Dear Snookie,
Thks for the feedback. I think I understand yr OP more clearly now. Not a user of SQF myself but i will try to roll the ball a little.
I presume we are talking about (essentially harvested/unprocessed) primary production of fruit/vegetables at the beginning of the process to reach the transition point from pre-farmgate to post-farmgate stage. ?
The ( ver.7/2012) para which you mention is (slightly expanded) -
2.3.2.4 Raw and packaging materials and ingredients shall be validated to ensure Product safety and quality is not compromised and the material is fit for its intended purpose. Validation of raw materials and ingredients shall include certificate of conformance; or certificate of analysis; or sampling and testing.
2.3.5.1 Finished product specifications shall be documented, current, approved by the supplier and their customer, accessible to relevant staff
and may include:
i. Microbiological and chemical limits;
ii. Labeling and packaging requirements;
and
iii. Product quality attributes.
2.3.5.2 A register of finished product specifications shall be maintained.
For context I include below (minus packaging related) the corresponding paras of the previous (now obsolete) sqf 1000/2000 codes. I presume you were using 1000.
(1000)
4.3.1.1 Specifications for raw materials purchased that impact on finished product safety and quality shall document and keep current.
4.3.1.2 A register of raw material specifications shall be maintained.
4.3.4.1 Finished product specifications shall be documented, current, formally agreed with the customer, and accessible to relevant employees.
4.3.4.2 A register of finished product specifications shall be maintained.
4.4.1 Food Legislation (Regulation)
The Producer shall ensure that, at the time of delivery to its customer, the product supplied shall comply with the food safety legislation that applies to the product and its production in the country of its origin and destination.
(2000)
4.3.2.1 Specifications for raw materials and ingredients that impact on finished product safety and quality shall be documented and kept current.
4.3.2.2 A register of raw material specifications shall be maintained.
Note: Raw materials include but are not limited to additives, hazardous chemicals and processing aids.
4.3.6.1 Finished product specifications shall be documented, current, approved by the supplier and their customer, accessible to relevant staff
and include:
i. Microbiological and chemical limits;
ii. Labeling and packaging requirements;
and
iii. Product quality attributes.
4.3.6.3 A register of finished product specifications shall be maintained.
It appears that SQF are “struggling” to put together an appropriate, modernistic (eg "validation"
), all-in-one combo text. Not surprising to experience some difficulty in view of the rather different scenarios / scopes involved.
I suspect that the word “testing” is intended to match the "validation" requirement assuming that the other offered alternatives are not available. If so, yr idea of a temperature check may be (somewhat) insufficient.
I hv previously encountered (non-SQF) complications of this sort when purchasing raw, unprocessed seafood. Was able to manouevre via the approved supplier route using mutually agreed raw material specifications (which i assume you must already have) and some (very) basic organoleptic measurements by the supplier. Micro.measurements for received input lots were (technically) out of the question and this is surely a common scenario.
(I agree with you that many micro.textbooks consider that micro.regs for earthy produce are not meaningful however in view of the absence of later bactericidal elimination steps plus pathogen problems of recent years this might now be a more sensitive issue. As you say, for some well-known leafy products, testing / special pathogen control procedures are already implemented.)
What was SQF's previous viewpoint for the raw material used as input for
postgate processing - any micro.data expected ?? Hopefully not.
I am guessing that other people here must surely hv already faced this question ? Or is everyone a guinea pig for SQF at the moment ?.
Rgds / Charles.C