What to include in a GMP Policy for SQF?
I am reviewing our GMP Policy and Training Program for SQF and am trying to understand what we need to address in our GMP Policy and training materials for staff. We currently only address SQF 9.0 elements 11.3 and 11.4.1 in the Policy and staff training (Personnel Hygiene and Welfare & Personnel Processing Practices).
Any other elements we should address?
Do you address HACCP training or Food fraud?
first, you need to define GMPS.
To many people GMPs are the personnel practices in 11.3-11.4. To SQF - it is all of section 11. You might using them interchangeably. To SQFI "personnel practices" are a portion of the "GMPs".
You need to have a policy/procedure that covers the pertinent info in 11.3-11.4 like you are currently doing PLUS:
Training 2.9 states you need to cover.
Haccp implementation for those involved.
CCP monitoring a CAs
personnel hygiene (11.3-11.4)
GMPS and work instructions ( this is where you need to go through section 11 and decide what /who needs training. for instance, how to calibrate instruments/devices, general pest control and how to report pest sightings, SSOPS/ cleaning, glass cleanup, receiving/storage/shipping procedures, etc.
Sampling and testing
EMP
Allergens
tasks critical to the program.
THEN if you search the standard for "train" there are others that pop up. chemical safety, and blood Borne pathogen, internal audit, come to mind.
Do you address HACCP training or Food fraud?
Yes, depending on the results of our annual training Verification exercise, we require certain Production staff and Management to complete the following training modules:
GMPs & Personal Hygiene
Document Control and Records
HACCP and CCPs
Cleaning and Sanitation
Food Defense
Chemical Control
Internal Auditing
Allergen Mgt.
Broken Glass and Plastic Control
Water Control
Pest Control
Supplier Approval
Preventative Maintenance
Track and Trace and Recall
CAPA
Customer Complaints
Crisis Management
Food System Maintenance
FSMA Overview
Waste Management
Calibrations
ISO 17025
Non-Conforming Product and Equipment
Foreign Material Control
Food Fraud
Food Safety Culture
Product Release
Product Rework
"Training" requirements seem to be detailed at length in section 2.9.
I do not see any specific reference to "Policy" in section 2.9 but afaik this aspect was previously interpreted by SQF as an automatic partner to each SOP, albeit an unusually encyclopedic approach.
The (quite useful) SQF9 Guidance lists these as applicable -
1. 2.1.1.6
2. 2.3.4.6
3. 2.4.3.2
4. 2.4.4.2
5. 2.4.8.2
6. 2.5.4.2
7. 2.6.4.1
8. 2.7.1.3
9. 2.7.2.3
10. 2.8.1.2
11. 2.9
12. 11.3.1
13. 11.3.2