5 replies to this topic

[FiorellaOrtizL]

Hello everybody!

I work in the Bakery Industry, and I'm elaborating on their SOPs according to the SQF standard. My question pertains to item 11.7 in SQF - Separation of Functions. Since we don't process high-risk food, is it mandatory to develop an SOP for this point, or can I ignore this item? If so, how can I explain this to the auditor?

[SQFconsultant]

It is not mandatory to develop something that represents nothing - you may simply want to put a statement in writing and leave it at that.

 

There are other areas in 11.7 however that would apply of course.

[jfrey123]

Does your HACCP identify your baking as a kill step and/or CCP?  I ask specifically because of this:

 

11.7.1.1 The processing of high-risk food shall be conducted under controlled conditions, such that sensitive areas, in which the high-risk food has undergone a “kill” step, a “food safety intervention” or is subject to post-process handling, are protected/segregated from other processes, raw materials, or staff who handle raw materials, to ensure cross-contamination is minimized.

 

If your HACCP does identify a kill step, then you'll want to show personnel separation via some SOP (could be people flow, your raw/finished goods handling program, etc.).  The moment an auditor watches your dough mixer team walk straight from the prep area to the end of the finished goods area, they're going to ding you.  As an example, our USDA meats/appetizers plant uses different colored smocks to separate out employees who handle the raw/wip material (white) and then the employees who handle finished sealed product (blue smocks for packaging/palletizing and warehousing).  Blue employees are prohibited from entering spaces where raw/wip is being handled to minimize cross-contamination of our RTC products there.

[FiorellaOrtizL]

Hi.

We have one CCP: a metal detector. We don't consider baking as a CCP. Staff working in the raw processing area and finished product area wear different colored uniforms.

 

 

Does your HACCP identify your baking as a kill step and/or CCP?  I ask specifically because of this:

 

11.7.1.1 The processing of high-risk food shall be conducted under controlled conditions, such that sensitive areas, in which the high-risk food has undergone a “kill” step, a “food safety intervention” or is subject to post-process handling, are protected/segregated from other processes, raw materials, or staff who handle raw materials, to ensure cross-contamination is minimized.

 

If your HACCP does identify a kill step, then you'll want to show personnel separation via some SOP (could be people flow, your raw/finished goods handling program, etc.).  The moment an auditor watches your dough mixer team walk straight from the prep area to the end of the finished goods area, they're going to ding you.  As an example, our USDA meats/appetizers plant uses different colored smocks to separate out employees who handle the raw/wip material (white) and then the employees who handle finished sealed product (blue smocks for packaging/palletizing and warehousing).  Blue employees are prohibited from entering spaces where raw/wip is being handled to minimize cross-contamination of our RTC products there.

[jfrey123]

@fiorellaortizl, that sounds perfectly reasonable.  Make sure that uniform difference is codified into your SOPs somewhere, and cited that SOP when you fill out your SQF checklist when you answer the 11.7 questions.  I don't like numbering my SOP's to match SQF's program, because it leads to a lot of repetition of SOP's, so wherever you've denoted this separation of functions is fine so long as you can show it to the auditor when they get to 11.7.

[G M]

Hi.

We have one CCP: a metal detector. We don't consider baking as a CCP. Staff working in the raw processing area and finished product area wear different colored uniforms.

 

 

Baked goods aren't my wheelhouse, but don't the raw agricultural commodities like flour going into your product carry some biological risks?