Tuesday, February 25, 2020

What is SQF? - Part II

The SQF Certification
If any organization is interested in achieving SQF certification as an independent initiative or because of a customer requirement, the site has to prepare and implement a fully integrated food safety management system that complies with SQF requirements according to the food sector category stipulated by SQFI. After implementation of the system, organization shall undergo a SQF certification audit where site required to have an agreement with a certification body which outlines the SQF audit and certification services including, but not limited to;
The scope of certification;
The expected time to conduct and finalize the audit and the reporting requirements;
The certification body’s fee structure;
The conditions under which the SQF certificate is issued, withdrawn or suspended;
The certification body’s appeals, complaints and disputes procedure.
The accredited certification agencies are listed in the SQFI assessment database for the convenience of the users if anyone need them and once sites get registered site can request a quote or select a certification body online.

Pre-assessment Audit
A pre-assessment audits or mock audits are not mandatory as they are expensive options, but it is very useful in understanding the real achievements in the site level or it will provide a "health check" of the site’s implemented SQF Food Safety System. A pre-assessment audit will help in identifying gaps in the site’s SQF Food Safety System so that corrective action can occur before engaging a full certification audit, which can be conducted using internal resources, a registered SQF consultant, or a registered SQF food safety auditor.

The Desk Audit
For any initial certification of a site, the assigned certification body will conduct an independent desk audit. The desk audits are conducted by the registered SQF food safety auditors who is appointed by a certification body, to ensure that the site has appointed an appropriately qualified SQF practitioner and the food safety plan and the associated critical control point (CCP) determinations, validations and verifications are appropriately documented and endorsed by the SQF practitioner. The desk audit highly focus on the documentation system and reviewed for its relevance to the scope of certification. The site will be notified for corrections or corrective action, or any aspects of the SQF food safety system that requires improvement or adjustment by the certification body. They will also verify that corrections or corrective action for all non-conformities have been addressed before proceeding with a site audit. Desk audits are not scored or rated and the close out times are indefinite until the certification date is decided.  

The Site Audit
The site audit is the most important event of the certification process, where site audit is conducted by the SQF food safety auditor appointed by the agreed certification body, which is conducted at a time agreed between the site and the certification body when the main processes are operating. The site audit basically include a review of the entire site, including the inside and outside of the building, regardless of the scope of certification and agreed exemptions. Nonetheless, site audit will also include a review of all operational and cleaning shifts and pre-operational inspections, where applicable. The site audit determines if the SQF system is effectively implemented as documented, which establishes and verifies:
Effectiveness of the SQF food safety System in its entirety;

Food safety hazards are effectively identified and controlled;
Effective interaction between all elements of the SQF System;
Level of commitment demonstrated by the site to maintaining an effective SQF System and to meeting their food safety regulatory and customer requirements;
The exempted products or areas of the site do not pose a food safety risk to the products covered under certification.

All applicable system elements and the relevant GMP module (s) are evaluated as part of the certification audit. However, if an element is not applicable and appropriately justified with relevant documentation, it will be stated as "not applicable" (N/A) by the SQF food safety auditor in the audit report.

SQF System Elements
The SQF systems are basically segregated into pre-farm gate or post farm gate. Thereafter, the manufacturing code is further segregated based on whose primary function is the pre-processing of plant and animal products and the manufacture of food, pet food, or animal feed (food sector categories 4, 7 – 22, 25, 31-34). Except for section 2.8 Allergen management, “food” can also be taken to mean “pet food" or “animal feed”; “food safety” can be taken to mean “pet food safety” or “feed safety,” and “food safety plan” can be taken to mean “pet food safety plan” or “feed safety plan.” Modules 3, 4, 9, 10 and 11 are the individual modules that describe the Good Manufacturing Practices (GMP) requirements applicable to the various food industry sectors based on specific guidance, where each individual site must meet the requirements of the module or modules applicable to its food industry sector.

On the other hand, there are mandatory system elements within the system elements, that cannot be reported as “not applicable” or “exempt” and must be audited and compliance/non-compliance reported as a mandatory exercise.

Mandatory elements are acknowledged with “Mandatory” in the system elements in the SQF Food Safety Code for Manufacturing, System Elements. The mandatory elements are listed below with the clause numbers represented in the SQF 8.1, Food Safety Code for Manufacturing;

2.1.1 Food Safety Policy
2.1.2 Management Responsibility
2.1.3 Management Review
2.1.4 Complaint Management
2.2.1 Food Safety Management System
2.2.2 Document Control
2.2.3 Records
2.4.1 Food Legislation
2.4.2 Good Manufacturing Practices
2.4.3 Food Safety Plan
2.4.4 Approved Supplier Program
2.4.7 Product Release
2.5.1 Validation and Effectiveness
2.5.2 Verification Activities
2.5.3 Corrective and Preventative Action
2.5.5 Internal Audit
2.6.1 Product Identification
2.6.2 Product Trace
2.6.3 Product Withdrawal and Recall
2.7.1 Food Defense Plan
2.8.1 Allergen Management for Food Manufacturing (mandatory for food manufacturers only)
2.8.2 Allergen management for Pet Food Manufacturing (mandatory for pet food manufacturers only)
2.9.2 Training Program
  
Non-conformities
SQF food safety auditor evaluates the deviations from the standard requirements of relevant modules of the SQF Food Safety Code relevant to the site, and auditor will also advise the site of the number, description, and extent of the non-conformities or non-conformances. Non-conformities against the SQF Food Safety Code are graded as follows:
A minor non-conformity is an omission or deficiency in the SQF system that produces unsatisfactory conditions that if not addressed may lead to a risk to food safety but not likely to cause a system element breakdown.
A major non-conformity is an omission or deficiency in the SQF system producing unsatisfactory conditions that carry a food safety risk and are likely to result in a system element breakdown.
A critical non-conformity is a breakdown of control (s) at a critical control point, a pre-requisite program, or other process step and judged likely to cause a significant public health risk and/or where product is contaminated.

Nonetheless, SQF auditor may raise a critical non-conformity, if the site fails to take effective corrective action within the timeframe agreed with the certification body, or if the certification body deems that there is systemic falsification of records relating to food safety controls and the SQF System. Certification also requires that all major and minor non-conformities are closed out within thirty (30) calendar days.

Audit Score and Rating
Each applicable aspect of the SQF certification audit is automatically scored in the audit
report based on the evidence collected and entered by the SQF food safety auditor, but desk audits are not scored.

The calculation uses the following factors:
0 aspect meets the criteria
1 aspect does not meet the criteria due to minor variations (minor non-conformity)
10 aspect does not meet the criteria (major non-conformity)
50 aspect does not meet the criteria (critical non-conformity)

A single rating is calculated for the site audit as (100 – N) where N is the sum of the individual rating criteria allocated. The rating provides an indication of the overall condition of the site against the SQF Food Safety Code, and also provides a guideline on the required level of surveillance by the certification body. Nonetheless, audit rating affects the frequency of audits where audit frequency at each rating level is indicated as follows:

Score               Rating                           Certification                 Audit Frequency
96 – 100          E – Excellent                 Certificate issued        Annual re-certification audit
86 – 95            G – Good                      Certificate issued         Annual re-certification audit
70 – 85            C – Complies               Certificate issued         Biannual surveillance audit
0 – 69              F – Fails to comply      No certificate issued   Considered as failed the SQF audit

If a site achieves an “F – fails to comply” rating at a certification audit, the site is failed the SQF food safety audit, where site must then re-apply for another site audit. When the site's re-application occurs within six (6) months of the last audit date, and with the same certification body, a site audit shall be scheduled, but a desk audit is not required. If the re-application occurs after six (6) months from the last audit date, or with a new certification body, then a desk audit and site audit are required.

Maintaining Certification
To maintain SQF food safety certification, a site is required to achieve at least a “C - complies” audit rating or greater at recertification audits, while ensuring the surveillance and/or re-certification audits occur within the required timeframe, and no critical non-conformities are raised at surveillance or re-certification audits. In addition, site must correct all major and minor non-conformities raised during the audits within the time frame specified. All re-certification audits are usually considered announced unless otherwise indicated as unannounced on the audit report and certificate.

However, the certification body must conduct one (1) unannounced re-certification audit of the site within three (3) certification cycles, where unannounced food safety audit will occur within the sixty (60) day re-certification window (i.e., the anniversary date of the initial certification audit +/- thirty (30) days). Hence, SQF sites must be required to undertake one (1) unannounced audit within the three (3) year certification cycle.

When the site certificates are suspended or withdrawn, the certification body shall immediately amend the site details on the SQFI assessment database to a "suspended" or “withdrawn” status indicating the reason for the suspension/withdrawn and the date of effect.

Few Important Remarks  
When comparing with ISO 22000:2018, and even in the ISO 22000:2005 version, the technical committees has put many efforts to improve CODEX Alimentarius HACCP into more of a their own version with OPRPs instead of CPs which are actually unclear area of codex HACCP. As an ISO 22000:2018 further deviated from the HACCP by introducing a Hazard Control Plan which included preventive controls instead of a HACCP plan that more closely aligned its requirements towards FSMA. But SQFI never touch the codex principles and even when FSMA was signed what SQFI further did was, it added a preventive control plan to match their requirements through food legislation to address FSMA within SQF where necessary.

On the other hand, SQF code is a comprehensive document, which describe each and every requirement down to the very simple activity level, where its simplicity to understand doesn’t undermine the complex requirements required by the standard. In comparison to ISO 22000:2018, which ask for bare minimum requirements as mandatory, while it has explained in a more complex reader unfriendly technical language, and also spread across ISO 22001 – n with separate sister modules with loose binding, but SQF has them together in bundles based on industry categories with mandatory elements. However, ISO 22000:2005 and its sister modules do not undermine its value in the overall standard as they are more approachable to the small and medium scale businesses and developing countries based on the inaccessible registration fees, audit fees, unbearable additional costs on infrastructure and unannounced audits embedded into all the private standards. Hence, if a company does not have a specific customer with a specific requirement asking for a SQF certification as supplier registration requirement, many companies outside the North America are reluctant to certify with private standards such as SQF, BRC, FSSC, etc.

As to the same viewpoints, if anyone applies all the comprehensive requirements required under the ISO 22000:2018 with its sister technical modules, there will be very slight difference to their audit results. Nevertheless, SQF will provide a more specific separation of facilities while frequently auditing them if necessary and auditing has been more rigorously considered in their quest to food safety. But ISO 22000 is considering to empower the organization and trying to provide more freedom for the manufacturer to decide on requirements and take more control over their own responsibility rather than audits.

Reference:
The SQF food safety Code, Edition 8.1

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