SQF 2.1.2.1 - Failed FSO... Now what?
Hi again, seeking guidance from the folks on SQF practices. I've never had a company fail a food safety objective, so this will be my first time helping to determine the best course of action.
I'm at a corporate level FSQA position, and our plants across the country all share the same FSO's, installed by a VP. The FSO in question is Successfully pass all second or third party audits with a 90% score or better in year 2022. One of our plants just scored an 87 on their SQF audit, therefore they have failed this FSO. If it matters for information purposes, the FSO is also mentioned as a corporate FSO regarding all plants (so not only a plant objective, but a corporate objective as well).
SQF 2.1.2.1 iii. only seems to list FSO's and performance measures as something for senior management to review annually, but I'm not seeing any specific instruction on how to handle a failed FSO. We've currently used our published monthly food safety reports to indicate the FSO is under review, all others have been met to date.
How have you handled a failure to meet FSO's in your plants in the past? I'm of the belief we should document it on one of our corrective action forms, with a root cause investigation and a corrective action to monitor through 2023. Any help would be appreciated.
I'm of the belief we should document it on one of our corrective action forms, with a root cause investigation and a corrective action to monitor through 2023. Any help would be appreciated.
Hi jfrey123,
I would tend to agree with you.
An analysis of the deficiencies that led to the score below the target should lead you to your proposed corrective actions.
It may also lead you to looking at the internal audit system and determining why the deficiencies weren’t detected internally before the SQF audit.
Kind regards,
Tony
I would raise it as a non-conformance and then conduct an investigation with root cause analysis. Then determine the corrective action you need to make and ensure that the corrective action is implemented in a timely manner and then monitored going forward.
I agree with both above
Reminder: these are OBJECTIVES not mandatory requirements
Your job now to to A) uncover the root cause and B) implement steps to prevent reoccurrence
A food safety objective should not be treated any differently than your other objectives. If there was a plant objective to decrease downtime by 10% and it was not met - what would you do? Just say oh well, we'll try again next year?
If you look at 2.1.1.2. The Food Safety Objectives are a form of accountability for senior management - in your case both at the plant and corporate. So yes, you will need to do the things you mentioned above in regard to corrective actions - but at the same time you should all take that hit come review season because you did not meet that goal/objective you set for yourselves.
It really comes down to the reasons for all the minors you received - but at the end of the day if that facility is lacking in accountable food safety culture then they are going to continue to think its ok that they still passed the audit with an 87 and there were not consequences for not getting the 90. Goals and objectives are set to better yourselves as employees and as an organization as a whole. So if you are not trying to coach managers, find gaps in programs, areas to spend your capital on - then what was the point of that objective?
_______________________________________________
Thanks for the input everyone. I've begun an investigation and submitted it to our FSQA team to expand upon.
Thanks for the input everyone. I've begun an investigation and submitted it to our FSQA team to expand upon.
Hi jfrey,
Is/was 87 (or 93 for that matter) significantly different to 90 ? ie where were the 3 points lost ?
IMO, the Ma/Mi/Se scoring system can be more "FS-meaningful" although "A+" maybe looks less impressive than "100".
Hey Charles, I'm unfamiliar with the Ma/Mi/Se system you mentioned. Can I ask for a link to check into it?
Truth be told, the 87 was a blessing as the auditor put a critical on our report and we successfully challenged it to a major. Majority of the findings were really stupid ones the QA Manager should have been on top of: the form for a PAA wash CCP stated different critical limits from the HACCP program, overgrown weeds across the parking lot, internal audit checklists not fully marked, mislabeled/unlabeled allergens in allergen area, unlabeled bucket carrying unidentified cleaning solution, etc. The kind of findings that drive you nuts as there's no excuse for them to have been missed.
In review of their CAPA items, I've discovered this plant makes more findings based on "observation/walkthrough" than they do versus internal audit checklists. It's suggesting to me that the internal audit program needs to be revisited at this plant (and likely our others) to ensure the internal auditing is effective at enforcing not just our programs, but adhering to the SQF codes.
Hey Charles, I'm unfamiliar with the Ma/Mi/Se system you mentioned. Can I ask for a link to check into it?
Truth be told, the 87 was a blessing as the auditor put a critical on our report and we successfully challenged it to a major. Majority of the findings were really stupid ones the QA Manager should have been on top of: the form for a PAA wash CCP stated different critical limits from the HACCP program, overgrown weeds across the parking lot, internal audit checklists not fully marked, mislabeled/unlabeled allergens in allergen area, unlabeled bucket carrying unidentified cleaning solution, etc. The kind of findings that drive you nuts as there's no excuse for them to have been missed.
In review of their CAPA items, I've discovered this plant makes more findings based on "observation/walkthrough" than they do versus internal audit checklists. It's suggesting to me that the internal audit program needs to be revisited at this plant (and likely our others) to ensure the internal auditing is effective at enforcing not just our programs, but adhering to the SQF codes.
Hi jfrey,
I was (mentally) comparing SQF to BRC (see attached BRC8) which also utilises a Minor/Major/Critical defect basis but in, I think, a more transparent (and discriminating) style with respect to "seriousness of defect". For example, can compare the Audit result due a finding of 1 - 3 Major defects respectively in the 2 systems.
BRC audit rating.PNG 87.83KB 0 downloads
(Offhand, one might suggest that the BRC System is more "punitive" but this assumes equivalence in the auditors and defect Categories which may / may not be entirely accurate in Practice).
(Some other Systems also include "Serious" in a BRC-type format which enables further delineations, a bit like 5x5 Risk matrices in HACCP)