:

The site. SQF certification is site specific. The entire site, including all premises, support buildings, silos, tanks, loading and unloading bays, and external grounds are identified and included in the scope of certification.

 

Food sector categories (FSCs). SQFI has a list of food sector categories to classify product groups and ensure that the auditor who audits your site has the requisite knowledge and skills. You want to apply for FSC 13: Bakery and Snack Food Processing

 

The products. SQF certification is product specific. Within each applicable food sector category, you need to identify the products (e.g., frozen peas) that are included in your SQF System. The manufacture of all listed products will be audited for compliance to SQF and will be listed on the certificate of compliance unless you request an exemption (refer to Part A 3.1).

 

See 3.1 Exemptions

If you wish to exempt any products processed or handled on-site or part of the premises, the request for exemption needs to be submitted to the certification body in writing prior to the certification audit, detailing the reason for exemption.

If approved by the certification body, exemptions are listed in the site description in the SQFI assessment database and in audit reports. However, all parts of the premises and processes that are involved with the production, processing, and storage of products included in the scope cannot be exempted.

 

I think it would pay to discuss this with a suitable certification body now.

 

Kind regards,

Tony

 

 

This is what I keep telling upper management. They are refusing to agree and are saying not to worry about it. I just don't feel like having this blow up in my face when we try and get certified for the first time. 

Thanks. 

[SQFconsultant]

Well now, there is a sticky wicket of issues.

Let mw assume for a moment - the customers of the comnissary not only get their donuts from them but other items as well.

I must assume the reason you are going for an SQF cert is because the chain wanrs your company and "donuts" certified.

Does the chain of stores also get items outside of your donuts?

If in fact that is the case then it is the commisary concern that would need to be ceetified SQF and your donut operation would be an approved supplier to the commisary and thus would need to have a robust FSMS in place that is 3rd party audited or an SQF certication to satisfy the requirements of the comnissary operation under their approved supplier program.

With that said I doubt highly that the end customer only wants donuts in the scope of the certification but wants all products received in that scope.

Bottom line - you have a food mfg and a dustribution center under 1 roof, regardless of separate entity or not you get a choice - get both certified as separate entities or get 1 certification thw covers ALL the products that the end customer is provided.

I doubt highly that you would be able to get an exemption as we have a client that had the same kibd of set up and what happened is that the end customer of ALL products wanted the scope to cover not just the pies that they get but also the coffee, milk, cream, sugar, canned goods, etc they receive.

Now in our client's facility the DC under the same roof but operated by a contracted entity actually accounts for about 30% of the overall business thus there was just 1 certification that covers both areas and the scope includes all products.

If you were to go to the store chain that asked that the company be certified ans ask them what products they wanted in the scope of the certification the answer would be everything that comes from you.

And that is exactly what happened last year to another client of ours that was convinced they could do a separation and only put their main product under the scope.

We made the call together and the buyers response was - we want ALL the items we get from you to be included.

Most end customers do not have blinders on and want everything they purchase to be on the scope.

Try that out (without explaining the sep entity thing - thats just un-needed confusion) and see what they say.

[jfrey123]

It's possible, but it gets sticky.

 

One of the first companies I worked QA for was a small, family run outfit with multiple buildings/operations, a few that were not SQF or food related.  One operation was a dry steam sterilization/pasteurization operation for dry goods and spices.  All SQF operations were performed in a walled off area of their warehouse, and the rest of the warehouse was storage for other business (third party storage/distribution of many non-food items).  The non-food areas were well designated and mapped out as separate from the food business, only sharing the dock doors and a travel lane for loading/unloading.  I successfully defended the program multiple years, though it did raise eyebrows each time.  Having to walk your auditor past pool cleaning chemicals, flammable agents, toys, all just to check rodent traps at the rear mandoors always led to fun side conversations.

 

I envision you would need to create designated zones where non-SQF activities are performed/goods are stored.  You'll need to map these out, create physical barriers, and your PRP's will need to reflect there is never to be comingling between these areas.  Being as your non-SQF area is still food product, it will need to be crystal clear to your customers that those items are not produced or stored under your SQF certification.  Your auditor will likely still want to walk the area, and the moment he finds SQF product stored there, or finds non-SQF "overflow" in your raw material area, you will take a major finding.