Top 10 GFSI Non-conformances for SQF & BRC Audits and how to avoid them March 2014 Gary Smith

Our Presenter Today

Gary Smith

• Director of Training & Improvement Solutions - SAI Global

• With an MS in Environmental Biology from Governors State

University and a BS in Animal Sciences from the University

of Illinois, Gary brings over 20 years of industry experience

to his duties at SAI Global

• Gary has an extensive list of professional certifications and industry

memberships and has been active on a number of policy influencing committees.

He currently serves as: Chair of the Food Safety Service Providers (FSSP), a

member of the Accreditation task force and Guidance document working group, a

member of the GFSI, and as a member of the Technical Advisory Committee for

SQFI. Previous committee work includes a Council III membership with the

Conference for Food Protection

• Prior to joining SAI Global, Gary served as the Vice-President of Supply Chain

Consulting at Steritech and Technical Director for the Safe Quality Food Institute

(SQFI)

Purpose of Webinar

• To discuss the most common documentation issues found during

desk and initial certification audits

• To understand the physical challenges from food manufacturing

audits observed

• To acquire an understanding of how to improve implementation of

systems

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Agenda

• Review the top non-conformances on the SQF standard,

version 7 levels 2 and 3

– Document audit

– Facility audit

• Review the severity of the non-conformance

• Provide recommendations and identify solutions to

proactively avoid the most common and significant non-

conformances

• Compare the SQF audit non-conformances against the BRC

audit non-conformances

Review of the data

• Data available starting with new version 7 of SQF

• Data range July 1st, 2012 to August 30th, 2013

• Does not contain data from Version 7.1

• Total audits used in analysis

– Level 2 – 4320

– Level 3 – 4457

• Data is broken down by major and minor

• Data is from modules 2 and 11 only (>80% of audits)

Severity of Non-Conformance

• Major NC – is an omission or deficiency in the SQF system

producing unsatisfactory conditions that carry a food safety

or quality risk and likely to result in a system element

breakdown. Numerous or systematic failures to be in

compliance with the standard.

• Minor NC – 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 and quality but not likely to

cause a system element breakdown. Isolated failures to be

in compliance with the standard.

Top 10 NCs – Document Audit

Clause Question Percentage

2.1.6.2 Business continuity plan components 3.23%

2.6.3.1 Product withdrawal and recall procedure 3.13%

2.1.6.3 Business continuity plan annual testing and review 2.60%

2.4.3.1 Food safety plan developed and maintained 2.54%

2.3.3.2 Contract service providers register 2.09%

11.2.10.2 Procedures for product disposition when calibration out 2.07%

2.1.2.8 Job descriptions include food safety, quality and backups 1.86%

2.5.3.1 Verification schedule, including PRPs 1.85%

2.4.5.4 Approved supplier program, risk assessment of raw

materials

1.80%

2.5.7.1 Methods and responsibility for Internal Audit Program 1.77%

BOLD – designates repeat from 2012

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Top 10 NCs – Facility Audit

Clause Question Percentage

11.2.12.1 Equipment and utensil construction and design 2.41%

11.2.3.1 Walls, doors and ceilings, construction, durable and clean 2.01%

2.4.3.1 Food safety plan implemented and controls met 1.94%

11.2.13.1 Cleaning and sanitation issues within the facility 1.64%

11.2.2.1 Floors; constructed, effectively graded, easily cleaned 1.63%

2.2.2.2 Records; legible, authorized, demonstrated activities taken 1.49%

11.7.5.3 Use of temporary repairs within the facility 1.35%

11.2.7.1 External windows and doors effectively sealed 1.35%

2.1.6.3 Business continuity plan not tested annually 1.29%

11.2.9.2 Maintenance practices in food handling areas 1.22%

BOLD – designates repeat from 2012

Top Major NCs – Facility Audit

Clause Question Percentage

11.2.12.1 Equipment and utensil condition 1.77%

2.6.2.1 Product traceability and traceability exercise 1.70%

11.2.2.1 Condition of floor (high risk / RTE facility) 1.57%

2.4.3.1 Food safety plan developed and maintained 1.50%

11.2.13.1 Sanitation of the facility 1.43%

11.2.3.1 Condition of walls and ceiling 1.43%

2.6.3.1 Product withdrawal and recall program 1.36%

2.5.7.1 Implementation of Internal Audit Program 1.36%

11.2.11.1 Effectiveness of pest management program 1.23%

2.8.2.1 Validation of allergen management program 1.23%

Comparison of the BRC Audit Non-conformances to the SQF Data

• Top non-conformances on the BRC audit

– Food safety plan (HACCP) implementation

– Food safety plan (HACCP) training

– Implementation of foreign material program

(metal detection)

– Building fabric suitable for intended use in high-

care facilities (floors, drains)

– Senior management commitment to the food

safety plan

– Allergen validation properly conducted and

documented

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Rating of Top Non-Conformances - BRC

• Major

– Food safety plan

– Validation of CCPs

– Product withdrawal contact

list

– Verification of food safety

fundamentals

– Equipment and utensils

condition

– Allergen management

program

– Approved supplier program

• Minor

– Equipment and utensils

condition

– Walls, ceiling and door

construction

– Food safety plan

– Condition of floor

– Sanitation of facility

– Records

– Temporary repairs

– Door and window closure

– Annual test of business

continuity plan

Biggest Risk to Supply Chain Based on Results of SQF & BRC Audits

1. Management of food safety plan

– Recall risk, product adulteration concern

2. Product traceability / product withdrawal and recall

– Minimize amount of product recalled, put customers at

risk

3. Allergen management, controls and validation

– Number #1 cause of recalls

4. Condition of equipment and utensils

– High number of customer complaints (foreign material)

Proactive Solutions to Avoid Non-Conformances

• Food Safety Plans

– HACCP team refresher training

– Review supporting documents during annual check

– Annual review – use an outside set of eyes

– All CCPs must be validated

– Question employees during internal audit at all CCP

monitoring stations

Proactive Solutions to Avoid Non-Conformances

• Traceability / Recall

– Keep recall team current, include CB and standard

owner

– Have procedures for mock recall, always perform

– Make mock recall be real test

– Include ingredients and packaging in all traceability

programs

– Perform product trace exercise during your own

internal audit – different than a mock recall

Proactive Solutions to Avoid Non-Conformances

• Allergen management

– Identify ingredients as allergens at receiving

– Specific allergen protein must be validated

• Surface testing

• Product testing

– Have label inspection program at receipt

– Allergens must be listed as hazards in hazard

analysis, list control as allergen management program

Proactive Solutions to Avoid Non-Conformances

• Condition of Equipment and Utensils

– Preventative maintenance schedule

– Focus internal audit program on equipment, not

just employees

– Use flashlight when conducting internal audits

– Train and empower production employees to

identify defects, rewards

– No temporary repairs

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Proactive Solutions to Avoid Non-Conformances

• Have a strong internal audit program

– Include as many from your facility in the program as possible

– Manage all non-conformances with a corrective action program

– Take photos of all findings during internal audits

– Question your employees during your internal audit, get them

accustom to answering questions

– Focus on the facility, not just the employees

– Be harder on yourself than anyone else will be

– Dress just like the auditor would, make the process as formal

as possible

– Remember the audit is beyond your normal job, you must

schedule and complete it separately from your “job”

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Summary

• To achieve food safety certification takes commitment and

dedication

• Maintaining certification takes more commitment and

dedication

• To perform your best on your audit

– Focus on high risk areas first

– Keep all levels of facility engaged, communicate well

– Have a strong internal audit program

– Don’t be afraid to identify issues, focus on corrective

action management

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THANK YOU FOR ATTENDING

Gary Smith

Director of Training & Improvement Solutions

Assurance Services - Americas

(704) 701 0210

Gary.smith@saiglobal.com

Certification.Americas@saiglobal.com