4 replies to this topic

[LaurenH]

Hello,

 

We recently had our recertification audit and we received a minor for not having a substitute SQF practitioner. See below for the evidence noted from the auditor. We currently do not have a Operations Manager but intend on replacing which is why we didn't change the job description. In the interim, the Domestic/Warehouse Coordinator ( we currently have 2) was designated as the back-up the Operations Manager. The Domestic/Warehouse Coordinator's are just recently HACCP certified but do not have an understanding of the SQF code and does not participate in the Senior Management meetings; although they participate in our monthly HACCP/FS meetings. I was already fully prepared to receive a minor for this but I am struggling on how to respond with a CA and PA if we intend on replacing the Operations Manager. Is it as simple as stating that they will be included in the Senior Management meetings or should I include training on implementing SQF systems. Do I also need to update the job descriptions to include this requirement? I think I am over thinking this but because we have two Domestic/Warehouse Coordinators, they both need to have the same qualifications has the Operations Manager (and the same as the SQF Practitioner; myself) at this point and it is somewhat unrealistic in terms of pay scale if that makes sense.

 

2.1.1.5 The primary and substitute SQF practitioner shall:

i. Be employed by the site;

ii. Hold a position of responsibility related to the management of the site's SQF System;

iii. Have completed a HACCP training course;

iv. Be competent to implement and maintain HACCP based food safety plans; and

v. Have an understanding of the SQF Food Safety Code: Food Manufacturing and the requirements to implement and maintain an SQF System relevant to the site's scope of certification.

 

“Operations Manager was designated as the back-up SQF Practitioner. The site did not have an Operations Manager. The job description outlines that the QA Supervisor, who was the designated SQF Practitioner; would be the back-up for duties involving the Food Safety Management System (FSM System, and the Domestic/Warehouse Coordinator would back-up operations, or where appropriate and competent. The Domestic/Warehouse Coordinator did have HACCP training though was not involved with the management of the SQF or FSM System.”

 

[Scampi]

Let's break it down

 

1) when was the Ops manager removed from that position---e.g. how much time and notice did you have to replace the SQFP back up-this will be an important part of your CAPA

 

2) how long until the OPs manager is replaced and have they taken the 5 day HACCP/SQF course?  If not, when can it be completed by

 

3) when did you last really review the org chart to ensure back ups made good sense

 

You need to meet the requirements of the code, most importantly

iii. Have completed a HACCP training course;

iv. Be competent to implement and maintain HACCP based food safety plans; and

v. Have an understanding of the SQF Food Safety Code:

[LaurenH]

Thank you for your quick response!

 

1. The Ops Manager resigned in 06/2024. He was not replaced because at the time our business was not doing well. In that time I made sure that all of his Ops responsibilities were designated and I had the two Domestic/Warehouse Coordinators complete the required HACCP training course so I has support with verification documents. 

2. Currently, there is no set time frame because our President is waiting for the business to increase.

3. The review of the Organizational Chart was completed in December and made sense at the time because we were fully prepared to take the hit on not having a back-up. The Domestic/Coordinators have no prior FSM system experience so I didn't think it was appropriate trying to designate them as back-up SQF practitioners.

Let's break it down

 

1) when was the Ops manager removed from that position---e.g. how much time and notice did you have to replace the SQFP back up-this will be an important part of your CAPA

 

2) how long until the OPs manager is replaced and have they taken the 5 day HACCP/SQF course?  If not, when can it be completed by

 

3) when did you last really review the org chart to ensure back ups made good sense

 

You need to meet the requirements of the code, most importantly

iii. Have completed a HACCP training course;

iv. Be competent to implement and maintain HACCP based food safety plans; and

v. Have an understanding of the SQF Food Safety Code:

[Scampi]

Soooooooo you need to get someone else trained in SQF in order to close this CAPA

 

Anything else won't be sufficient and will be rejected

 

The business sounds like it needs to decide if the cost of SQF is worth it at this point

 

I don't see any other way for this non conformance to be accepted, the code is clear on this one

[jfrey123]

The guidance docs here might be helpful:

SQFI | Code Document

 

From what I'm reading, plain and simple you did not have a backup Practitioner due to someone leaving the role that was designated.  That can be the root cause, your backup practitioner (ops mgr) left and was not replaced.  This should've been identified when you self-audited yourself under 2.5.4.1(ii), unless the person was still employed when you did it (but it sounds like they were not), so you can add this to your root cause investigation.

 

For the CAPA, I would consider designating multiple roles in your job descriptions and FSQMS as substitute practitioners.  People who can take over your responsibilities when you're not on site.  The SQF certification is not mandatory for this, only a knowledge of the code, but a 2-day certified HACCP course is a hard requirement for the role.  So I would look within your department and find people qualified to hold the role of substitute practitioners.  Train them on the duties required by your SOPs.  Note that your future self-audits will check to ensure those with substitute practitioners are still employed and have up-to-date trainings.