8 replies to this topic

[LostInTheWoods]

Hi Gang,

Last week was our initial SQF audit, and we ended with a score of 93!

 

All 7 were minors, with 5 of them purely focused on our documentation. For example:

 

Clause:

FD 2.4 - 2.4.7.1 :The responsibility and methods for releasing products shall be documented and implemented. The methods applied shall ensure the product is released by authorized personnel, and only after all inspections and analyses are successfully completed and documented to verify legislative and other established food safety controls have been met. Records of all product releases shall be maintained.

 

Evidence:

The methods for releasing products has not been clearly defined and documented. Products are released after CCP monitoring checks and customer specifications are checked for compliance, however, the process/policy is incomplete. The complete release process is not defined in the policies that were reviewed.

 

We're doing it. The practitioner is reviewing all batch records before marking as complete in our ERP, but there's no documented SOP/WI describing that review. We had informally identified this as a gap, but we had a super tight deadline, and that was one of the documents that didn't get completed before the audit.

 

So what is the CB looking for in terms of Root Cause Analysis?

 

TIA

 

[Scampi]

Why you didn't have a written procedure for a required element

 

Training on the newly produced written procedure

 

Record for above review for product releases

 

Deviation procedures for the above

[Setanta]

If it isn't documented, it didn't occur, is a mantra for food safety and quality people.

[SQFconsultant]

As a former Auditor for years I can not tell you how many times I heard "but, we're doing it".... we just don't/didn't/couldn't/didn't have enough time/etc, etc, etc to write it down.

 

"Verbal Don't Go!, is what you are saying, Mr. Oster?"   Excellent observation by a facility president where the SQF Practitioner said over and over again - but, we are doing it.

 

Say what you do, do what you say, prove it!

 

Documentation is king.

[LostInTheWoods]

As a former Auditor for years I can not tell you how many times I heard "but, we're doing it".... we just don't/didn't/couldn't/didn't have enough time/etc, etc, etc to write it down.

 

"Verbal Don't Go!, is what you are saying, Mr. Oster?"   Excellent observation by a facility president where the SQF Practitioner said over and over again - but, we are doing it.

 

Say what you do, do what you say, prove it!

 

Documentation is king.

 

I understand that, and we're documenting the pre-release review on a form (and showed records of that), but no SOP/WI on how to use the form.

 

Our correction is to create the WI, can the Root Cause be as simple as "Not enough time to create SOP/WI?" Or would the CB expect us to dig deeper than that?

[Scampi]

 

Our correction is to create the WI, can the Root Cause be as simple as "Not enough time to create SOP/WI?" Or would the CB expect us to dig deeper than that?

 

not enough time isn't suitable

 

under the management commitment, your company is supposed to allow for enough people/time/money etc to meet the code

[jfrey123]

Sounds like you need a scapegoat.  You state someone identified that the program was missing the description of this step that you were actually doing.  Somewhere between the identification of that gap and the SQF audit, someone failed to correct the program and someone else failed to check that it happened.  Figure out whose shoulder the responsibility for updating the program was placed, then you could issue some retraining and a review of how you'll ensure self-identified gaps are dealt with quickly in the future.

[LostInTheWoods]

Sounds like you need a scapegoat.  You state someone identified that the program was missing the description of this step that you were actually doing.  Somewhere between the identification of that gap and the SQF audit, someone failed to correct the program and someone else failed to check that it happened.  Figure out whose shoulder the responsibility for updating the program was placed, then you could issue some retraining and a review of how you'll ensure self-identified gaps are dealt with quickly in the future.

 

Yes, we had a "to do" list that was quite long. Our timeline was significantly shortened due to reasons, and that was one of the items that wasn't prioritized. We thought we'd be good with having the form, and the records to show that the release form was used.

 

I'll likely shade towards our internal audit program as the scapegoat. We were able to justify to ourselves during the internal audit, but not the external audit.

 

It's much easier for me to root cause "physical" problems than "procedural" problems.

[MOHAMMED ZAMEERUDDIN]

"Say what you do, do what you say" is the foundation of any FSMS. It should be conscientiously implemented.