8 replies to this topic

[NorCalNate]

I just submitted the final CARs from our first SQF audit (winery and wine bottling facility) and the auditor accepted them all except he rejected our Process Flow Diagram because they did not include "waste" outputs. For reference, he did not note this issue in any of our non-conformances. He also wants "decision points" removed as he noted:

 

"The diagrams need to remove decision points of rejected and acceptable as these are process flow diagrams and not decision trees"

 

The points he is referring to are actually inspection points in our bottling process such as Fill-Point Verification, Label Inspection and Case Weigh Station, and I could make a very strong argument that these points mitigate the following issues:

 

-High Fill-Point: TTB issue as we would not be paying enough taxes

-Low Fill-Point: Consumer Fraud (not enough wine in the bottle)

-Missing Label: We're required to put "contains sulfites" as this is an irritant and could be considered a consumer risk

-Case Weigh Station: If a bottle is missing the weigh station kicks the case out which prevents consumer fraud 

 

Unfortunately in our Hazard Analysis we did not address "Fraud" at any of these points so I'm worried by arguing this point I might open a can of worms. Maybe I should just do what he says and be done with this, though wanted others opinions as I'm a bit annoyed at the moment!

[Scampi]

have you called those CCPs?  If so, then they need to stay on your diagram

 

I do not include other inspection points on my diagram, that is what your decision tree shows (so i guess i'm agreeing with your auditor on that)

 

BUT it's your program and as long as you meet the standard, how you do it should be up to you with zero room for the auditors personal opinion

[olenazh]

Completely agree with Scampi: on my flow charts, I have QC inspection points as per customer requirement. I don't see why it should not be compliant with SQF or any other scheme requirements.

[NorCalNate]

have you called those CCPs?  If so, then they need to stay on your diagram

 

I do not include other inspection points on my diagram, that is what your decision tree shows (so i guess i'm agreeing with your auditor on that)

 

BUT it's your program and as long as you meet the standard, how you do it should be up to you with zero room for the auditors personal opinion

So you don't include steps including inspection equipment unless it's a CCP? In our situation, our inspection equipment aren't CCPs, though they do mitigate some consumer safety and consumer fraud issues, though I'm going to just go with the auditor's suggestion.

 

I've asked him if he's OK with me at least showing "reject" or "fail" points at each inspection station followed by the waste stream (e.g., Fill Point Verification => Reject => Cork removed put into black waste bin; Bottle Decanted & put into blue recycle bin). This at least provides context for there being a waste stream at a given point.

[Scampi]

No i do not, flow, yes for items like waste or rework with arrows to the next step

 

your decision tree is the base for the preventive control program---that is where you list what procedure mitigate what risks

 

the entire HACCP/Food Safety plan works as a whole, and not stand alone documents

 

that is why the process flow should be done BEFORE the decision tree as those flows are part of the overall analysis

[Charles.C]

I thought that SQF auditors always require CPs (= DPs = IPs = QCPs ?) on the Process Flow diagram despite IIRC of no mention of such within the Standard or Codex HACCP. Funny but not Hilarious.

[Tony-C]

Hi NorCalNate,

 

I think you can argue that you are complying with the requirements of CODEX as per SQF Food Safety Code requirements as your inspection points release or remove products.

 

SQF Food Safety Code

2.4.3 Food Safety Plan (Mandatory)

2.4.3.1 A food safety plan shall be prepared in accordance with the twelve steps identified in the Codex Alimentarius Commission HACCP guidelines.

2.4.3.6 The food safety team shall develop and document a flow diagram covering the scope of each food safety plan. The flow diagram shall include every step in the process, all raw materials, packaging, service inputs (e.g., water, steam, gasses as applicable), scheduled process delays, and all process outputs including waste and rework. Each flow diagram shall be confirmed by the food safety team to cover all stages and hours of operation.

 

CODEX GENERAL PRINCIPLES OF FOOD HYGIENE

 

DEFINITIONS

Step: A point, procedure, operation or stage in the food chain, including raw materials, from primary production to final consumption.

 

CHAPTER TWO HAZARD ANALYSIS AND CRITICAL CONTROL POINT (HACCP) SYSTEM AND GUIDELINES FOR ITS APPLICATION

SECTION 3: APPLICATION

3.4 Construct flow diagram (Step 4)

A flow diagram that covers all steps in the production of a specific product, including any applicable rework, should be constructed….etc.

Flow diagrams should, as appropriate, include but not be limited to the following:

the sequence and interaction of the steps in the operation;

where raw materials, ingredients, processing aids, packaging materials, utilities and intermediate

products enter the flow;

any outsourced processes;

where applicable reworking and recycling take place;

where end products, intermediate products, waste and by-products are released or removed.

 

To conclude, I think your auditor is being pedantic, you need to decide whether you want to appease him or stick to your guns and risk antagonising him. A solution might be to send them a revised version, wait until they approve the final CARs and issue your report, then issue a new revision as per your preferred format.

 

Provided you document your changes, I would be happy at the next audit to state that the team reviewed the submitted flow diagram and decided that the inspection points really should be in there as they are a step as per the CODEX definition.

 

Kind regards,

 

Tony

[Hoosiersmoker]

When the instructions point out: "Flow diagrams should, as appropriate, include but not be limited to the following" emphasis on the "...not be limited to" portion, as long as it includes the stated, required elements, it can also include others without jeopardizing the integrity of the flow diagram. This section is inclusive of required components, not exclusive of additional items added for the benefit of the HACCP program. 

 

Also, I have contested several auditor decisions without fear of antagonizing them. I look at it as enlightening them to information they might be unclear on as well as possibly confirming their point and therefore clarifying that element for us. We hire auditors to examine and help test our FSQMSs, many times nonconformances arise because of miscommunication or disconnect during the audit which can be clarified through the appeal process. Any auditor worth their salt should not view appeals as a personal affront but as and opportunity for improvement and increased understanding of the whole code of which the appeal process is a part.

[G M]

I just submitted the final CARs from our first SQF audit (winery and wine bottling facility) and the auditor accepted them all except he rejected our Process Flow Diagram because they did not include "waste" outputs. For reference, he did not note this issue in any of our non-conformances. He also wants "decision points" removed as he noted:

 

...

 

While our flow diagrams don't include every inspection point, they do certainly include the CQPs (critical quality points).  Even our federal inspectors don't say boo about having those on our flow diagrams, and they're necessary to some degree for the SQF quality code.

 

It sounds like most of your inspection points that the auditor is questioning are generating rework, and that kind of backflow can certainly be included in the chart, especially if it has the potential to blend separate lots together if not traced properly.

 

 

2.4.6 Product Rework

2.4.6.1 Procedures shall be documented and implemented to ensure product quality or formulation is not compromised by the rework process. Material to be reworked shall be identified and traceable. Rework operations shall be overseen by qualified personnel.

 

Rework: Food, materials, and ingredients, including work-in-progress that has left the normal product flow and requires action to be taken on it before it is acceptable for release and is suitable for reuse within the process.