This document provides a summary of a webinar on understanding the top non-conformances in SQF 7.1 certification. It discusses the relationship between SQF and GFSI and the changes between SQF Code editions. The webinar focuses on the most common non-conformances found during SQF certification, re-certification, and surveillance audits for Module 2 (SQF system elements) and Module 11 (food processing). Management responsibility, business continuity planning, food safety plans, internal audits, and corrective action were identified as the most common themes among non-conformances. The webinar provides tips on compliance and ensures understanding of SQF requirements for these areas

1. Tips and Traps for SQF 7.1: Understanding
NonTop 10 Non-conformances
Bill McBride
13 November, 2013

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3. Introductions
• Based in Sydney, Australia
• Asia Pacific Representative for SQF
program
• Chairman of the GFSI Auditor Competence
Scheme Committee
• CEO of Foodlink Management Services
since 1998
• Forty years experience in food and
beverage manufacturing, quality
management, food safety systems.
3

4. Agenda
• Welcome and Introductions
• The relationship between SQFI and GFSI
• The difference between the SQF Code, edition 7 and
earlier versions
• Top Non-conformances (NCRs), module 2 and module 11
• Common themes in NCRs:
• Management Responsibility
• Business Continuity Planning
• Food Safety Plan
• Internal Audits
• Corrective and Preventative Action
• Tips for Compliance
• Q&A

5. GFSI Mission and Objectives
Provide continuous improvement in food safety
management systems to ensure confidence in the
delivery of safe food to consumers worldwide
Reduce Food Safety
Risks
Manage Cost in the
Supply Chain
Develop
Competencies and
Capacity Building
Knowledge
Exchange and
Networking

6. GFSI - A Collaborative Approach
Government
Certification
Bodies
Scheme Owners
Suppliers
Retailers
Accreditation
Bodies
Academia
International
Organisations
Service Providers
Food Service

7. The GFSI Guidance Document
multiA multi-stakeholder document that:
›
Sets out the requirements for food
safety management schemes and the
key elements for the production of
food, feed, packaging, etc
›
Provides guidance to schemes seeking
compliance with the GFSI Guidance
Document and recognition by the GFSI
›
Defines the requirements for the
effective management and control of
conforming schemes
›
Puts in place transparent procedures
for the GFSI benchmarking process

9. SQF Code Revision
The publication of edition
6 of the GFSI Guidance
Documented presented
SQFI with a challenge,
and an opportunity to
review the SQF 2000 and
SQF 1000 Codes and
revise as necessary
before resubmission

10. Revised SQF Code - Format
Part A:
Implementing and Maintaining the SQF Code
1. Preparing for SQF certification
2. The Certification Process
3. The Certification Decision
4. Surveillance and Re-certification
5. Obligations of Suppliers and
Certification Bodies
Part B:
The SQF Code
Module 1: Scope, References, and Definitions
Module 2: SQF System Elements
Modules 3 – 15: Food Safety Fundamentals (GAP/GMP)
Module 16: Multi-site Program
Appendix 1: Food Sector Categories
Appendix 2: Glossary
Appendix 3: SQF Quality Shield and Logo

11. The SQF Code, edition 7
Implemented July 2012
Module 2: SQF System Elements (applies to all Suppliers)
Approved
Module 3: GAP for Single Feed Production (TBD)
Module 4: GAP for Compound Feed Production (TBD)
Approved
Module 5: Farming of Animals (FSC: 1)
Module 6: Farming of Fish (FSC: 6) not benchmarked; need 10 certificates
Approved
Module 7: Farming of Plants (FSC: 3)
not benchmarked; need 10 certificates
Module 8: Farming of Grains and Pulses (FSC: 5)
Approved
Module 9: Animal Conversion (FSC: 7)
Module 10: Pre Processing Handling of Plant Products (FSC: 4)
Approved
Approved
Module 11: Processing of Animal Perishable Products (FSC: 8,9,10,11, 12)
Approved
Module 11: Processing of Plant Perishable Products (FSC: 14, 22)
Approved
Module 11: Processing of Animal and Plant Perishable Products (FSC: 20, 21)
Approved
Module 11: Processing of Ambient Stable Products (FSC: 13, 15, 16, 17, 18)
Module 12: Provision of Transport and Storage Services (FSC 25, 26) not benchmarked
Module 11: Production of (Bio) Chemicals (FSC: 19, 31)
Approved
Module 13: Production of Food Packaging (FSC: 27)
Approved

12. The SQF Code, edition 7.1
Implemented July 2013
Key Changes:
Approximately 50 changes
Addition of the feed, pet food and Harmonized
produce module
Realignment of FSCs 32, 33 and 34
Added requirement for the auditor to review the
entire facility, regardless of the scope of
certification
The addition of requiring facilities to report all
regulatory warning letters to SQF (of public nature)
An additional element that requires the facility to
follow the requirements of the Quality Shield
Added an element on air and water quality to
comply with GFSI distribution Guidance Document

13. The SQF Code, edition 7.1
Implemented July 2013
Module 2: SQF System Elements (applies to all Suppliers)
Module 3: GMP for Animal Feed Production(FSC: 34)
Submitted to GFSI for benchmarking
Module 4: GMP for Processing of Pet Food (FSC: 32)
Submitted to GFSI for benchmarking
Module 5: Farming of Animals (FSC: 1)
Module 6: Farming of Fish (FSC: 6)
Module 7: Farming of Plants (FSC: 3)
Module 7H: Farming of Plants (FSC: 3)
Preparing to submit to GFSI
Module 8: Farming of Grains and Pulses (FSC: 5)
Module 9: Animal Conversion (FSC: 7)
Module 10: Pre Processing Handling of Plant Products (FSC: 4)
Module 11: Processing of Animal Perishable Products (FSC: 8,9,10,11, 12)
Module 11: Processing of Plant Perishable Products (FSC: 14, 22)
Module 11: Processing of Animal and Plant Perishable Products (FSC: 20, 21)
Module 11: Processing of Ambient Stable Products (FSC: 13, 15, 16, 17, 18)
Module 12: Provision of Transport and Storage Services (FSC 25, 26)
Module 11: Production of (Bio) Chemicals (FSC: 19, 31)
Module 13: Production of Food Packaging (FSC: 27)
Preparing to submit to GFSI

14. Modules in Development
• Module 14 GMP for Food Brokers (FSC 35)*
• Module 15 GMP for Retail (FSC 24)*
• * GFSI recognition will only apply once GFSI Guidance is
available for these sectors, and SQFI has requested an
extension

15. Top Non-Conformances
Certification Audits
Module 2
2.1.6.1 Business Continuity Planning
2.3.2.1 Raw and Packaging
Materials
2.1.2.1 Management Responsibility
2.3.3.1 Contract Service Providers
2.5.7.1 Internal Audits
2.5.2.1 Validation and Effectiveness
2.3.1.4 Specification and Product
Development
2.8.2.1 Allergen Management
2.1.2.5 SQF Practitioner
2.4.5.4 Incoming Goods and Service
Module 11
11.2.13 Cleaning and sanitation
11.7.5. Control of Foreign Matter
Contamination
11.2.3 Walls, Partitions, Doors and
Ceilings
11.2.12 Equipment, Utensils and
Protective Clothing
11.2.9 Premises and Equipment
Maintenance
11.6.1. Cold Storage, Freezing and
Chilling of Foods
15

16. Top Non-Conformances
Re-certification Audits
Module 2
Module 11
2.5.7.1 Internal Audits
11.7.5.4 Control of Foreign Matter
Contamination
2.1.2.8 Management Responsibility
2.4.5.4 Incoming Goods and Services
2.1.4.5 Management Review
2.3.2.5 Raw and Packaging Materials
2.4.2.3 Food Safety Fundamentals
2.5.5.1 Corrective and Preventative
Action
11.2.13.1 Cleaning and Sanitation
11.2.12.1 Equipment, Utensils and
Protective Clothing
11.2.3.1 Walls, Partitions, Doors and
Ceilings
11.2.13.1 Cleaning and Sanitation
11.2.10.4 Calibration
11.2.9.2 Premises and Equipment
Maintenance
16

17. Top Non-Conformances
Surveillance Audits
Module 2
2.9.1.1 Training Requirements
2.5.7.1 Internal Audits
2.1.6.3 Business Continuity Planning
2.5.5.1 Corrective and Preventative
Action
2.3.3.1 Contract Service Providers
2.2.2.3 Records
2.5.5.2 Corrective and Preventative
Action
2.4.5.1 Incoming Goods and Services
Module 11
11.2.13 Cleaning and Sanitation
11.7.5.4 Control of Foreign Matter
Contamination
11.2.11.2 Management of Pests
and Vermin
11.2.12.1 Equipment, Utensils and
Protective Clothing
11.2.7.1 Dust, Fly and Vermin
Proofing
11.2.3.1 Walls, Partitions, Doors
and Ceilings
11.2.12.1 Equipment, Utensils and
Protective Clothing
17

18. Common Themes– All Audit Types
Module 2
Module 11
• Management Responsibility
• Cleaning and Sanitation
• Business Continuity Planning
• Control of Foreign Matter
Contamination
• Food Safety Plan
• Internal Audits
• Equipment, Utensils and
Protective Clothing
• Corrective and Preventative
Action
• Walls, Partitions, Doors and
Ceilings
18

19. Management Responsibility and SQF
Certification
• the difference between an effective,
workable food safety management system
and an ineffective system is the level of
management commitment, and how that
influences the attitudes and behaviour
within the business.
• Food safety culture is an integral part of an
effective food safety management system.
The two are not mutually exclusive. One is
not an extension of the other.
• A positive culture is necessary for the
system to work – the system is necessary
to underpin the culture.
• Management must drive the positive
culture
Technology
Systems
Culture

20. 2.1.2 Management Responsibility
•
……. organisational structure describing those with
responsibility for food safety ……..
•
……. ensure fundamental food safety practices are adopted
and maintained ……
•
……. ensure adequate resources are available ……
•
……. designate an SQF Practitioner ……..
•
……. establish (food safety) training needs …….
•
……. continuous improvement …….
20

21. 2.1.6 Business Continuity Planning
2.1.6.1 A business continuity plan based on the
understanding of known threats to a business shall be
prepared by senior management outlining the methods and
responsibility the organization will implement to cope with a
business crisis that may impact on the ability of the supplier to
deliver safe, quality food.

22. 2.4 Attaining Food Safety
2.4.1 Food Legislation
• The organization shall ensure that, at the time of delivery to its customer,
the food supplied shall comply with the legislation that applies to the food
and its production in the country of its origin and destination……
2.4.2 Food Safety Fundamentals
• The supplier shall ensure the food safety fundamentals described in the
relevant subsequent modules of this Code (eg module 11) are applied, or
excluded according to a detailed risk analysis outlining the justification
for exclusion or evidence of the effectiveness of alternative control
measures to ensure that food safety is not compromised.
2.4.3 Food Safety Plan (Level 2)
• A food safety plan shall be developed, effectively implemented, and
maintained and outline the means by which the organization controls and
assures food safety.
2.4.4 Food Quality Plan (Level 3)
• A food quality plan shall be developed, effectively implemented, and
maintained in accordance with the HACCP method.

23. 2.5.7 Internal Audits
• Methods and responsibilities for scheduling and conducting
internal audits to verify the effectiveness of the SQF system
including facility and equipment inspections, PRPs, food
safety plans, food quality plans, and regulation controls shall
be documented and implemented
o An internal audit schedule with scope and frequency
o Corrections and corrective actions of deficiencies
o Audit results are communicated to relevant management and staff
o Records of internal audits and corrective actions
• Staff conducting internal audits shall be trained in internal
audit procedures

24. Benefits of a Strong Internal Audit Program
• Drives continuous
improvement
• Promotes ownership of the
entire SQF system
• Promotes a food safety
culture within your
organization
• Adds credibility to the audit
results
• Improves the audit score!

25. Challenges to an Internal Audit Program
• Management commitment – if leaders do
not take your results seriously, no one else
will
• Time management- letting issues pull you
away from audit schedule or issuance of
report
• Conflict resolution – you and the plant
manager can never seem to see eye to
eye…
• Bias – who audits you? Who can review the
quality programs?
• Ignoring previous issues for information –
findings should be what is found during the
audit only, not what was observed earlier

26. 5 Keys to Successful Internal Audit Programs
1. Define objectives of the Internal Audit Program
with management to facilitate management
commitment
2. Formalize the audit process
3. Communicate well
4. Manage Internal Audits as its own program
5. Use correction action management program
(2.5.5) to manage and resolve internal audit
findings

27. Tips for Compliance
• How can a facility improve their audit performance?
– Implement effective training programs
– Know the standard and any updates
– Conduct validation activities
– Review facility condition
– Maintain records
– Conduct internal audits

28. Summary
Ensure you have knowledge of the SQF Code. Edition 7.1,
and how to implement it.
Keep it simple. Don’t drown in paperwork.
Have a strong internal audit program. Take it seriously.
System implementation and maintenance must be a team
approach.
Success can be achieved through diligence, awareness
and commitment from all levels of the organization.

29. SQF Technical Contacts
North America
LeAnn Chuboff
Senior Technical Director
lchuboff@sqfi.com
Kristie A. Grzywinski
Technical Manager
kgrzywinski@sqfi.com
Melody Ge
Compliance Specialist
mge@sqfi.com
Australia, Asia
Bill McBride
Asia Pacific Representative
bmcbride@sqfi.com.au
General Info
info@sqfi.com

30. Questions and discussion

31. Upcoming “SQF Implementation” dates
2013
Melbourne - 25 & 26 November
2014
Parramatta – 10 & 11 March
Melbourne – 24 & 25 March
Call 1300 727 444 for further information

32. Thank you for attending
A recording of this webinar and unanswered questions
will be available on the SAI Global ‘MyTutor’ portal
• Visit saiglobal-mytutor.com
• Call 1300 727 444
• Email training@saiglobal.com