Does a Product Have to Have a HACCP Plan for an SQF Certification?

Our Beverage co-packaging company also PACKAGES and DISTRIBUTES (but we do not manufacture) a food grade mineral oil.

As we  prepare to obtain our initial SQF certification, I am wondering if we will need an individual HACCP plan for this mineral oil, seeing as we do not utilize this ingredient to be mixed with any other formulas, neither are we running any test on said product. We receive this product from a certified company, we store it on-site and package it for immediate distribution once an order comes in for this product. Our means of verification are through COA, Kosher wash and approved supplier verification. Our products are also NSF certified.

Without identifying any CCP in my Hazard Analysis, do you all believe I will be able to achieve SQF certification on this  finished product? 

I might also add that the manufacturer of the mineral oil that we purchase from does, in fact, have their own HACCP plan for this mineral oil. 

So I'm sure I understand

You're running a non -food item down a food processing line and wondering if you'll achieve SQF without a HACCP plan for the non food item?

If there is no HACCP plan for your facility (or copackers) how do you know what the risks are to the food you/they also process????

I think there are a couple of holes in your idea 

It's great that the manufacturer of the oil has a HACCP plan, but how do YOU mitigate risks in house without one?  It doesn't matter that you don't make the product, it sounds like you do make others 

Hell Scampi, 

We do have a HACCP plan in place for our site. It covers the other products that we mix, which are beverages, but it does not include the food grade mineral oil. 

That's a problem IMHO

You're running it on the same equipment, correct?  If so, you need a plan for it, if for no other reason that to ensure you're not contaminating the beverages somehow 

You can also have a product exemption for the oil but I would still create a plan for it

Food grade does not equal safe to consume, it's only labelled that was for incidental food contact

Thanks for the insight. I am new to the world of HACCP and I've learned a great bit since starting in my current role. My #1 goal is to be 100% compliant and so I am very much grateful to have such a resource for these unknown topics. 

Welcome to the industry!  Buckle up it's a wild ride

NOTE:  If I were calling the shots at your facility---there would never been non food product going down a food line, under any circumstances

Okay, 

Scampi, I believe that you may be under the assumption that there is lawlessness in this oil packaging process of ours. Please allow me to clarify, just so as to ensure that I am receiving the correct information in the end...

Renoil 70- W White Mineral Oil is packaged by our company and distributed to customers to be used for grain de-dust to prevent explosions, as a food grade H1 lubricant, and as a release oil for baking (FDA and USP food grade quality required.) This is a food processing aide that is regulated as a non-food mineral-oil, with direct contact with direct and indirect food contact. There are several prerequisite programs in place to include: Vendor verification, training, allergen management (though these oils do not contain any allergens requiring declaration by the FDA, SOPs, GMP's, verification of COAs as well as Kosher wash verification (Halal registration as well)

There are no identified biological hazards since oil does not support growth of microbs. No chemicals hazards since no chemicals are used or added in the receiving or packaging process at our plant and have been deemed chemical free from our supplier. There are lastly extremely limited physical hazards due to GMP and cleanliness procedures through our ISO 9001 quality system. 

All in all, no critical control points are found and any low risk hazards are mitigated through prerequisite programs.  (Should I just put this all into a formal HACCP plan or will our SOPs be enough to have this specific product certified? ) I'm sorry that was the depth of the inquiry. 

Ah, thanks for the rest of the information

You will need a food safety plan (including HACCP forms) for SQF certification

However, SQF certifies sites, not products FYI, so what the manufacturer has done re: HACCP plan at their facility has no standing at yours outside of the approved supplier program

Halal and Kosher are not a measure of safety, but a measure of the process and/or ingredients used in making said product

re: this particular item, I would reach out to SQF directly to ensure that they will before doing any of the leg work

Have you verified that your equipment is clean after running the oil?  

Thanks you guys!