7 replies to this topic

[NorCalNate]

I've received my first consultant position and my first duty is to perform an internal audit of a company's SQF program (modules 2 and 11). I'm looking for some guidance on how far an internal audit of these modules goes. I'm on my first week of consulting. Here are some of my questions:

 

Example #1: Clause 2.4.3.6 outlines requirements for documentation of the flow diagrams, and notes "each flow diagram shall be confirmed by the food safety team to cover all stages and hours of operation"

Question #1: Does the internal audit simply confirm the presence of the flow diagrams and whether a flow-diagram verification has been performed? Where does the IA stop? 

 

Example #2: Clause 2.4.5.2 notes "Quarantine records and records of the handling, corrective action, or disposal of nonconforming materials or product shall be maintained."

Question #2: All the documentation has been created to comply with this item#. Does my audit stop at whether these records are being maintained vs maintained properly? The Hold Tags are not being filled out properly or being signed off as noted on the document and there is no HOLDs Log. Suggestions on how far to go appreciated!!!

 

Overall I'm just looking for some guidance regarding the depth and responsibility a person conducting an IA is required to go. 

 

Thanks!

Edited by NorCalNate, 09 October 2025 - 04:15 PM.

[GMO]

I'm not an SQF auditor but how much in depth internal audits go I think is a question beyond SQF and opinion and practice varies.  I always hold with the approach that more in depth is LOADS better for internal audits before some external auditor picks you apart.

So personally to comply with that clause, I'd be looking for evidence on their records or in their meeting minutes that they'd not just verified the flow diagram and that all of them took part in that but they also did so at different times of the day / different production scheduling and actively chose those times to try and find something different.  So not that they did it once, ticked it off and said "job done, never looking at that again!"

[TimG]

Did the customer give you any indication on desired level of detail?

If I hired a consultant, I would absolutely want them to list ANY possible thing an auditor could hit me on. Along with WHY the auditor could hit me (intent of code vs. actual code violation, etc.) I also would not be opposed to them listing areas of improvement they discover that doesn't fall under either code or intent violation, but might be something an actual auditor see's and thinks "hrmm, that's something I see go along with a lot of NC's, I'm going to dig further.." 

If I have a consultant in, I have them in to get me TOP NOTCH, not just barely passable. However, not all owners or FSQ program directors feel that way (I've worked with some).

[jfrey123]

Two your two examples:

1.  IA can probably stop there IMO.

2.  I think that's a non-conformity.  They're not completing hold tags to their own SOP standard, and the hold tag itself likely isn't going to have the CA or record of disposal as required by the code.  The lack of a hold log to tie all the required information to the issued tag is a flaw.

 

 

For you performing this audit for them, I'm going to point out 2.5.4.1 requires "objective evidence" when reporting yourself as compliant.  Couple of my plants got dinged in past audits for merely write "compliant" on the self-audit checklist.  SQF requires you to demonstrate HOW you are compliant with every single code item.  (Yes, auditors agree it's basically SQF requiring that the auditee do the auditor's job for them)

 

2.5.4.1 The methods and responsibility for scheduling and conducting internal audits to verify the effectiveness of the SQF System shall be documented and implemented. Internal audits shall be conducted in full and at least annually. The methods applied shall ensure:

 

ii. Objective evidence is recorded to verify compliance and/or non-compliance;

[acarver]

I'm with TimG. I hired a consultant when we started the SQF process (previously just GMP through AIB). I only had a few NCs at the time, but tons of things to look at and improve upon. If he had not taken a deep dive into everything, the process would have been much more difficult. The purpose of hiring a consultant is not to make someone feel good about the situation at hand, but to help them see things that have been missed and to improve.

[Tony-C]

Hi NorCalNate,

 

For Question 1, When auditing against clause 2.4.3.6, it is not sufficient to check that flow diagrams exist, you need to check that flow diagrams include every step in the process, all raw materials, packaging, service inputs (e.g., water, steam, gasses as applicable), scheduled process delays, and all process outputs including waste and rework. As internal auditing tends to be a snapshot I would check at least one flow diagram and note that is is good practice to work through the rest on subsequent audits so that they are all covered over a period of time.

 

For Question 2, Clause 2.4.5.2, that needs to be raised as a non-conformance.

 

Note, whilst checking compliance with SQF during Internal Audits, you also need to be checking that the clients procedures are being followed.

 

Kind regards,

 

Tony

[NorCalNate]

I respectfully disagree with you Tony C about auditing of the flowchart diagrams, especially in my role as a consultant who doesn't have the expertise of the Food Safety team. To me this falls underneath the scope of required "Verification activities" which should be performed by the Food Safety team, i.e., annual verification and review of the food safety plan which involves verifying the flow chart, hazard analysis and any other aspects of that document. 

 

I do agree with your second point. 

 

Thanks

[GMO]

I respectfully disagree with you Tony C about auditing of the flowchart diagrams, especially in my role as a consultant who doesn't have the expertise of the Food Safety team. To me this falls underneath the scope of required "Verification activities" which should be performed by the Food Safety team, i.e., annual verification and review of the food safety plan which involves verifying the flow chart, hazard analysis and any other aspects of that document. 

 

I do agree with your second point. 

 

Thanks

 

Sorry to disagree with your disagreement    but I do disagree.

 

You're there as an independent pair of eyes.  Yes the HACCP team should ensure that the flow diagram is accurate, however, as part of an internal audit of the HACCP plan, one of the questions I'd think is entirely reasonable is to go out into the plant with the flow and see if it broadly reflects reality.  Yes I'd be unfamiliar with the plant but I could ask members of staff, look for rework processes which aren't included and basically try and follow the flow.

 

An external GFSI auditor can do that, why can't I?