13 replies to this topic

[LostInTheWoods]

Hey, we're facing an extended downtime where we won't be producing food for business reasons. We're contractually obligated to maintain production readiness (including SQF Certification). The current forecast is that we'll be down for longer than we can extend our certification window, so our cert will be withdrawn then we'll go through a new certification process when we resume.

 

Has anyone ever faced a situation like this? How have you handled required elements during these?

 

I'm keeping the EMP going, and having CAPAs with findings. But items like Management Review, and Internal Audits don't really seem applicable. As we approach restart, we'll need a ramp up period to restaff operations and engineering (currently people have been transferred to other manufacturing areas). I plan on reinstituting those types of activities when we get a firmer date on production restart.

 

Anything that I'm missing here? Any specific traps we may walk into.

[SQFconsultant]

Yes.

You provide the reasons for the temporary shut down and request a temporary withdrawal ONLY, keeping the certification in place -  you run everything including internal audits, etc documenting on a daily basis the shutdown.

 

That way you don't have to go thru a completely new certification unless of course you want to.

[LostInTheWoods]

Yes.

You provide the reasons for the temporary shut down and request a temporary withdrawal ONLY, keeping the certification in place -  you run everything including internal audits, etc documenting on a daily basis the shutdown.

 

That way you don't have to go thru a completely new certification unless of course you want to.

Our CB did not present that as an option. We were able to bump our cert window out 6 months, but that was the max allowed by SQF. When we got close and were beyond the point where we would have been able to do all the pre-startup work prior to hitting the extended window, they advised that we can't keep it and that we'd have to go through a new certification process as production resumes.

 

I haven't seen anything in Part A that provides for temporary withdrawal. Our Internal Audit was in August of 2025, so we'd be able to stay within the 12 month window there, and the shutdown has been well documented.

[GMO]

Have you already started the shutdown? Could you have your audit early?

[G M]

You have some extra concerns on top of this with renewal, but to handle the issue of loads of documents saying you're going to do X at Y frequency then all of a sudden not doing that, we address that in our safety and quality programs by starting with a 'disclaimer' type of policy that creates a method for suspending the activities described in other documents, as long as you have records clearly stating when the interruption begins and ends:

 

Due to maintenance or supply or demand interruptions this facility may not be engaged in production activities for an entire shift or weeks at a time.  When this interruption occurs, personnel will not perform sanitation, monitoring, or verification activities at the frequencies stated in the individual policies.  Those frequencies were developed based on [standard schedule].

 

There may also be instances of partial operation, in which product is only [process A] (not [process B or C]), and frequencies of sanitation, monitoring, and verification affecting those areas not in use will not be followed at those times.

 

Records covering a period of time in which production ceases early or has a delayed start will be noted with a statement indicating such an event has occurred, such as “End of Production” or “No Production”, in lieu of the standard complement of observations.  

 

We've used this for things ranging from a few minutes to several weeks, one production line, one room or department, or a whole building, and dozens of inspectors and auditors have seen it, with no push back.  It simply creates another 'loop' of "say what you will do, do what you say" that lets you not operate at full capacity.

[Tony-C]

Hi LostInTheWoods,

 

Be interesting to know how long you have been and are likely to be shutdown?

 

Kind regards,

 

Tony

[LostInTheWoods]

Hi LostInTheWoods,

 

Be interesting to know how long you have been and are likely to be shutdown?

 

Kind regards,

 

Tony

Internal Audit August 2025

Management Review September 2025

We went down in October 2025.

Unannounced audit window Nov-Dec 2025.

Notified CB, and got a 6 month extension, so new window was May-June 2026.

Restart date is currently unknown, Q4 2026 at the earliest.

 

Originally, the plan was to start up in time for the new window. We've estimated minimum 8 weeks lead time to restart (make sure the equipment still functions correctly, clean out our water systems, recall and retrain operators, re-validate CIP). During the downtime, we have been performing EMP and our GMP/Glass and brittle inspections.

 

We have documented our restart plan/checklist. We plan on re-doing our initial equipment acceptance tests and revalidating our CIP process.

Edited by LostInTheWoods, 07 May 2026 - 11:13 AM.

[Scampi]

So you're saying the facility will be done for roughly 1 year    assuming this is for major retooling and/or changes to the facility itself??  You'll need a full PCP and HACCP review

 

Also, SQF is very clear on certification duration

SQF certification is valid for one year.

 

So since you've request an extension already  AND the facility is still closed, you will have to start at the beginning again

[GMO]

A shutdown for that long is essentially a different plant opening up. I'm guessing your operations people have left for other jobs? You'll have done vast amounts of maintenance and a huge amount of change, if not, why shut down so long? Why would it not be right to recertify? It is going to be pretty much starting from scratch.

[LostInTheWoods]

So you're saying the facility will be done for roughly 1 year    assuming this is for major retooling and/or changes to the facility itself??  You'll need a full PCP and HACCP review

 

Also, SQF is very clear on certification duration

SQF certification is valid for one year.

 

So since you've request an extension already  AND the facility is still closed, you will have to start at the beginning again

It's not for a major retool. There are business/commercial issues with our only food customer. There are no planned processing, equipment, or facilities changes. PCP/HACCP plan will still be reviewed per the annual schedule.

 

My biggest question is related to the timing of the Internal Audit. Is it worth performing it in August just to keep the annual requirement if 1) there's no production occurring, AND 2) we don't have an active cert?

 

The alternative would be for example of a November restart:

November begin production

December Internal Audit (16 months)

January Management Review (16 months)

January SQF "new" certification

 

I would argue that the latter is more valuable, as the internal audit can look at actual production and records. We would glean more useful, actionable information from that audit. It just wouldn't fulfill the annual requirement. I would argue that the pause renders that moot, but would most auditors share that opinion?

[LostInTheWoods]

A shutdown for that long is essentially a different plant opening up. I'm guessing your operations people have left for other jobs? You'll have done vast amounts of maintenance and a huge amount of change, if not, why shut down so long? Why would it not be right to recertify? It is going to be pretty much starting from scratch.

 

We are a diversified manufacturing company that has a small food operation. Operations, maintenance, and engineering have been reassigned to other production areas. They would be recalled (and undergo required re-trainings) when decision is made to start up.

 

The length of the shutdown is related to commercial issues with our only food customer (who has an exclusivity contract with us).

[MDaleDDF]

 I would argue that the pause renders that moot, but would most auditors share that opinion?

Probably not....

[Scampi]

You really need to reach out to your CB for direction............only they can assist in how you proceed----after all it's them sticking their necks out on this certification

[GMO]

We are a diversified manufacturing company that has a small food operation. Operations, maintenance, and engineering have been reassigned to other production areas. They would be recalled (and undergo required re-trainings) when decision is made to start up.

 

The length of the shutdown is related to commercial issues with our only food customer (who has an exclusivity contract with us).

 

Then you will still have had employees who have not made food in over a year. I'm sorry but as you didn't choose to bring your certification forward before the shutdown, I don't see how you have anything else you can do?