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SQF Certification for Food Packaging Plants
Dr. Bob Strong - Senior Consultant - SAI Global (Americas)
April 2014
Our Presenter Today Dr. Bob Strong • Senior Consultant – SAI Global Assurance Services
• Ph.D. and BSC in Chemistry and an accomplished food safety trainer for numerous food safety manager certification courses
• Driving force behind our food safety operations in the areas of Good Manufacturing Practice (GMP), Good Agricultural Practice (GAP) and supplier assurance programs, including SAFE, SQF and BRC
• 44 years of experience in the food industry, while working for national and international companies in quality assurance, product development and auditing. He is an oft-requested seminar speaker in the areas of GMP and HACCP
• In addition, he is a GMP/HACCP instructor, a Lead Auditor trainer, and is also certified to consult on the Global Food Safety Initiative by SQF. Dr. Bob is certified in 20 product categories.
Agenda • What is GFSI? • What is SQF? • Road to Certification for Packaging Plants • Mandatory requirements • Exemptions, when applicable • How to apply for a Variance • Module 2 requirements • Module 13 requirements • Scoring numerical and grade • Road map to Certification • Q&A
Global Food Safety Initiative
Global Food Safety Initiative (GFSI) Started by CIES (The Food Business Forum) in Paris in 2000
• Now called the Consumer Goods Forum (CGF) • 400 members, 150 countries • Non-profit foundation
Focus is a simple set of rules for accepting different standards, establishing harmony between countries & auditing efficiency by:
• benchmarking food safety standards worldwide • facilitating cooperation between standard owners • assurance of quality of certification & accreditation
Global Food Safety Initiative (GFSI ) The GFSI guidance document sets the minimum
requirements for: • Food Safety Management Systems • GMPs, GAPs, GDPs • HACCP • Delivery of Food Safety Management Systems
All standards to get approved must meet these minimum requirements in the GFSI guidance document
Standards owners can go above and beyond the requirements to add value
GFSI Vision Initially was Once certified, Accepted Everywhere
Is now Safe Food for Consumers Everywhere
Mission: Driving continuous improvement in food safety to strengthen consumer confidence worldwide
Reduce food safety risks Manage cost
Develop competencies and capacity building
Knowledge exchange and networking
GFSI
Initial Companies Involved with GFSI in 2000 • Albertson’s • Campbell’s • Carrefour • Danone • Delhaize (Food Lion,
Hannaford) • Hormel • Kroger • Metro AG
• Migros • Royal Ahold • Sara Lee • Tesco (Fresh and Easy) • Tyson • Wakefern • Wal-Mart
Governance: GFSI Board of Directors
Providing strategic direction and supervision of GFSI, and governance to the GFSI Technical Working Groups
Chair Vice-Chairs
Board Members
Nestle
Convergence Means Confidence Benchmarking work was originally carried out in 2000 on four
food safety schemes (BRC, IFS, Dutch HACCP and SQF) to reach a point of convergence.
All of the 9 currently approved schemes are completely aligned with the GFSI Guidance Document Version 6 Requirements issued in 2011.
GFSI Guidelines will be reviewed again in 2014 for possible updating
GFSI Benchmarked and approved schemes
SQF Code Edition 7.2
About SQF (Safe Quality Food) Originated as an Australian standard in 1994
Purchased by FMI in 2004 and is now operated by the Safe Quality
Food Institute in the United States
One of the first 4 Schemes approved by GFSI in 2004
3 Certification Levels
Only Scheme offering a Quality Level over and above Food Safety
Current Edition is 7.1 and is available for free from www.sqfi.com
Edition 7.2 will be effective on July 3rd 2014
SQF Levels of Certification
Level 3
Level 2
Level 1
Level 1 • Food Safety Fundamentals (Pre-requisite programs) +
Building and Equipment
Level 2 • Adds in the Food Safety Plans (HACCP) • Element 2.4.3 (GFSI Approval level)
Level 3
• Adds in the Food Quality Plans • Element 2.4.4 (Above GFSI approval requirement)
3 Levels of Certification
Initial Certification Process requires two separate audits: • Desk/Document audit (Readiness audit) • Facility Audit
Recertification annual audits only require 1 audit which is a combination of both.
SQF has products and services divided into 35 Food Safety Categories (FSC) of which Category 27 is “Manufacture of Food Sector Packaging Materials”.
SQF Initial Certification Audits
SQF Initial Certification Audits Desk/document audit is a review of all your documented programs, policies and procedures as required by the SQF Code for manufacturers of food packaging materials. Hence this is a review of what you say you do. This can be done on site or at a mutually agreeable location and is a non-graded evaluation. All deficiencies in the documentation identified in this review have to be corrected before the auditor can return to conduct your facility audit. In future years there is no separate document review.
SQF Initial Certification Audits Facility audit is an audit of your total facility as to compliance with these documented programs, policies and procedures. The auditor looks at your equipment, building, processes, records, etc. and this is a graded evaluation. Hence this is to see if you do what you say and can prove it. All deficiencies in this audit cause you to lose points and require that they all be corrected before the Certifying Body can issue you your SQF Certificate.
Requires an SQF Practitioner Employed by the Supplier • In a full-time at the facility being certified • In a position to manage the program
HACCP Knowledge • Have completed a HACCP Course • Be competent to implement & manage HACCP plans
SQF Code Knowledge • Be competent to implement & manage SQF Programs • Taking “Implementing SQF Systems” Course (highly recommended) • Taking and passing the “Implementing SQF Systems” on-line exam
(highly recommended)
SQF Code requires that you Say what you do in writing
Do what you say
Have the records to prove it
SQF Code requires You meet the regulatory requirements of the Country in which
you operate as well as to those of each country that you sell your product to.
That you meet your Customer requirements.
That you comply with the current edition of the SQF Code.
That you practice Continuous Improvement.
SQF Code requires that packaging manufacturers Comply with the requirements of the following SQF Modules:
• Module 2: SQF System Elements • Module 13: Pre-requisite programs for the manufacturing
of Food sector packaging
Mandatory Elements These are SQF sub-elements that are required to be documented and implemented by everybody.
• Cannot be excluded by the facility applying for certification • Cannot be exempted by the Certifying Body • Cannot be marked non-applicable (NA) by the auditor
Applies to Module 2 only
Mandatory Elements (20) 2.1.1 – Management Policy 2.1.2 – Management Responsibility 2.1.3 – Food Safety and Quality Management System 2.1.4 – Management Review 2.2.1 – Document Control 2.2.2 – Records 2.4.1 – Food Legislation 2.4.2 -- Food Safety Fundamentals 2.4.3 – Food Safety Plan (levels 2, 3) 2.4.4 – Food Quality Plan (level 3 only)
Mandatory Elements (20) 2.4.8 – Product Release 2.5.2 – Validation and Effectiveness 2.5.4 – Verification and Monitoring 2.5.5 – Corrective and Preventative Action 2.5.7 – Internal Audit 2.6.1 – Product Identification 2.6.2 – Product Trace 2.6.3 – Product Withdrawal and Recall 2.7.1 – Food Defense 2.9.2 – Training Program
SQF Code possible exemptions
Certain sub-elements in these Modules however may not be applicable to you and so they will not apply
If you only go SQF Level 2 then the following sub-elements do not apply and the SQF auditor will not expect you to provide any evidence (programs or records) for these sub-elements.
These sub-elements will apply if you apply for certification at Level 3:
2.4.4. Food Quality Plan 2.8.1. Identity Preserved Foods
SQF Code possible exemptions Certain sub-elements in these Modules may not be applicable and if so then they will also not apply.
The following sub-elements may not apply to your facility and the auditor will agree if you provide evidence that they do not.
2.3.4. Contract Manufacturer program 2.4.7. Rework program 2.8.2. Allergen Management program 13.5.4. Air Supply 13.6.4. Alternate Storage
The SQF Code
SQF System Elements Module 2
Terms Used in Module 2
“Food” also means “feed,” “pet food,” or
“food contact packaging materials.”
Module 2 – Elements Overview 2.1 – Management Commitment 2.2 - Document Control and Records 2.3 – Specification and Product Development 2.4 – Attaining Food Packaging Safety 2.5 – SQF System Verification 2.6 – Product Identification, Trace, Withdrawal and Recall 2.7 – Site Security 2.8 – Identity Preserved Foods 2.9 – Training
Module 2 defines management-level commitments including Statement of management’s commitment to provide safe, quality
food packaging Designation of an SQF practitioner Creation and documentation of organization’s food safety plans (Level 2) and quality plans (Level 3) Addressing non-conforming products and equipment
Module 2 defines management-level commitments including Development and execution of an internal audit process.
Documentation and implementation of a food defense program.
Creation of systems to address food allergens, if applicable.
Execution of an effective and appropriate training program.
2.1 Management Commitment - Overview
2.1.1 – Management Policy (M) 2.1.2 – Management Responsibility (M) 2.1.3 – Food Safety and Quality Management System (M) 2.1.4 – Management Review (M) 2.1.5 – Complaint Management 2.1.6 – Business Continuity Planning
Each Module 2 element contains sub-elements
2.1 Management Commitment (M) Success of your SQF System is contingent upon: A signed commitment by Senior Management at your facility to:
• Implement and maintain an effective SQF System • Support ongoing improvement • Provide adequate resources
2.1.6 Business Continuity Management Documented program that:
• Defines the handling of a potential business crisis that may
impact ability to deliver safe, quality food packaging • Prepared by senior management • Defining methods and responsibility • Risk assessment of each type of crisis • Crisis management team (a top nonconformity)
2.1.6 Business Continuity Management
• Includes controls implemented so product safety and quality not compromised
• Includes isolation and identification of affected product • Verification of product prior to release • Crisis alert contact list • Sources of legal and expert advice • Internal and external communications • Annual review – testing + verification (One of top nonconformities) • Records • Product withdrawal and recall
2.2.1 Document Control – Registers to be Maintained 2.2.1.1 SQF System Documents and Amendments 2.3.2.6 Raw and Packaging Materials Specifications and Labels 2.3.3.2 Contract Service Providers and Specifications 2.3.5.2 Finished Product Specifications
2.2.1 Document Control - Registers to be Maintained 2.4.5.5 Approved Suppliers and Records of Inspections and Audits of Suppliers 2.8.2.1 Allergens (if applicable) 2.9.7.1 Training Skills Register 3.2.9.3 Pesticides/Pest Control Chemicals 13.7.1.3 Glass Register
2.4.3 Food Safety Plan (M) Outlines how facility will control and assure food safety:
• Prepared using a HACCP-based method
• Cover product and associated processes
• Describe the methodology and results of a hazard analysis
• 4th highest nonconformity is a poor hazard analysis
2.5 SQF System Verification
2.5.1 – Responsibility, Frequency and Methods 2.5.2 – Validation and Effectiveness (M) 2.5.3 – Verification Schedule 2.5.4 – Verification of Monitoring Activities (M) 2.5.5 – Corrective and Preventative Action (M) 2.5.6 – Product Sampling, Inspection and Analysis 2.5.7 – Internal Audits (M)
2.5.2 Validation and Effectiveness (M) Document and implement methods, responsibility and criteria for ensuring the effectiveness of the pre-requisite programs (PRPs) and validating any critical food safety (CCPs) and critical quality limits (CQPs).
• Confirm they achieve required results • Critical limits are selected to achieve designated level of control
of identified hazard or threat Failure to document how you determined your PRPs are effective is the 10th biggest nonconformity.
2.5.7 Internal Audits (M) Document and implement methods for scheduling, conducting internal audits (incl. factory and equipment inspections) (One of largest nonconformities) • Internal audit schedule • Action taken to correct deficiencies found • Maintenance of records • Results communicated to relevant staff • Staff conducting internal audits trained in internal audit
procedures • Staff independent of the function being audited, where possible
Good Manufacturing Practices for Production of Food Packaging Materials
SQF Code Module 13
Based on Edition 7.2 effective 7/3/14
Module 13 Elements 13.1 – Site Requirements and Approval 13.2 – Construction and Control of Product Handling and Storage Areas 13.3 – Personnel Hygiene and Welfare 13.4 – Personnel Processing Practices 13.5 – Water and Air Supply 13.6 – Storage and Transport 13.7 – Control of Foreign Matter Contamination 13.8 – Waste Disposal 13.9 – Exterior
All items in Section 13 are “Shalls” Exclusions to these requirements or alternate methods of control are
permitted, however they need to be supported by a detailed risk analysis outlining the basis for any exclusion and demonstrating food packaging safety is not compromised. The risk assessment must contain:
• A description of the element of the standard and the hazards which need to be addressed.
• The control protocol which the facility will implement to ensure the identified hazards are controlled.
• Validation that the protocols are properly implemented and effective.
Not all Module 13 sub-elements need documenting 13.1.1 – Premises Location 13.1.2 – Construction and Operational Approval 13.2.1 – Materials and Surfaces 13.2.2 – Floors, Drains and Waste traps 13.2.3 – Walls, Partitions, Doors and Ceilings 13.2.4 – Lighting and Light Fittings 13.2.5 – Dust, Fly and Vermin Proofing 13.2.6 – Ventilation 13.2.10 – Equipment, Utensils and Protective Clothing
Not all Module 13 sub-elements need documenting 13.3.2 – Hand Washing facilities 13.3.3 – Clothing provided (if applicable) 13.3.6 – Staff Amenities 13.3.7 – Change rooms/Locker rooms (if applicable) 13.3.8 – Sanitary Facilities 13.3.9 – Lunch Rooms 13.3.10 – First Aid 13.6.1 – Storage Conditions for packaging materials and products 13.6.2 – Storage Conditions for equipment 13.9 – Exterior
Following programs do need documenting
13.2.7. Premises and Equipment Maintenance • Document plan showing methods and responsibility
• Minimize risk of product contamination • Needs to include maintenance and repair of warehouse, equipment and buildings
• Routine maintenance in accordance with Maintenance schedule
• Document, review, incorporate into maintenance control schedule all equipment failures
• Follow personnel hygiene and welfare (see13.3)
• Remove all tools, debris once maintenance completed • Inform the area Supervisor so appropriate hygiene and sanitation can be
completed
• Need to document annually how you determine your maintenance program is effective
13.2.8. Calibration Document and implement showing methods and responsibility for
calibration and re-calibration of measuring equipment used for any monitoring activities (Calipers, etc.).
Document and implement procedures to address the disposition of potentially affected product if equipment is found to be out of calibration.
Protect equipment from damage and unauthorized Adjustment.
Need to document annually how you determine your calibration program is effective.
13.2.9. Management of Pests and Vermin Document and implement showing methods and responsibility
for integrated pest management. Premises, surrounds, ancillary storage areas, machinery and
equipment kept free of waste or accumulated debris so as not to attract pests and vermin.
Need to document annually how you determine your pest control program is effective.
13.2.11. Cleaning and Sanitation Document and implement methods and responsibility for cleaning food
packaging processing equipment and food packaging storage areas, transport equipment and staff amenities and toilet facilities.
• Consider:
What is to be cleaned
How it is to be cleaned
When it is to be cleaned
Who is responsible for the cleaning
Responsibility and methods for verification of effectiveness
Need to document annually how you determine your sanitation program is effective.
13.3. Personnel Hygiene and Welfare 13.3.1 – Personnel’s health 13.3.4 – Jewelry and Personal Effects 13.3.5 – Visitors
13.3.1 Personnel Personal health
• Do not handle product if suffering from or being a carrier of infectious diseases
• Note – health questionnaire, screening Cuts and lesions
• Do not handle product or food contact packaging materials if exposed cuts, sores or lesions are present
• Cover minor cuts, abrasions with suitable waterproof colored bandage or bandaid
Personal practices • No smoking, chewing, eating, drinking or spitting in
any food packaging handling or storage areas
Drinking on the processing floor variance. As the SQF Code prohibits any drinking on the processing floor
as product is exposed you are going to have to apply for a variance from the Certifying Body prior to your facility audit if you allow drinking or you will receive a non-conformity.
Variances can only be granted by Certifying Bodies not by auditors.
Variance request has to be in writing and the Certifying Body has the right to grant or deny the variance.
Cannot be appealed to SQFI as the SQF Code does not permit drinking where product is exposed.
13.5.4. Air Quality Compressed air used in the food packaging operations shall be:
• Clean and present no risk to food packaging safety. • Regularly monitored for environmental contaminants. • Test annually for Aerobic Plate Count and Molds and
Yeasts
13.6 Storage and Transport 13.6.1 – Storage of Food Packaging 13.6.2 – Storage of Equipment 13.6.3 – Storage of Hazardous Chemicals and Toxic Substances 13.6.4 – Alternative Storage and Handling of Goods 13.6.5 – Loading, Transport and Unloading Practices 13.6.6 – Loading/Unloading
13.6.4. Alternative Storage and Handling of Goods Where goods described in 13.6.1 to 13.6.3 are held under temporary or overflow conditions that are not designed for the safe storage of goods, a risk analysis shall be undertaken to ensure there is no risk to the integrity of those goods or contamination or adverse affect on food packaging safety and quality.
13.7.2. Control of Foreign Matter Contamination.
Glass register – list glass objects or similar material in food packaging processing areas showing location.
Containers, equipment, utensils made of glass, porcelain, ceramics, testing glassware or like material (except where packaging product packaged is glass/like materials, instruments with glass dial covers, thermometers).
Regular inspections of processing areas, affirm condition of items in glass registry.
Inspect glass instrument dial covers, MIG thermometers at start and finish of each shift in processing areas if they cannot be eliminated or protected to confirm they have not been damaged.
NON-CONFORMITIES
SCORING
GRADING
Minor Nonconformity
A Minor Nonconformity shall be corrected, verified and closed out within thirty (30) calendar days of the completion of the Facility Audit
Extensions may be granted by the Certification Body where there is no immediate threat to product safety and quality, and alternative, temporary methods of control are initiated
Major Nonconformity A Major Nonconformity shall be corrected and appropriate
Corrective Action verified and closed out within fourteen (14) calendar days of the completion of the Facility Audit
Critical Nonconformity A Critical Nonconformity raised at a Certification Audit results
in an automatic failure of the audit & the Supplier must reapply for certification
The Auditor shall immediately advise the Supplier and Notify the Certification Body
(If re-application occurs within 6 months and with the same CB, no desk audit is required)
SQF Non-conformances These non-conformances can occur during the Desk
(Document) audit or during the Facility (Site) audit. ONLY FACILITY AUDIT IS SCORED.
Scoring effect of facility non-conformances on the possible score of 100.
• Critical (Minus 50 points) • Major (Minus 10 points) • Minor (Minus 1 point)
All non-conformances should be corrected before an SQF Certificate will be issued however if all minor nonconformities have not been corrected a certificate can still be issued within 45 days of last day of facility audit.
Audit Score Score Rating Certification Audit
Frequency 96 - 100 E – Excellent Certificate issued 12 monthly
re-certification audit.
86 - 95 G – Good Certificate issued 12 monthly re-certification audit.
70 - 85 C – Complies Certificate issued 6 monthly surveillance audit required.
0 - 69 F – Fails to comply
No certificate issued
Considered to have failed the SQF Audit.
The SQF Certification Process
Select a Certification
Body
Identify the Scope of
Certification Select an Auditor
Identify the Scope of the
Audit Desk Audit Facility Audit
The Audit Report
Granting Certification
Maintenance of
Certification
SQF Annual Meeting 2014
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Sea World Orlando
Oct 28-30th, 2014
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Public training On-site training eLearning courses http://www.saiglobal.com/training/assurance/eLearning/
ISO 9001 Essentials for Everyone
Introduction and Refresher to HACCP Food Safety Systems
Upcoming SQF Public Training Courses SQF Internal Auditing
Date Location May 8-9 Dallas
May 21-22 Charlotte
Jun 10-11 Chicago
June 25-26 Boston
Aug 14-15 Chicago
Sept 4-5 Boston
Sept 25-26 Orlando
Oct 2-3 Los Angeles
Oct 23-24 St. Louis
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HACCP For Food Processors
SQF Code Edition 7.2 - Implementation Course Date Location
May 1-2 St. Louis
May 8-9 Boston
May 14-15 Los Angeles
May 15-16 Chicago
May 22-23 Boston
June 5-6 Vancouver
June 12-13 Calgary
June 26-27 Toronto
July 17-18 Baltimore
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Date Location
May 6-7 Baltimore
May 12-13 Los Angeles
May 13-14 Chicago
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June 10-11 Calgary
June 24-25 Toronto
July 15-16 Baltimore
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Advanced Practitioner Training Course SAI Global is pleased to announce the following dates and locations for this new 2-day course. SQF Advanced Practitioner Training Date Location May 5-6 Chicago May 22-23 Toronto June 24-25 Dallas July 7-8 Vancouver July 22-23 Los Angeles Aug 7-8 Montreal Aug 12-13 Orlando
Date Location Sept 8-9 Toronto Sept 16-17 Boston Oct 9-10 Charlotte Oct 23-24 Calgary Nov 20-21 Vancouver Dec 2-3 Chicago
Training & Improvement Solutions
10% Discount* Code: SQFPACKAGING10
*Not valid for eLearning or on-site courses
www.saiglobal.com/courses
Assurance Services SAI Global can offer on-site consulting for SQF including:
Design of your entire program On-site GAP analysis HACCP program facilitation Program review & development Allergen program review and validation Product specification building
Food Safety Services TRANSFER your GFSI, HACCP, etc. today! Local auditors, Global reach:
SQF BRC FSSC 22000 IFS HACCP GMP-SAFE
Request more information on Training, Auditing, Consulting & Certification
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SAI Global Assurance Services - Americas
Dr. Bob Strong Senior Consultant 513-349-5398 [email protected]