Coming soon to a food production, retail, storage, packaging and distribution center near you: Safe Quality Foods (SQF) Code 8.0 requires new steps in an effort to ensure food safety and new requirements for food safety certifications – all by January 2, 2018.
With today’s consumer emphasis on farm to table, locally produced food and supporting of small family-run businesses, the increased requirements put forth by the Safe Quality Foods Institute (SQFI) offer an opportunity through their Code on Food Safety Fundamentals and Primary Production for small farms and businesses to demonstrate a level of competence in this time of increasing focus on food safety under the FDA’s Food Safety Modernization Act.
SQF certification audits provide assurances to not only individual firms that they are operating safely but to their customers as well. Per SQFI, sites may continue their annual announced recertification audit schedule or, new under SQF 8.0, may choose to participate in an annual unannounced audit which, upon successful completion, will designate the facility a SQF Select Supplier.
Of course the expectation of every diligent facility is an “excellent” or at least a “good” score on their certification audit and the continuation of a twelve month recertification cycle. However, those sites receiving a score of 70-85%, or a “C -Complies,” do receive a passing certificate but fall into a six month surveillance audit schedule for closer monitoring. Those receiving a score of 69 points and fewer fail the audit completely. Non-conformities which can lead to certification woes fall into minor and major categories and, with some exceptions for facility structural changes, installation of equipment and seasonal conditions which impact production, should be corrected, verified and closed out in 30 calendar days.
So what has happened when a site fails a certification audit or merely complies with the minimum requirements? What has gone wrong and how do companies turn things around within such a short time?
The answer depends on the infraction, its severity and the corrective action necessary. It is common knowledge that the various the SQF “Codes” require that the SQF Practitioner be a qualified full-time employee with a level of professional responsibility commensurate with the ability to oversee the SQF Systems, including Good Manufacturing, Good Distribution and Good Agricultural Practices. Their qualification can be satisfied by outside training through a SQF training center or through in-house knowledge and experience in food safety requirements. However, all SQF Practitioners must provide documentation that they have received formal HACCP-based training. This SQF Practitioner must document and implement the SQF System, including policies, procedures, instructions and specifications that are up to code and easily accessible. Likewise, they oversee the implementation of the SQF System including assurances that those policies are performed to standard and documented, with records maintained for designated times, usually at least one year and in some cases two years.
A common area of concern for all food manufacturers is the traceability of suppliers, including those international suppliers under the Food Safety Modernization Act’s (FSMA) Foreign Supplier Verification Program (FSVP) and the very tight restrictions on allergen controls. Newer and smaller firms falling under any of SQFI’s Codes all find challenges in the traceability and allergen areas, but it can be particularly daunting for smaller firms without available staffing, records systems or advanced processing equipment that aids in the achieving SQF compliance.
While the Food Safety Fundamentals certification does not have a Hazard Analysis and Critical Control Points (HACCP) requirement, SQF Practitioners are still required to have complete oversight of the source of their raw materials and their countries of origin (COOL), how those materials are transported (including cleaning schedules between shipments, prevention of cross contamination, etc.) as well as allergen contact during production, (even those contacts found in employee lunchrooms, on-site vending machines and on the shoes of visitors.) Practitioners are required to keep a list of allergens in the country of manufacture as well as the country of destination and document their plan for cleaning, validation and verification where allergens are present. Once corrective action has been taken, SQFI recommends documentation be kept for a minimum of 90 days supporting any new policies and procedures.
Oftentimes, assessment of where policies have not met code can be better understood and corrected through a re-reading and interpretation of the code. In other cases, companies choose to bring in outside assistance in the form of consultants who have expertise in specific areas such as traceability and allergens (or any of the code specifics). “That is where companies such as EAS Consulting Group can be of assistance,” says Allen Sayler, Senior Director of Food and Cosmetic Consulting Services. “EAS has SQF trained consultants that can help firms get ready for SQF certification and maintain high food safety standards.” With the requirement to correct and close-out the infraction within 30 days, the clock is ticking, particularly for small businesses with the proper training but limited practical experience in dealing with SQF code non-conformities.
However firms choose to respond to infractions, their response will only bring about safer production methods which result in safer food. As our emphasis on food sourcing grows and smaller businesses gain a foothold in the market, SQF codes will insure better compliance for all.
Amy Scanlin, M.S. works for EAS Consulting Group, LLC, headquartered in Alexandria, VA. EAS is a leading consulting, auditing and training firm that specializes in FDA regulatory matters, providing assistance to the food, dietary supplement, pharmaceutical, medical device, tobacco and cosmetics industries. Staffed primarily with former FDA compliance and inspection officials and former industry executives, many of whom have more than 30 years of regulatory experience, EAS takes a proactive role in educating on FSMA, FSVP, SQF 8.0, GMPs and more, offering public and in-house seminars around the country. Visit www.easconsultinggroup.com to learn more.