5 replies to this topic

[MaximeL]

Hi, I have 2 questions for co-manufacturers (external plants making products for a SQF entity).

 

 

2.3.3.2 The site shall establish a method to determine the food safety risk level of contract manufactured product and shall document the risk. The site shall ensure that:

 

i. Products and processes of co-manufacturers that are considered high-risk have undergone an audit by the site or third-party agency to confirm compliance with the SQF Food Safety Code: Food Manufacturing and regulatory and customer requirements;

 

ii. Products and processes of co-manufacturers that are considered low-risk meet the requirements of the SQF Food Safety Code: Food Manufacturing, or other GFSI benchmarked certification programs, and regulatory and customer requirements; and

 

First, we establish what is an high or low risk supplier based on internal criteria. I don't think that there's any guideline from SQF.

 

By reading 2.3.3.2 i., for the High risk, we absolutely need to work with a plant that his SQF or we need to audit them under SQF code? A GFSI certificate such as FSCC or BRC wouldn't be sufficient?

 

If a co-manufacturer produce a product that is not under my SQF scope, example he manufacture cheese stick but we are not producing it. If my client do not request it, do I need to find a SQF plant since I'm SQF?

 

Thanks

Maxime

[Scampi]

I don't believe they have to be SQF in particular but do need a GFSI current certification

 

"All the requirements in the code for contract manufacturers and distribution centers combine to ensure these important partners are managing food safety systems similar to the certified site"  See previous guidance for assistance

 

What does it mean? Contract manufacturers are facilities that are contracted by the SQF certified supplier to produce, process, pack, and/or store part of all of one or more products included in the supplier’s product scope. In some cases, a product may be manufactured interchangeably at the supplier’s site and at a contracted site. In other cases, a contract manufacturer may only be used intermittently to fulfill or supplement the supplier’s production. Whatever the situation, any contract site used to manufacture, in part or in whole, an SQF certified product MUST fulfill the same requirements as the SQF certified supplier. The responsibility for ensuring that these conditions are met is part of the primary supplier’s SQF System. What do I have to do? The supplier must have a documented procedure detailing how they will ensure that product in the care of the contact manufacturer meets their customer specifications and the requirements of the SQF Code. Control of the food safety management system in an external site that is under different management is not an easy task. However the supplier must ensure that facilities selected to contract manufacturer are committed to meeting SQF System requirements. This includes management commitment, pre-requisite programs, document control and records, adhering to specifications, food safety plans, and all other food safety controls. The supplier may simply require the contract manufacturer themselves to be independently SQF certified, or may choose to control the conditions in the contract site via sampling, testing, inspections and internal auditing. In the latter case, a verification schedule, including a sampling plan and internal audit procedure must be included. If the contract manufacturer is processing or packing high risk product on behalf of the supplier, then the contract manufacturer must undergo an audit to the requirements of the SQF Code for the particular food sector category. The audit may be conducted by the supplier, or by an independent third party agency, and must be conducted at least annually. The audit does not necessarily require certification but must confirm compliance to the requirements of the SQF Code. An annual SQF audit of the contract manufacturer does not replace the need for other regular checks and inspections at regular intervals. Any changes to customer specifications must be fully documented. Procedures must include a communication plan to contract manufacturer(s) with changes to specification identified. The supplier’s procedure must include verification that the contract manufacturer is aware of the changes to specification and that product produced after the change has been implemented reflects those required changes.

 

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

 

The answer re: risk level is embedded in the element  "The site shall establish a method to determine the food safety risk level of contract manufactured product and shall document the risk"   There is this guidance  https://www.sqfi.com...-Assessment.pdf

[MaximeL]

There's a clear indication that high risk co-man have undergone an audit to confirm compliance with the SQF code and low risk co-man need to meet the requirements of the SQF Food Safety Code or other GFSI benchmarked certification programs.

 

I do not agree with the specific requirement from SQF for high risk... GFSI benchmarked programs are in my opinion equivalent for high or low risk co-man. 

 

 

i. Products and processes of co-manufacturers that are considered high-risk have undergone an audit by the site or third-party agency to confirm compliance with the SQF Food Safety Code: Food Manufacturing and regulatory and customer requirements;

 

ii. Products and processes of co-manufacturers that are considered low-risk meet the requirements of the SQF Food Safety Code: Food Manufacturing, or other GFSI benchmarked certification programs, and regulatory and customer requirements;

[Scampi]

What you've posted says  "compliance with the code"  it DOES NOT say SQF certified

 

And from what I posted previously 

If the contract manufacturer is processing or packing high risk product on behalf of the supplier, then the contract manufacturer must undergo an audit to the requirements of the SQF Code for the particular food sector category. The audit may be conducted by the supplier, or by an independent third party agency, and must be conducted at least annually. The audit does not necessarily require certification but must confirm compliance to the requirements of the SQF Code. 

[Scotty_SQF]

Agree with Scampi on this and I have actually done this before.  They do not need to be SQF certified.  Just audited to ensure they are complying the elements spelled out in the code.  You can audit them if you are trained in auditing (have a certificate) and document it.  If they are GFSI certified, it should be good as they all follow the same general guidelines, there are just differences in the finer details.  You need to be able to show an auditor that your co-man's are in compliance, how you do so is up to you.

[MaximeL]

Words are important and can be interpreted, so should a co-manufacturer with an active GFSI certificate other than SQF manufacturing a high risk product need to be monitored to confirm compliance to the requirements of the SQF Code?

 

If the answer is yes, then the only solution I see is to audit them with the SQF actual version.

 

It's still not clear.

 

Thanks for your help guys.

 

... And if the product is not under my SQF scope, this doesn't apply. I can apply my own startegy.