Hi Everyone,
I thought I’d post some recent information and statics for non-conformances from SQF Audits that I think that members will find useful in preparing for future audits. Below I have summarized information from 2021 and 2022 SQF certification audits including the Critical Non-conformances, Top 5 Major Non-conformances and the Top 10 Minor Non-conformances for both years.
2021 (Edition 9 Implemented in 2021) Critical Non-Conformances Clauses
Clause 2.5.4.1 from Section Internal Audits and Inspections (Mandatory) x 2 - The methods and responsibility for scheduling and conducting internal audits to verify the effectiveness of the SQF System shall be documented and implemented.
Clause 2.1.2.2 from Section Management Responsibility (Mandatory) - The SQF practitioner(s) shall update senior site management on at least a monthly basis on matters impacting the implementation and maintenance of the SQF System.
Clause 2.4.1.1 from Section Food Legislation (Mandatory) - The site shall ensure that at the time of delivery to customers finished products shall comply with food safety legislation applicable in the country of manufacture and sale.
Clause 2.4.3.1 from Section Food Safety Plan (Mandatory) - A food safety plan shall be prepared in accordance with the twelve steps identified in the Codex Alimentarius Commission HACCP guidelines.
Clause 2.4.3.9 from Section Food Safety Plan (Mandatory) - The food safety team shall determine and document the control measures that must be applied to all significant hazards.
Clause 2.4.3.16 from Section Food Safety Plan (Mandatory) - Critical control point monitoring, corrective action, and verification records shall be maintained and appropriately used.
Clause 2.5.3.2 from Section Corrective and Preventative Action (Mandatory) - Records of all investigation, root cause analysis, and resolution of non-conformities, their correction
Clause 2.8.1.1 from Section Allergen Management (Mandatory) - The responsibility and methods used to control allergens and to prevent sources of allergens from contaminating product shall be documented and implemented.
Clause 9.1.2.4 from Module 9: Good Manufacturing Practices for Processing of Animal Products from Section Building Materials - Walls, partitions, ceilings, and doors shall be of durable construction…
2022 Critical Non-Conformances
3 x Clause 11.2.4.3 from Section Pest Prevention - Pest activity risks shall be analyzed and recorded. Inspections for pest activity shall be conducted on a regular basis
2 x 11.2.4.4 from Section Pest Prevention - Food products, raw materials, or packaging that are found to be contaminated by pest activity shall be effectively disposed of, and the source of pest infestation shall be investigated and resolved.
2 x Clause 2.4.3.1 from Section Food Safety Plan (Mandatory) - A food safety plan shall be prepared in accordance with the twelve steps identified in the Codex Alimentarius Commission HACCP guidelines.
2 x Clause 2.4.3.10 from Section Food Safety Plan (Mandatory) - A food safety plan shall be prepared in accordance with the twelve steps identified in the Codex Alimentarius Commission HACCP guidelines.
Clause 11.2.4.1 from Section Pest Prevention - A documented pest prevention program shall be effectively implemented.
Clause 2.1.1.2 from Section Management Responsibility (Mandatory) - Senior site management shall lead and support a food safety culture within the site ……..
Clause 2.4.3.11 from Section Food Safety Plan (Mandatory) - For each identified CCP, the food safety team shall identify and document the limits that separate safe from unsafe product (critical limits).
Clause 2.4.3.12 from Section Food Safety Plan (Mandatory) - The food safety team shall develop and document procedures to monitor CCPs to ensure they remain within the established limits.
Clause 2.4.3.14 from Section Food Safety Plan (Mandatory) - The documented and approved food safety plan(s) shall be implemented in full.
I know the numbers do not match but apparently, there were 24 Critical NCs in total in 2022, this was double the number in 2021.
SQF Code Top 5 Major Non-Conformances in 2021
Clause 2.5.4.1 from Section Internal Audits and Inspections (Mandatory) - The methods and responsibility for scheduling and conducting internal audits to verify the effectiveness of the SQF System shall be documented and implemented.
Clause 2.1.1.2 from Section Management Responsibility (Mandatory) - Senior site management shall lead and support a food safety culture within the site ……..
Clause 11.2.5.1 from Section Cleaning and Sanitation - The methods and responsibility for the effective cleaning of the food handling and processing equipment and environment and storage areas shall be documented and implemented.
Clause 2.4.3.1 from Section Food Safety Plan (Mandatory) - A food safety plan shall be prepared in accordance with the twelve steps identified in the Codex Alimentarius Commission HACCP guidelines.
Clause 2.5.3.1 from Section Corrective and Preventative Action (Mandatory) - The responsibility and methods outlining how corrective and preventative actions are determined, implemented, and verified, including the identification of the root cause and resolution of non-compliance …..
SQF Code Top 5 Major Non-Conformances in 2022
Clause 2.5.4.1 from Section Internal Audits and Inspections (Mandatory) - The methods and responsibility for scheduling and conducting internal audits to verify the effectiveness of the SQF System shall be documented and implemented.
Clause 11.2.5.1 from Section Cleaning and Sanitation - The methods and responsibility for the effective cleaning of the food handling and processing equipment and environment and storage areas shall be documented and implemented.
Clause 11.2.4.3 from Section Pest Prevention - Pest activity risks shall be analyzed and recorded. Inspections for pest activity shall be conducted on a regular basis
Clause 11.2.4.1 from Section Pest Prevention - A documented pest prevention program shall be effectively implemented.
Clause 2.4.3.12 from Section Food Safety Plan (Mandatory) - The food safety team shall develop and document procedures to monitor CCPs to ensure they remain within the established limits.
SQF Code Top 10 Minor Non-Conformances in 2021
Clause 11.4.1.1 from Section Staff Engaged in Food Handling and Processing Operations
Clause 2.7.1.2 from Section Food Defense Plan (Mandatory)
Clause 11.2.5.1 from Section Cleaning and Sanitation
Clause 11.1.7.2 from Section Equipment and Utensils
Clause 2.4.3.7 from Section Food Safety Plan (Mandatory)
Clause 2.6.1.1 from Section Product Identification (Mandatory)
Clause 2.2.3.2 from Section Records (Mandatory)
Clause 2.1.2.1 from Section Management Review (Mandatory)
Clause 11.1.2.4 from Section Building Materials
Clause 11.2.9.2 from Edition 8.1 Section 11.2.9 Equipment, Utensils and Protective Clothing
SQF Code Top 10 Minor Non-Conformances in 2022
Clause 11.2.5.1 from Section Cleaning and Sanitation
Clause 11.1.7.2 from Section Equipment and Utensils
Clause 11.1.2.4 from Section Building Materials
Clause 11.4.1.1 from Section Staff Engaged in Food Handling and Processing Operations
Clause 2.1.2.1 from Section Management Review (Mandatory)
Clause 11.1.5.1 from Section Dust, Insect, and Pest Proofing
Clause 2.4.3.6 from Section Food Safety Plan (Mandatory)
Clause 2.7.1.2 from Section 2.7.1 Food Defense Plan (Mandatory)
Clause 2.5.4.1 from Section Internal Audits and Inspections (Mandatory)
Clause 2.7.1.4 from Section 2.7.1 Food Defense Plan (Mandatory)
Statistics for SQF Food Safety Code Edition 9 Audits
Total Audits: 13,748
Critical Non-Conformances 22 (Equivalent to 1 in 0.16% of Audits)
Major Non-Conformances 1,338 (Equivalent to 1 in 9.73% of Audits)
Minor Non-Conformances 64,248 (Equivalent to 4.67 per Audit)
Information presented by and source:
Tammie Van Buren, Compliance Manager, SQFI Food Marketing Institute
Food Safety Trends and Challenges - Insights from SGS and Not Your Top Non-Conformances ... But Should They Be?
Additional Notes
I did note Tammie’s comments in Not Your Top Non-Conformances ... But Should They Be? that Micro (pathogen contamination) and Labelling (allergens) are major contributors to product recalls but are not major contributors to non-conformances in SQF audits. It would seem this indicates they will be an area for greater focus in future audits.
This is something I have been banging on about for a while, in my IFSQN presentations going back over 10 years I have highlighted issues with product recalls due to pathogen contamination and product labelling (particularly with allergens).
From the IFSQN Practical HACCP Training for Food Safety Teams Webinar:
A significant number of recalls are due to contamination with well-known environmental pathogens Salmonella and Listeria. FDA data shows that since 2017 there were 376 such Recalls, (34% of all Recalls)
Analysis of FDA Recall Notices from 2017 to 2021:
561 Recalls due to problems with labelling/undeclared allergens. Out of 1101 Recalls, 51% were due to labelling/undeclared allergens.
Kind regards,
Tony
Edited by Tony-C, 08 March 2023 - 08:28 AM.