17 replies to this topic

[KarrieC]

Just got through our recertification.  Good score but we were hit with a major for something that happened outside of our scope.  A co-tenant of our building had a spill. non-allergen, non-toxic, non-bio., etc.  It's sugar.  It was all over there side of the warehouse.  We tried to help them clean it up, but it was big and the auditor came before we finished.  I want to appeal this.  I don't believe it is a food safety issue/hazard.  Undesirable maybe. It does not pose a threat to our food. We started cleaning immediately so not a failure in sanitation, somethings take time.  We didn't just leave it there.  The powder itself is not threat to our product, it may attract pests, but our pest control has been made aware of the situation and monitoring extra just in case.  So not a failure of pest control.  We did not spill it, but we are working with the other tenant to get it cleaned up (our free labor).  I requested and appeal.  this is the response I got.  What do you think my chances are?  $1000?  Is this going to an outside group or will they decide if THEIR auditor is right/wrong?

 

"Dear Karrie,

 

I understand you have requested information to submit an appeal. Please find attached the REC6 Complaints, Appeals, Disputes or Concerns Record Form to be completed to initiate the process. Please complete the first page and return to me. Upon receipt of the completed form, I will forward to our SQF Certification Manager for review and investigation. **Please note in the case of a denied appeal you will be charged an Appeal Processing Fee of $978.

 

Lastly, appealing any Non-conformance does not deter from the timeframe all corrective actions must be submitted. Meaning, you must still submit any and all Corrective Actions and Evidence to your auditor in the timeframe provided (30 days from the last day of your audit).

 

Please let me know if you have any questions."

 

[SHQuality]

How did they word the major in their report?

 

Everything you said makes sense to me, but if the spill wasn't your fault, cleaning was started on time and increased pest control checks were implemented immediately, I'm not sure what they're dinging you for. If you want any sensible answers a few more details would be helpful.

 

Did they perhaps upgrade from a minor to a major because this has been a recurring event from previous audits?

[kingstudruler1]

How did they word the major in their report?

 

Everything you said makes sense to me, but if the spill wasn't your fault, cleaning was started on time and increased pest control checks were implemented immediately, I'm not sure what they're dinging you for. If you want any sensible answers a few more details would be helpful.

 

Did they perhaps upgrade from a minor to a major because this has been a recurring event from previous audits?

 

This.  Please provide the clause and exact wording of the non conformity.   

[SQFconsultant]

I also would like to know exactly how this was worded, but also how is it that you could get a "good score" with a major.

 

My next question would be is their side open to your side - as in do you share a physical space?

 

And finally, did you argue the finding prior to the Auditor leaving the facility?

 

$978 huh?  that is fishy - a sketchy CB could make some nice change by simply saying no to all appeals.

 

I don't actually see how this would be a major, unless of course that "powder" drifted and cross contaminated your side.

[GMO]

Agree with all of the above.  I'd really push it when the auditor is on site as well and make it clear to the auditor that you intend to appeal.  A minor is pushing it as well in my opinion.  Sh** happens but if dealt with appropriately, then it's a judgement call on the part of the auditor.  Is this actually stuff which happens every day or just bad luck?  Even if you believe it's not just a one off, anything higher than a minor seems bizarre.

[jfrey123]

 

 

Is this going to an outside group or will they decide if THEIR auditor is right/wrong?

 

The CB's procedure they referenced should specify, but per the code the CB is required to review your appeal themselves and decide if their auditor was in or out of bounds.  If they return to you and back the auditor, then you can appeal directly to SQFI and let them review both the auditor and the CB to determine whether the finding was valid.

 

Pending whether you can share the code they referenced and the wording of the finding, I would be screaming to high holy heaven in my most indignant outrage.  If the auditor saw you actively trying to clean an ingredient spill, even on your side of the warehouse, and decided to write us up for it, I'd probably have to be physically restrained. 

 

And I've run SQF programs in co-opt'd spaces.  So long as the other tenant's area is clearly marked in your maps as "Not In Scope", only the most egregious of hazards should be of concern.  Granted in my case there were physical barriers between my food and the other tenant's warehouse space, but they were holding all sorts of hazmat chemicals and other crap.  Auditor still walked their space to verify we were vermin proofing the entire shared unit, walked past and commented on all sorts of the naughty items the other tenant kept, but agreed it was not a risk to our food side of the unit.

[LostInTheWoods]

I'll +1 to the others asking for the full wording. At face value, it appears that you've reacted properly, but there could be majors discovered by this error. Putting on my (very much amatuerish) auditing hat, is the shared space accounted for in your location risk assessments (11.1.1.1)? Your allergen risk assessments (2.8.1.1)? Food Defense (2.7.1)?

[KarrieC]

1.- The HACCP team and I addressed this issue directly with the auditor during his visit.  

2. Although there is no physical wall separating our section of the warehouse, there were four rows of unrelated inventory between the spill and our product, providing a clear buffer. (out of scope)

3.- The auditor initially stated that the spill occurred in February, which is incorrect. That date marks when the company moved into the facility. I have informed him of this discrepancy, and he acknowledged the error and committed to updating the report.  Still waiting.

4.We first observed product shifting on September 23, 2025, and immediately contacted the responsible party to address it. The removal process was gradual—one bag at a time—to ensure safety. I have weekly photographic documentation showing the cleanup progress and the consistently clean condition of our side of the warehouse. 

5.- There has been no increase in pest activity due to the sugar spill, and we have received no customer complaints regarding shipped products. Our sanitation crew has been working overtime for the past month to manage dust and maintain cleanliness.

6.- Sugar is not classified as an allergen. If the spill had involved an allergenic or hazardous substance, the situation would have posed a more serious risk.

7. The products we handle are dry and non-ready-to-eat (non-RTE), and both the product and its packaging generate significant dust. Dust control is a regular part of our sanitation schedule.

8.We do not own any of the products or materials. Our customer supplies all items, which we assemble and return. They frequently send dirty pallets, which we remove from service. Once we accumulate a full load, we send them to a pallet company for repair or disposal. These pallets are kept segregated from active inventory.

 

Here are his findings...

MAJOR: Evidence of sugar dust was observed at multiple locations of the main warehouse during the audit. The facility shares warehousing space with another company who stores sugar. There is no physical barrier between the leased space area and the main warehouse storage area, but does have segregation of materials via empty pallet spaces approximately 4 pallets wide. Back in February 2025, the leased space company had multiple pallets of bagged sugar fall from excessive heights which caused the sugar dust to disperse through the air into the entire warehouse. The facility was making attempts to clean up this spill throughout the past months. However, sugar dust was observed on almost all of the storage racks, and pallets of ingredients, packaging supplies, and other materials in these racks at the time of the audit. Sugar dust was also observed on many of the Work-in Process collapsed Gaylord containers and empty pallets used in production. Many of the 1000 Gaylord totes of regrind/WIP totes of pasta in storage, some used for the packaging operations, had sugar dust on them as well. The site notified their customer of the sugar spillage and mitigation strategies involved to dust off any products prior to use in the packaging operations. There was no evidence of sugar on any opened products at the time of the audit.

[KarrieC]

The CB's procedure they referenced should specify, but per the code the CB is required to review your appeal themselves and decide if their auditor was in or out of bounds.  If they return to you and back the auditor, then you can appeal directly to SQFI and let them review both the auditor and the CB to determine whether the finding was valid.

 

Pending whether you can share the code they referenced and the wording of the finding, I would be screaming to high holy heaven in my most indignant outrage.  If the auditor saw you actively trying to clean an ingredient spill, even on your side of the warehouse, and decided to write us up for it, I'd probably have to be physically restrained. 

 

And I've run SQF programs in co-opt'd spaces.  So long as the other tenant's area is clearly marked in your maps as "Not In Scope", only the most egregious of hazards should be of concern.  Granted in my case there were physical barriers between my food and the other tenant's warehouse space, but they were holding all sorts of hazmat chemicals and other crap.  Auditor still walked their space to verify we were vermin proofing the entire shared unit, walked past and commented on all sorts of the naughty items the other tenant kept, but agreed it was not a risk to our food side of the unit.

I only came in for a few hours yesterday to gather documents, brought my daughter (college student with a day off) with me as a filter because I was having trouble controlling my outrage!   I even had her check my emails before sending.  We were study buddies for a day.  I plan on filing an appeal.  Just gathering all my ducks first.  

[KarrieC]

I also would like to know exactly how this was worded, but also how is it that you could get a "good score" with a major.

 

My next question would be is their side open to your side - as in do you share a physical space?

 

And finally, did you argue the finding prior to the Auditor leaving the facility?

 

$978 huh?  that is fishy - a sketchy CB could make some nice change by simply saying no to all appeals.

 

I don't actually see how this would be a major, unless of course that "powder" drifted and cross contaminated your side.

1 major and only a couple minors. 

[LostInTheWoods]

3.- The auditor initially stated that the spill occurred in February, which is incorrect. That date marks when the company moved into the facility. I have informed him of this discrepancy, and he acknowledged the error and committed to updating the report.  Still waiting.

 

This becomes the key point. It sounds like a misunderstanding. Had a spill lingered for 8 months, it most definitely should be a major.

 

I would continue pressing the auditor for an amendment to the report based on the factual misunderstanding before laying out $978 for an appeal.

[KarrieC]

This becomes the key point. It sounds like a misunderstanding. Had a spill lingered for 8 months, it most definitely should be a major.

 

I would continue pressing the auditor for an amendment to the report based on the factual misunderstanding before laying out $978 for an appeal.

He said he would change it.  I have not seen that happen. 

[jfrey123]

Here are his findings...

MAJOR: Evidence of sugar dust was observed at multiple locations of the main warehouse during the audit. The facility shares warehousing space with another company who stores sugar. There is no physical barrier between the leased space area and the main warehouse storage area, but does have segregation of materials via empty pallet spaces approximately 4 pallets wide. Back in February 2025, the leased space company had multiple pallets of bagged sugar fall from excessive heights which caused the sugar dust to disperse through the air into the entire warehouse. The facility was making attempts to clean up this spill throughout the past months. However, sugar dust was observed on almost all of the storage racks, and pallets of ingredients, packaging supplies, and other materials in these racks at the time of the audit. Sugar dust was also observed on many of the Work-in Process collapsed Gaylord containers and empty pallets used in production. Many of the 1000 Gaylord totes of regrind/WIP totes of pasta in storage, some used for the packaging operations, had sugar dust on them as well. The site notified their customer of the sugar spillage and mitigation strategies involved to dust off any products prior to use in the packaging operations. There was no evidence of sugar on any opened products at the time of the audit.

 

I was with you through this thread, but from this perspective (acknowledging he incorrectly said February), I'm inclined to believe the major is warranted.  I was envisioning a small area where sugar had been spilled pretty much during the audit and your crews were actively working the small mess to rectify it.  But now it's just not making sense to me:  It happened over a month ago, plus somehow falling sugar bags were able to disperse sugar dust "on almost all storage racks, pallets of ingredients, packaging supplies," etc.?  This seems a lot more significant.  And I think the nail in the coffin is the dust being on packaging supplies along with your WIP material.

 

WIP should be protected from cross contamination with your own raw and finished materials.  Not only is that now a demonstratable concern, but you've got non-scope non-controlled ingredient contamination from over 4 pallet rows away.  Just because it was sugar today now doesn't mean a pallet of peanut powder can't be the next thing to fall from your co-renter's inventory.

 

In point 7, you list dust control is part of your sanitation schedule, and that your products and packaging generate significant dust.  Without knowing your operation, you should have management looking into better dust mitigation and prevention.  I was in spices, and we had dust collection hoods, flumes, tubes, all incorporated into the production areas and all over the equipment.  Mitigation is far better than sanitation, both in man hours and best practices to prevent cross contamination.

 

Again, none of us are on site nor have seen the issue for ourselves.  But if your auditor's written assessment is accurate beyond the incorrect month, product residue all over your side of the building from this spill for this amount of time is a valid finding to write a major for.

Edited by jfrey123, 07 November 2025 - 08:42 PM.

[GMO]

Yep, agree with the above that this now presents a different image.  While it wasn't February, it's still over a month and dust has spread throughout the warehouse.  I thought it was outside the warehouse from the original description and being immediately cleaned up the same day as the spill. 

 

Ultimately this feels like a change in process was not fully considered (e.g. with your HACCP team) when it was made, or insufficient controls were put in place. But likewise, it feels as though you have no sway over this tenant to get them to act.  It's unreasonable to not clean up the sugar in that timescale and safety is not an excuse.

 

The dust having spread more widely is a problem and the fact there is no pest activity yet is probably more due to the time of year (i.e. luck) than judgement.  Be thankful this didn't happen in summer and you end up with wasp and rodent activity.

 

So now to me, it's sounding like:

1. You have no comeback on this tenant sharing your space and collaboration has been poor.
2. They have been slow to act on food spillage.  VERY slow.
3. Dust has spread despite your clean up efforts, presumably because their resolution has been so slow.  Why are you putting up with it?

This is looking like a major to me.  This other company are a risk to your business.  I'd rethink the relationship if you can.

[KarrieC]

I was with you through this thread, but from this perspective (acknowledging he incorrectly said February), I'm inclined to believe the major is warranted.  I was envisioning a small area where sugar had been spilled pretty much during the audit and your crews were actively working the small mess to rectify it.  But now it's just not making sense to me:  It happened over a month ago, plus somehow falling sugar bags were able to disperse sugar dust "on almost all storage racks, pallets of ingredients, packaging supplies," etc.?  This seems a lot more significant.  And I think the nail in the coffin is the dust being on packaging supplies along with your WIP material.

 

WIP should be protected from cross contamination with your own raw and finished materials.  Not only is that now a demonstratable concern, but you've got non-scope non-controlled ingredient contamination from over 4 pallet rows away.  Just because it was sugar today now doesn't mean a pallet of peanut powder can't be the next thing to fall from your co-renter's inventory.

 

In point 7, you list dust control is part of your sanitation schedule, and that your products and packaging generate significant dust.  Without knowing your operation, you should have management looking into better dust mitigation and prevention.  I was in spices, and we had dust collection hoods, flumes, tubes, all incorporated into the production areas and all over the equipment.  Mitigation is far better than sanitation, both in man hours and best practices to prevent cross contamination.

 

Again, none of us are on site nor have seen the issue for ourselves.  But if your auditor's written assessment is accurate beyond the incorrect month, product residue all over your side of the building from this spill for this amount of time is a valid finding to write a major for.

The spill didn't happen all at once.  It tilted. They had to get a crew in to hand stack all of it very slowly so no one would get hurt.  Even then bags would slip off the top and bang. It took 3 weeks for them to clean up their issue.  Nothing was on WIP, pallets of ingredient, or packaging supplies. There was some dust on was on the Regrind/food waste totes sent to us (they are used) and in the bad pallets we pulled from use (sent to us by our customer) because they were not clean.  I have pictures of my racks. They are not covered in sugar. the "segregation barrier" was 2 rows, 12 pallets deep, 64 pallets wide.  We would not have let another allergen into the building.  Sugar was allowed because it is not an allergen.  We kept our side clean throughout the restacking process and had a couple of our employees help them sweep/vacuum.  Anyone know how to attach a picture here?    

[GMO]

I'm still not buying that there was not a safe alternative that took less than 3 weeks.  Sorry.  And any foodstuff is a risk even if it's not an allergen.  I agree with the major or at least I think you will struggle to argue it down to a minor. 

[Tony-C]

Anyone know how to attach a picture here?    

 

Hi Karrie,

 

To add a picture: From the more reply options page for this topic, follow the attached instructions.

 

 IFSQN Add Picture.jpg   135.63KB   0 downloads

 

Based on the information provided it would seem that rapid action and a deep clean was required, but this did not happen, so I wouldn't hold much hope of a successful appeal.

 

Kind regards,

 

Tony

Edited by Tony-C, Yesterday, 05:28 AM.

[ShaunD]

Not related, apart from trying to make an appeal.

I had an minor n/c raised during a BRC audit (about 12 years ago) that ended up becoming a critical. It was in relation to food contact materials and migration certificates. The auditor raised it as a minor as we had based our analysis on the previous legislation requirements for testing and not the current legislation requirements. I should note there was an 18 month transitional period for the testing, of which at least half was left. The results, during this period, could be based on either requirement. I accepted the n/c as it would not change the audit score at the time (think it was 5 or 6 minors).  

I was later contacted by the auditor who apologised and said the certification body had reviewed his findings and escalated it to a critical as we had not followed legislation.

I contacted them and pointed out the transitional period and that this meant the n/c should be removed.

They then contacted me again stating it was reduced to a major as I had not demonstrated that the items were hygienically fit for use.

I then shared our saitising procedure along with the records to demontrate compliance.

They again contacted me to state it would remain a major as we had not provided evidence that the supplier had been made aware of how we would use their items and what types of foods the items would be used for.

I didn't have this on file as we had been using these items for years and management had changed serveral times but I could easily get a written statement from the supplier to confirm they were fully aware of the intended use.

In the end, my Managing Director, told me to drop it and accept the n/c as a B grade was still a pass, and who knows where the certification body would go next.

 

This still annoys me to date.