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kyrabowden

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Posted 21 September 2023 - 03:11 PM

As the QA specialist, I've been tasked with transitioning our HACCP plan into an SQF program at our food manufacturing facility. Although our product is classified as low-risk (processed fruits/vegetables product and grain derived snack foods), I've been making our HACCP plan more robust and have implemented environmental swabbing, food defense, etc. 

 

Our goal is to be SQF certified for January 2024, so there is a time crunch. I have reviewed the SQF edition 9 Level 2 checklist and created a gap analysis/proposal containing all efforts and documents needed to (hopefully) pass the audit. We have gotten 99% on our past HACCP audits and I believe we can acquire SQF, however I am a junior in food safety and definitely still learning.

 

Does anyone have any advice, support, or honest feedback when transitioning from HACCP to SQF in such a short period of time? Anybody that has been through similar situations? 

 

All feedback would be greatly appreciated!



Scampi

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Posted 21 September 2023 - 03:55 PM

SQF at it's heart IS HACCP, just called something else

 

Do you have forms 1-10 AND a PRP plan?  IF so, then you're more than 1/2 there

 

Are you currently using the CFIA FSEP plan?

 

What I have done is added SQF element numbers to my SOP/SSOPs so I know exactly what covers what as far as the PRP goes

 

In my HACCP plan I reference SQF AND CFIA requirements so it's easy reference

 

 

If you're running a traditional (buy enhanced) HACCP plan, you'll more than likely find that your GAP analysis comes up empty or close to it


Edited by Scampi, 21 September 2023 - 03:58 PM.

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kyrabowden

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Posted 21 September 2023 - 04:52 PM

Hi Scampi! 

 

We have forms FSEP forms 1-10 in place for all of our products, and pre-req programs A-G. 

 

Thanks for the insight on adding SQF elements into the SOP's, great idea! I'm going to note to add that and also update all pre-req plans to reference SQF. 

 

And you're right, the gap analysis was mostly comprised of just changing wording and enhancing the current plans we have in place. 

 

Thank you for the response. 

SQF at it's heart IS HACCP, just called something else

 

Do you have forms 1-10 AND a PRP plan?  IF so, then you're more than 1/2 there

 

Are you currently using the CFIA FSEP plan?

 

What I have done is added SQF element numbers to my SOP/SSOPs so I know exactly what covers what as far as the PRP goes

 

In my HACCP plan I reference SQF AND CFIA requirements so it's easy reference

 

 

If you're running a traditional (buy enhanced) HACCP plan, you'll more than likely find that your GAP analysis comes up empty or close to it



SQFconsultant

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Posted 21 September 2023 - 04:59 PM

One bug suggestion is to change the goal date from January to end of 1st quarter or there abouts.

 

Less than 4 months is a lot of pressure to be under.


All the Best,

 

All Rights Reserved,

Without Prejudice,

Glenn Oster.

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http://www.GCEMVI.XYZ

http://www.GlennOster.com

 


Scampi

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Posted 21 September 2023 - 05:08 PM

I would suggest you remove the FSEP titles on your PRP and change those to SQF elements/categories also

 

CFIA isn't auditing to FSEP anymore, so they won't care what they are called, and will make your SQF process a lot easier


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jfrey123

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Posted 21 September 2023 - 05:54 PM

If you're HACCP certified now, you're almost set for an SQF certification.

 

Guidance documents are helpful tools for me:  SQF Guidance, Tip Sheets and Checklists - SQFI

 

In that same link, you'll see "Checklists" you can download to help give yourself a pre-audit run down.  Not only are these helpful for finding your own gaps, but they are required to be filled out before your audit.  It doesn't "technically" have to be their exact form, but I've noticed auditors like it.

 

When completing that Checklist, SQF code 2.5.4.1.ii requires "Objective evidence is recorded to verify compliance and/or non-compliance;"  Three of my plants were hit on that this year, because when they completed the checklist, they merely wrote down "yes" or something similar to items they felt like they were compliant to.  SQF is demanding you explicitly record how you are meeting that objective.  I've asked auditors, "isn't that us just doing your job for you?" and they just smirk...

 

You've got this!



kyrabowden

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Posted 21 September 2023 - 07:44 PM

Thank you jfrey123! I appreciate the honest and positive feedback. Good insight on SQF code 2.5.4.1.ii, I'll be sure to make note of that to cover ourselves.

 

 

If you're HACCP certified now, you're almost set for an SQF certification.

 

Guidance documents are helpful tools for me:  SQF Guidance, Tip Sheets and Checklists - SQFI

 

In that same link, you'll see "Checklists" you can download to help give yourself a pre-audit run down.  Not only are these helpful for finding your own gaps, but they are required to be filled out before your audit.  It doesn't "technically" have to be their exact form, but I've noticed auditors like it.

 

When completing that Checklist, SQF code 2.5.4.1.ii requires "Objective evidence is recorded to verify compliance and/or non-compliance;"  Three of my plants were hit on that this year, because when they completed the checklist, they merely wrote down "yes" or something similar to items they felt like they were compliant to.  SQF is demanding you explicitly record how you are meeting that objective.  I've asked auditors, "isn't that us just doing your job for you?" and they just smirk...

 

You've got this!



Xoinks

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Posted 21 September 2023 - 08:41 PM

I agree with maybe moving to end of Q1 if possible.   The challenge really depends on the complexity of your operation, leadership buy-in, and how much time you are able to dedicate to it.    

 

I've now implemented SQF for 4 separate businesses as QA Manager.   The most recent one I started with almost nothing (including no HACCP plan as almost all of the previous documentation was lost due to an external drive failure - that was "fun"), and wrote everything (converting many from previously existing templates from a FS Consultant) in 2 months, and then was audited with about 3 weeks of solid records after that. (98%)

 

The one previous to that was about 5 months to implement in a large but new RTE operation and a great Corporate QA person doing most of the writing - that was a hot mess but we passed with a 97%.  (I've implemented SQF in 2 facilities this year)

 

The only reason that succeeded is because a) the owner told everyone to do whatever I said, b) jumped on whatever I asked, and c) is a new, extremely well designed and clean facility with a simple process and one formulation of low risk product for further processing and a shared allergen profile with about 5 ingredients and d) I was able to focus almost solely on implementation every day.   0/10, do not recommend if you have anxiety and/or enjoy time outside of work.  

 

They removed the 3 month requirement of records, so technically you can push your true implementation date pretty close to your audit if you have any records you won't have SQF ready.  If you do this:  You can use the records you have on lockdown as a good way to help demonstrate to the auditor you have effective implementation and a culture/commitment to maintain it, just maybe a few pieces weren't ready until close to the audit.  

 

Recommendations:  Get a 3rd party Gap Assessment, it's a good investment.  Plus if you expect to have a lot of arguing from people set in their ways, it's a really good way to start off right and set the tone from the get go.  Make sure the owner/senior site manager is involved in the gap assessment for a period and have at least one key person from production management come with for the full gap assessment.  There are things you may think you're meeting that the consultant will be able to identify you're not, and things you think aren't meeting the code that you are.  (It's gotten better, but I swear SQF code still has the tendency to mean one thing but write another in places).  

 

It goes way better if your senior site manager truly buys in.  If you don't have that, it's a painful slog and the most likely cause of failure.  Management/Senior site manager needs to show up to the opening meeting, but if they're invested they wouldn't want to miss it.  Keep them updated.

 

And finally I always spent a lot of time training our production personnel what SQF means (weekly pre-shift meetings).  (Like what it really means - we are getting SQF certification because we want to make Safe, Quality Food.)  Repeating that stuff over and over again is more powerful than it seems, and it helps connect WHY all of these changes are suddenly occurring.  The best programs in the world mean nothing if your front line doesn't follow them. 

 

Good luck!  



kyrabowden

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Posted 22 September 2023 - 01:17 PM

Thank you for the feedback! 

 

Sounds like you've had some really successful audits, great job and I love hearing success stories :clap: Thankfully, our team is very small (9 people), that have been working here for 2+ years so they understand my role and why I have to implement certain things. The production team blows me away with their commitment to quality - coming to me with quality issues, suggestions for improvement, etc. I think if we had double the amount of people and more CCP's/more complex processes I would not be as eager to agree to having the audit this upcoming January. 

 

Nonetheless, I am going to greatly consider your suggestions with having a 3rd party gap analysis and having more frequent meetings with my team. I think both of these are great ideas. 

 

I appreciate your helpful and honest feedback!

I agree with maybe moving to end of Q1 if possible.   The challenge really depends on the complexity of your operation, leadership buy-in, and how much time you are able to dedicate to it.    

 

I've now implemented SQF for 4 separate businesses as QA Manager.   The most recent one I started with almost nothing (including no HACCP plan as almost all of the previous documentation was lost due to an external drive failure - that was "fun"), and wrote everything (converting many from previously existing templates from a FS Consultant) in 2 months, and then was audited with about 3 weeks of solid records after that. (98%)

 

The one previous to that was about 5 months to implement in a large but new RTE operation and a great Corporate QA person doing most of the writing - that was a hot mess but we passed with a 97%.  (I've implemented SQF in 2 facilities this year)

 

The only reason that succeeded is because a) the owner told everyone to do whatever I said, b) jumped on whatever I asked, and c) is a new, extremely well designed and clean facility with a simple process and one formulation of low risk product for further processing and a shared allergen profile with about 5 ingredients and d) I was able to focus almost solely on implementation every day.   0/10, do not recommend if you have anxiety and/or enjoy time outside of work.  

 

They removed the 3 month requirement of records, so technically you can push your true implementation date pretty close to your audit if you have any records you won't have SQF ready.  If you do this:  You can use the records you have on lockdown as a good way to help demonstrate to the auditor you have effective implementation and a culture/commitment to maintain it, just maybe a few pieces weren't ready until close to the audit.  

 

Recommendations:  Get a 3rd party Gap Assessment, it's a good investment.  Plus if you expect to have a lot of arguing from people set in their ways, it's a really good way to start off right and set the tone from the get go.  Make sure the owner/senior site manager is involved in the gap assessment for a period and have at least one key person from production management come with for the full gap assessment.  There are things you may think you're meeting that the consultant will be able to identify you're not, and things you think aren't meeting the code that you are.  (It's gotten better, but I swear SQF code still has the tendency to mean one thing but write another in places).  

 

It goes way better if your senior site manager truly buys in.  If you don't have that, it's a painful slog and the most likely cause of failure.  Management/Senior site manager needs to show up to the opening meeting, but if they're invested they wouldn't want to miss it.  Keep them updated.

 

And finally I always spent a lot of time training our production personnel what SQF means (weekly pre-shift meetings).  (Like what it really means - we are getting SQF certification because we want to make Safe, Quality Food.)  Repeating that stuff over and over again is more powerful than it seems, and it helps connect WHY all of these changes are suddenly occurring.  The best programs in the world mean nothing if your front line doesn't follow them. 

 

Good luck!  



Scampi

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Posted 22 September 2023 - 01:41 PM

One thing to remember post certification--------let CFIA know that you are now GFSI certified, it will alter your risk rating for level of inspection :)


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Charles.C

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Posted 23 September 2023 - 04:41 AM

I take some issue with claims that SQF "approximates" to HACCP.  IMHO this comparison is a disservice to HACCP, notably in the context of "clarity" .

 

Not that HACCP itself is "simple" but by comparison - Wow !

 

A similar criticism IMO applies to all the other major GFSI-recognised Standards although each often has its own characteristic obfuscations  which are maintained through successive Revisions.

 

As single examples in frustration  - SQF (Validation), BRC (Risk Assessment), ISO/FSSC (OPRP)

 

Just my 5 cents. :smile:


Kind Regards,

 

Charles.C


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Posted 04 December 2023 - 05:46 PM

I'm assuming this is a relatively recent push and you've yet to implement all the documentation and monitoring activities demanded by the SQF system. Please be aware SQF requires a minimum of 90 days of records in support of your SQF food safety plan before an initial certification audit can be attempted.

 

... be SQF certified for January 2024 ...





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