Food Defense/Appeals Question
We recently had our annual SQF Fundamentals Edition 1 Manufacturing - Intermediate audit and received a non-conformance for Food Defense. 2.7.1.1 - The methods, responsibility and criteria for preventing food adulteration caused by a deliberate act of sabotage or terrorist-like incident shall be documented, implemented and maintained.
The reason given for the non-conformance is that we leave the front door and vestibule door unlocked. However, there is an alarm on the front door that chimes every time it is opened. Also, our Office Manager has a view of the parking lot from her desk and forewarns us about anyone coming to the front door or just in the parking lot unexpectedly. Our facility has 7 employees, making it very easy to identify any intruders. Finally, you have to walk through our lobby and office to get to our production area. Not to mention the fact that you have to know where our manufacturing area is. And before you mention disgruntled employees, it's been more than 2 years since we've fired anyone.
Our facility is very inconspicuous; you have to know where we are to find us. I've literally had to go into the parking lot to wave down food safety auditors so they could find us. In the 20 years that we've been in this facility, we've had 3 SQF auditors, 2 IDPH auditors, and 1 FDA auditor; none had any issues with our food defense mechanisms. Then we get a new SQF auditor who seems to expect us to maintain the same standards he saw working for giant food companies and wants us to lock the front door. We have customers who pick up orders and others who just drop in to visit us. All of them appreciate that they are welcome to show up unannounced to chat with us. When people visit us, they always stop in the lobby until they are greeted and welcomed into the office or sent away (as is the case with unsolicated sales people).
I feel like this food safety auditor was more interested in pushing his personal agenda of locked doors than in paying attention to the food defense measures we already have in place. Measures that we have shown to be successful. Is it unreasonable for me to appeal this non-conformance? I've never appealed a non-conformance before.
I used to do food defense breaches where I'd put a lab coat on and walk in with a hardhat (that said inspector on it ) and clipboard under my arm
With the exception of 2 times out of a hundred or so, I was never stopped - even with chimes on the door and somebody watching the door, and that reliance must account for bathroom breaks, etc.
Someone that intends to do damage to the interior of the facility will already know how to go from the open door, thru the office and into production.
I would suggest putting a remote controlled lock on the door and something like a Ring Camera with intercom - a little sign that says, for entry, ring bell and speak into the speaker.
By the way, most of our breaches were because the front door was unlocked (or a dock, shipping or exit door) and when available the door from the lobby to the front office areas was unlocked as well.
Why the others missed this I have no idea, but this Auditor was not over the top - it was good finding.
You can always appeal it, but I doubt it would go thru/
If you want to appeal just contact your CB contact and request the process as they may have their own format/form for you to complete and submit.