SQF Code Version 7.2 NSF International May 20, 2014
SQF Code Version 7.2 Mike Govro, Technical QA Manager Part 1, Discussion of general changes, questions Part 2, Discussion of Unannounced audits and questions Please post your questions in the chat box This webinar is being recorded If you ask questions I can t answer, I will note them and provide answers in a follow up email
What Does 7.2 Mean to You? Details, I want details! Approximately 40 Changes were made to the Code Most changes are clarifications and do not represent operational changes for the supplier The most significant change is the implementation of unannounced audits
What Does 7.2 Mean to You? Details, I want details! Implementation Date: July 3, 2014 All audits must be conducted after July 3, 2014 will be to Edition 7.2, except Surveillance audits resulting from a C grade audit conducted to Edition 7.1 All initial certification audits conducted after July 3 must have had a desk audit conducted to Edition 7.2
Edition 7.2 Code Changes: Surveillance Audits Surveillance Audits Will Be Scored and New Rating will Apply, i.e. the database will reflect a new rating after the surveillance audit A supplier can now fail a surveillance audit, which will result in suspension of the supplier s certificate A new rating will not change the certification cycle
Edition 7.2 Code Changes Traceability Exercise is Required to be Performed During Audit. This requirement is in the Criteria for Certification Bodies, not the code. SQFI and the CB must be Listed as an Essential Contact in Elements 2.4.1.3 and 2.6.3.1 iv.
Edition 7.2 Code Changes SQFI and the certification body (NSF) must be notified within 24 hours upon identification of a food safety event that requires public notification (regulatory warning letter, recall) Contact NSF at recalls@nsf.org Contact SQFI at foodsafetycrisis@sqfi.com Exemptions of Products or Product Lines are Only Allowed when Written Justification is Provided
Edition 7.2 Code Changes Addition of foods containing allergens to the definition of high risk foods SQFI added allergens to the definition to raise awareness about the risks associated with allergens because allergens are associated with a large percentage of product recalls This apparently doesn t mean anything to how the audit will be conducted
Edition 7.2 Code Changes Enhanced the contract manufacturer requirement to require onsite audits for high risk producers, either by the supplier or a third party auditor to confirm compliance to the SQF Code and agreed arrangements Records of mock exercises must be maintained for product withdrawal and recall (2.6.3.4.) New: Module 14 Good Manufacturing Practices for Food Brokers and Agents
Edition 7.2 Code Changes: Seasonal Production Initial Certification Audit: will be conducted during the peak of the operating season Surveillance Audits: if no activity during the surveillance audit period, then a desk review of corrective actions will be performed Recertification Audits: If there is a change in the season, then the CB will temporarily reset the recertification audit window. SQF shall approve a permanent change in a recertification window
Clarification & Addition of Definitions See Appendix 2 Certification cycle The annual period between certification audits Customer A buyer or person that purchases goods or services from the supplier High Risk Food/Process includes allergens NA Element does not apply
Clarification & Addition of Definitions Onsite laboratories definition does not include QA activities such as brix, color analysis, viscosity, weight checks, etc. that do not pose a risk to products in production Unannounced audit new Rework Food, materials, and ingredients, including work in progress, that is clean, unadulterated and that has left the normal product flow and requires action to be taken on it before it is acceptable for release and is suitable for reuse within the process
Clarification & Addition of Definitions Exempt - A term applied to elements of the SQF Code that the supplier does not wish to be included in the SQF System assessment, and has submitted a written request to the certification body to exclude, prior to commencement of any scheduled audit activity, Mandatory elements in Module 2 cannot be exempted. The certification body may confirm the reasons for exemption during the facility audit The term also applies to products, processes or areas of the facility that the supplier wishes to exclude from the audit. A request must be submitted to the certification body in writing prior to the audit activity, and shall be listed in the facility description in the SQF assessment database
Unannounced Audits The unannounced audit will take place within the 60 day re-certification window (i.e., the anniversary date of the initial certification audit +/- 30 days.) Certified SQF suppliers will have one unannounced audit within the three year certification cycle. NSF will announce suppliers initial unannounced audit year by September 1, 2014.
Unannounced Audits (cont.) Suppliers may request a change in the initial unannounced audit year with justification. NSF will not conduct unannounced audits until 2015 except by supplier s request. The three year cycle for currently certified suppliers will be 2015-2017. Suppliers who had their initial certification audit in 2014 will not have an unannounced audit in 2015.
Unannounced Audits (cont.) NSF plans to conduct unannounced audits in approximately 1/3 of its certified facilities each year As a general practice, NSF plans to schedule unannounced audits on a every three years rotation, although the year can be changed at the supplier s request with reasonable justification
Unannounced Audits (cont.): Surveillance audits Surveillance audits will NOT be unannounced
Unannounced Audits (cont.): Blackout Dates A supplier may request blackout dates established by negotiation between the supplier and NSF to prevent the unannounced audit from occurring at a time when the facility is not operating
Unannounced Audits (cont.): Refusing an unannounced audit Immediate suspension of the certificate will occur in facilities that refuse entry to the auditor for an unannounced audit The facility will remain suspended until a recertification audit can be conducted The supplier will be required to have a surveillance audit after six months The following year s audit will be unannounced, and if this audit is in the subsequent three year cycle, two unannounced audits will be held in that cycle
Unannounced Audits (cont.) Multi-Site Suppliers are Exempted from Unannounced Audits. Multi-site suppliers are not suppliers with multiple locations If a supplier changes CBs, the supplier s recertification audit schedule will not change The unannounced re-certification audit will follow the protocol under the SQF Code, Part A, section 4.3 and 4.4. (This section describes how audits are conducted.)
Unannounced Audits (cont.): Audit Expectations The supplier should check the credentials of the auditor upon arrival The auditor will expect to hold an opening meeting within one half hour arrival The auditor will gather information about current operating conditions, e.g. products scheduled to be run, shift change times, available personnel, etc.
Unannounced Audits (cont.): Audit Expectations Auditor will formulate and provide a basic audit plan Auditor will request documents and records required for the audit Auditor will begin plant tour immediately after the opening meeting to allow supplier to gather the requested documents
Unannounced Audits (cont.): Audit Expectations The supplier should assure that backups for key personnel are adequately trained in the SQF system to provide information requested by the auditor The supplier should assure that the location of documents and records are known to backups and that they have access to these documents and records
Unannounced Audits (cont.): Products under scope not being run If products under the scope of certification are not run during the unannounced audit, the auditor will evaluate production of those products by records review and physical examination of areas and equipment used for those products if they are not in use The supplier will not be required to alter its production schedule to demonstrate production
Questions Post your questions in the Chat Box
Contact Information Michael Govro Technical QA Manager mgovro@nsf.org