California Ag Network

Tag: SQF

  • Top 10 SQF Version 8 Non-Conformances for 2019

    Did you know that in 2018 there were about 6000 SQF audits globally? When I read that, I was struck by how many sites are audited to the standard. You may be aware that in 2018 the new edition 8 of SQF went into effect, which affected all of those sites worldwide.  Although the standard remained largely the same in spirit, there were some significant structural changes and as many of you discovered there were some very notable changes in the requirements too.

    A Little Bit About SQF

    According to the owners of the scheme, “The Safe Quality Food (SQF) Program is a rigorous and credible food safety and quality program that is recognized by retailers, brand owners, and food service providers worldwide. Recognized by the Global Food Safety Initiative (GFSI), the SQF family of food safety and quality codes are designed to meet industry, customer, and regulatory requirements for all sectors of the food supply chain – from the farm all the way to the retail stores”.

    Every year SQFI (the organization that manages the SQF food safety standards) issues summary data about the year’s audits, which includes information regarding the certification bodies, auditees, industry recalls, and other relevant information. Our team reviews the data they share, both as part of our auditor calibration process, and to gauge our performance to see where we might improve.  I’m always drawn to their list of top non-conformities because it’s precious information to share with our customers.  So, let’s take a look at this past year’s list of top non-conformities and examine what we, as an industry, might glean to improve our performance in the coming year.

    Top 10 Major Non-Conformities

    • 2.7.2.1 Food Fraud Program
    • 2.4.8.1 Environmental monitoring
    • 11.2.13.1 Cleaning and Sanitation
    • 2.4.3.2 Food Safety Plan
    • 2.5.1.1 Validation and Effectiveness
    • 2.5.5.1 Internal Audits and Inspections
    • 2.4.3.13 Food Safety Plan Monitoring
    • 11.2.12.2 Identified Pest Activity Risk
    • 11.2.10.1 Maintenance Program
    • 11.7.6.2 Metal Detector Management

    Key Takeaways:

    Several of these findings are in new sections or sections which have new requirements.  For example, food fraud (which, by the way, is in alignment with new requirements under FSMA), new environmental monitoring requirements, and pest activity.  Anecdotally, I’ve seen this in my audits as well – many companies have been taken by surprise by a few of the new requirements.  As compared to 2017, companies do appear to have a better handle on FSMA requirements as this hasn’t come up as often this year.  Yet we do still see some of the same struggles with existing programs such as sanitation, validation, the food safety plan, and internal audits.

    Major NCs: Announced Versus Unannounced

    In 2018, there were several unique top-10 Major NCs found in unannounced audits which were NOT in the “Top 10” for announced audits:

    • 11.2.9.2 Equipment, utensils, and clothing
    • 11.2.12.5 Inspections for pest activity
    • 11.7.5.1 Foreign Material Control Program
    • 2.4.4.5 Food fraud raw material review
    • 2.4.6.2 Records of reworking are maintained

    The one unique top-10 minor NC in unannounced audits was 2.8.1.1 Allergen management.

    Key Takeaways:

    What can we gather from this? It represents observational findings, rather than the “system” findings we see in the announced audits.  It’s what can go wrong on a day-to-day basis that might be observed in an unannounced audit, and may be less likely to come up when we’re more prepared for the audit.  This list of non-conformities indicates to me that the unannounced audits are working as a check on how things look in our usual day-to-day operations.

    I should mention that 20% of audits in 2018 were unannounced.

    Top 10 Minor Non-Conformities

    • 2.7.1.3 Food defense plan
    • 11.2.9.2 Equipment, utensils, and clothing
    • 11.4.1.1 Staff engaged in food handling
    • 2.7.2.1 Food fraud program
    • 11.2.13.1 Cleaning and sanitation
    • 11.2.3.1 Walls, floors and ceilings
    • 2.4.3.7 Food safety plan – flow diagram
    • 2.2.3.2 Records
    • 11.2.2.1 Floors, drains and waste traps
    • 2.1.3.2 Management review

    Key Takeaways:

    As with Major non-conformities, we see the appearance of several new requirements in the top non-conformities.  We aren’t testing our food defense plans as we should, we haven’t fully implemented the monthly management review meetings, and we aren’t meeting the mark in the new food fraud program requirements.  And again, we still find ourselves faced with some of the old familiar challenges – recordkeeping, sanitation, HACCP flow diagrams, and the condition of items and our facility.

    OK, So What’s Next?

    Based on the above there are a few recommendations I can make to keep your programs in shape.

    1. Get training if needed – You need to make sure you understand any new requirements. If you are uncertain about where or when to get trained, check on upcoming SQF training with us on our events page.
    2. Train your crews – They can’t meet the requirements if they don’t understand them.  Many companies find themselves short-staffed or facing employee turnover.  Training is where you find one of the most significant returns on your time.
    3. Internal audits – They’re your best tool for verifying how your programs are doing and keeping your employees aware of what’s expected.  Make sure members of different departments are involved, and your program does a thorough evaluation of your processes. Never had an internal auditor program, check out our new web-based internal auditor course to get started.
    4. Test your food defense system – This is a new requirement.
    5. Revisit food fraud – Make sure your food fraud program is in place and meets the new requirements.  If you’re not sure where you stand, contact us for help.
    6. Environmental monitoring – This is a major focus now, both with SQF and for FDA.  Make sure your program has what it needs. Again, for more information check out our web-based course on this subject.
    7.  Attend Safe Food California – Jeannette Litschewski, Specialist for SQFI Technical Affairs, will be speaking on the Most Common SQF Audit Non-Conformities. If you’re interested in attending, please visit www.safefoodcalifornia.com to register.

  • The Importance of Food Safety Culture

    In my role, I routinely work with facilities pursuing a third-party food safety certification audit for the first time. After four years of assisting and educating people about the audit process, I have noticed that you can recognize early on whether a company’s pursuit is focused more on obtaining the necessary certificate or in ensuring that their products are safe.

    Most facilities fall somewhere in the middle of the spectrum, balancing the desire for food safety with legitimate concerns about profitability. It is not difficult, however, to identify whether a facility sees a food safety audit as another bureaucratic hurdle or an opportunity for growth. That attitude often acts as an indicator of how the company will perform on their audit. Sites that prioritize safety and continuous improvement are likely to have better audit outcomes.

    Of course, this is not news to many people. GFSI-benchmarked schemes intentionally look for this quality through objective evidence, with SQF emphasizing “Management Commitment” and BRC clauses mentioning “Food Safety Culture.”

    Food Safety Culture refers to the specific culture of a facility: the attitudes, beliefs, practices, and values that determine what is happening when no one is watching. If you want to gauge a site’s Food Safety Culture, try asking yourself how the site typically responds to food safety concerns. Does the staff take potential problem seriously, as if its importance is obvious? Or do they view food safety practices as just one more hoop they need to jump through in order to stay in business? Is their response to simply ask, “How much is this going to cost?”

    In reality, no facility can afford not to develop a healthy Food Safety Culture. A strong culture of food safety helps a facility both to prevent and catch deviations in their processes that impact the safety, quality, and legality of their products. This, in turn, has a major impact on the likelihood and severity of a recall impacting that site.

    In 2012, the Food Marketing Institute and the Grocery Manufacturers Association found that “the average cost of a recall to a food company is $10M in direct costs, in addition to brand damage and lost sales[SK1]  according to a joint industry study.” The costs were significantly higher for larger manufacturers as seen below.

    While it is common for there to be tension between Quality Assurance and Operations teams over the allocation of resources in a plant, the data suggests that it is in the interest of both departments to develop a strong Food Safety Culture. Doing so ensures the integrity of food products and protects the bottom line.

    How, then, can you cultivate Food Safety Culture in your facility?

    As suggested by the SQF scheme approach, a change to company culture always begins at the top. Because senior management has final control over resources, their buy-in on food safety is absolutely essential. Ways management commitment can be seen include:

    • proper money and time are allocated to staff receiving necessary food safety training
    • machinery and tools are repaired and replaced accordingly to decrease the risk of health hazards for the product and employees
    • a food safety plan is well developed and acts as a living document that is regularly updated

    Management commitment is also apparent when senior management regularly participate in routine food safety meetings; reviewing customer complaints, results of recent inspections, food safety issue in the industry, corrective actions from previous audits, and progress toward new food safety goals.

    Beyond the above listed actions, a truly robust Food Safety Culture requires creative thinking to help the entire staff understand the importance of food safety. At the root, you want the people in your facility to understand not just what they are doing and how they are supposed to do it, but why. Why does an employee need to follow their assigned procedures and protocols? Why should they report any concerns to supervisors? Most importantly, why does their job matter?

    For instance, it is possible people on the floor of your facility think of their work as tedious or insignificant. How can you help every member of the staff understand their role in manufacturing safe food? How can you can help them to see that their work helps keep people alive and out of the hospital? Changing a company culture is never easy. It takes time and knowledge to move forward. The eight step process featured below acts a helpful first step towards your adoption of a more food safety focused company culture.

    Eight steps to culture change It is important to remember that creating this type of culture is only truly effective when it is backed up with action. Are employees provided with an effective anonymous way to share safety concerns with management? Do they see maintenance and repair tickets being addressed promptly? Are they penalized for doing things right even when that slows them down?

    Cultivating a Food Safety Culture is a never-ending process of continuous improvement, but commitment to this area yields benefits for the bottom line, for employee satisfaction, and for the families who eat your product. You can’t afford to neglect it.