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Minor on 2.4.4.2 sampling and proficiency testing

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loveforfood

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Posted 11 October 2021 - 08:25 PM

Hello,

 

We just passed our unannounced SQF audit and one of the minors we got is that we don't have a testing program based on ISO/IEC 17025 for our analytical testing, product sampling and environmental sampling. We also don't have proficiency testing in place for the staff conducting the analysis.

 

Our company makes juices and the test that we perform for food safety is pH. We also swab for environmental testing and we send the swabs to a lab certified ISO 17025.

 

I have to change my sampling SOP and base it on ISO 17025. What are the requirements for sampling on ISO 17025? All I've been reading for now is pretty generic and can't find anything that I can use, so any insight or resources on that would be appreciated.

 

For the proficiency testing I'm trying to find a certified lab that does proficiency testing on pH but I'm not being very successful on that either. So far I've only found 1 lab in the US that does proficiency testing for pH on food. If you can share a link or a lab that you are using for that purpose I would appreciate that.

 

Thank you all for your help!

 

 

 

 



Charles.C

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Posted 11 October 2021 - 08:42 PM

Hello,

 

We just passed our unannounced SQF audit and one of the minors we got is that we don't have a testing program based on ISO/IEC 17025 for our analytical testing, product sampling and environmental sampling. We also don't have proficiency testing in place for the staff conducting the analysis.

 

Our company makes juices and the test that we perform for food safety is pH. We also swab for environmental testing and we send the swabs to a lab certified ISO 17025.

 

I have to change my sampling SOP and base it on ISO 17025. What are the requirements for sampling on ISO 17025? All I've been reading for now is pretty generic and can't find anything that I can use, so any insight or resources on that would be appreciated.

 

For the proficiency testing I'm trying to find a certified lab that does proficiency testing on pH but I'm not being very successful on that either. So far I've only found 1 lab in the US that does proficiency testing for pH on food. If you can share a link or a lab that you are using for that purpose I would appreciate that.

 

Thank you all for your help!

 

Hi lff,

 

I presume you refer to this -
 

2.4.4.2  Product analyses shall be conducted to nationally recognized methods or company requirements, or alternative methods that are validated as equivalent to the nationally recognized methods.

Where internal laboratories are used to conduct input, environmental, or product analyses, sampling and testing methods shall be in accordance with the applicable requirements of ISO/IEC 17025, including annual proficiency testing for staff conducting analyses.

External laboratories shall be accredited to ISO/IEC 17025, or an equivalent international standard, and included on the site’s contract service specifications list
(refer to 2.3.2.11)

 

.

I suggest you study the detailed SQF9 Guidance on proficiency testing. The Standard is, semantically, rather poorly stated IMO.

 

Also note the Standard's textual distinction between requirements for internal/external labs.

 

Also see -

 

https://www.ifsqn.co...cy/#entry176376

https://www.ifsqn.co...42/#entry176470


Edited by Charles.C, 11 October 2021 - 08:52 PM.
added

Kind Regards,

 

Charles.C


JPresswood

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Posted 13 October 2021 - 11:26 AM

Hello!

 

EPTIS is a great database for finding PT providers for the testing you are looking for. I do know that LGC AXIO Proficiency Testing has pH available as an analyte in several of their programs, including their juice program.



loveforfood

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Posted 15 October 2021 - 01:35 AM

This is the Minor NC:  "Facility does not have testing program based on ISO/IEC 17025 for their analytical testing, product sampling, and environmental sampling. There is no proficiency testing for staff conducting analysis."

 

I want to do the proficiency testing on the pH, since it is our food safety parameter. Based on the SQF guidance, would it be accepted if I use an external lab with ISO 17025 certification that has pH in their scope and I send them a duplicate of a sample to test pH and I test the other duplicate for pH as well? I have to submit my corrective actions before November 4th and I'm struggling to find a lab that conducts proficiency testing before that date.

 

In addition to that I have to adapt my sampling program to ISO 17025. We normally pull a sample from each batch produced plus 2 additional ones as retain, no matter what the size of the batch is. Where can I find a table or a procedure for sampling that can be accepted ?

 

Thank you again for all your help!



Charles.C

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Posted 15 October 2021 - 03:16 AM

This is the Minor NC:  "Facility does not have testing program based on ISO/IEC 17025 for their analytical testing, product sampling, and environmental sampling. There is no proficiency testing for staff conducting analysis."

 

I want to do the proficiency testing on the pH, since it is our food safety parameter. Based on the SQF guidance, would it be accepted if I use an external lab with ISO 17025 certification that has pH in their scope and I send them a duplicate of a sample to test pH and I test the other duplicate for pH as well? I have to submit my corrective actions before November 4th and I'm struggling to find a lab that conducts proficiency testing before that date. (see PPS and also note the Standard's precise text)

 

In addition to that I have to adapt my sampling program to ISO 17025. We normally pull a sample from each batch produced plus 2 additional ones as retain, no matter what the size of the batch is. Where can I find a table or a procedure for sampling that can be accepted ?

 

Thank you again for all your help!

Hi Lff,

 

IMHO you are probably over-thinking this issue.

If the auditor's comment was in respect to your using an external laboratory, the comment IMO was not in accord with the Standard. Was it ??

 

Did you read the Guidance's sampling comments ? The Guidance material is not auditable but attempts to interpret/respond to the major intentions of the Standard's text. Unfortunately it, perhaps inevitably, tends to overkill the typical auditorial expectations (Note the caveat terms sprinkled within the text). I anticipate (SQF users are welcome to correct me) that the auditorially required sampling scheme is much simpler than you are now envisaging but nonetheless increased from yr current (insufficient IMO) procedure.

 

As per my previous comments - The Standard's text regarding "proficiency" is semantically questionable (see the links in post2). Also note the word "applicable". (Also, sadly, note the boo-boo in 1st line of Guidance Pg2).

 

SQF unfortunately have a track record in reluctance to correct their occasional mis-statements/semantic fallibilities. Their new, split, "Guidance" System seems to  be accentuating these deficiencies.

 

PS - Haven't checked the Standard but I was under the impression that Labs which are ISO17025 accredited MUST have shown evidence of routinely carrying out Proficiency testing ?? (It's a fundamental activity IMO).

 

.


Kind Regards,

 

Charles.C




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