SQF Certification for Packaging Companies = Food Safety Success
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As the packaging industry gears up for SQF, industry members should be well acquainted with the rigors of the program as well as the opportunities it represents. This presentation describes the drivers for SQF in the food packaging industry, the requirements for becoming certified, as well as SQF training options for getting started.
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SQF Certification for Packaging Companies = Food Safety Success
- 1. © Scientific Certification Systems | 1© SCS Global Services | 1 SQF Certification for Packaging Companies = Food Safety Success 2000 Powell St., Suite 600, Emeryville, CA 94608 || (510) 452-8000 || www.scsglobalservices.com
- 2. © Scientific Certification Systems | 2© SCS Global Services | 2 A Leader in Food Safety and Sustainability 7,000 clients worldwide 14 satellite offices Trusted 3rd-party food industry certifier (1,000+ certificates issued in 2012) Grower-based certifications: Food Safety (GlobalGAP, SQF, BRC, GAP/GMP, Harmonized) Antioxidant Superfoods and Pesticide Residue Free USDA Organic Instrumental in developing national and international sustainability standards Extensive food retailer relationships, including retailer education programs on food safety Accreditations / partnerships in sustainability certification: Fair Trade USA, FSC, MSC, ASC, NSF, RSB, Bonsucro, CSBP
- 3. © Scientific Certification Systems | 3© SCS Global Services | 3 Food Safety Audits Widely Accepted (Random Selection) Whole Foods Ahold US Foodservice Safeway Kroger Walmart Costco Publix HEB Foods McDonalds Wendy’s Starbucks
- 4. © Scientific Certification Systems | 4© SCS Global Services | 4 Top Food Safety Problems Independent experts hired by the FDA identified these issues: 1. Deficient employee training 2. Contamination of raw materials 3. Poor plant and equipment sanitation 4. Poor plant design and construction
- 5. © Scientific Certification Systems | 5© SCS Global Services | 5 Root Causes of FDA Recalls Root Causes of FDA Class 1 and 2 RecaIIs (1999- 2003) Incorrect package or label Ineffective training Failure to follow processing SOP Mistake in addition of ingredient Contamination of raw material Ineffective use of sanitation Principle
- 6. © Scientific Certification Systems | 6© SCS Global Services | 6 Regulatory Response: Food Safety Modernization Act (FSMA) Focus Areas: Audits, Prevention, Compliance, and Response Considering new ways to inspect – Systematic approach * Mandatory recall * Expanded record access and administrative detention * Suspension of registration Enhanced product tracing * Third party laboratory testing * * Required by SQF
- 7. © Scientific Certification Systems | 7© SCS Global Services | 7 Buying Chain Response “Food safety specifications required from the top down through the supply chain are far more stringent and effective than regulatory requirements.” - Report of the Food GMP Modernization Working Group
- 8. © Scientific Certification Systems | 8© SCS Global Services | 8 More Drivers for Implementing Food Safety and SQF In addition to new regulations and buyer specifications: Food-borne illness + “at risk” populations Greater understanding of the micro world: increased virulence, adaptation and better detection Global food supply and technology/transportation Protect reputation, reduce liability, and avoid negative press Reduce QA costs
- 9. © Scientific Certification Systems | 9© SCS Global Services | 9 Food Handlers (Manufacturers and Processors) – Roles and Responsibilities Good Manufacturing Practices (GMPs) and HACCP require: Safer design and construction of the Food Packaging Manufacturing Facility Safer design, construction, and operation of Food Packaging Manufacturing Equipment Prevention and avoidance of contamination Routine testing of raw materials, in-process, and finished products
- 10. © Scientific Certification Systems | 10© SCS Global Services | 10 Current Good Manufacturing Practices (cGMPs) 1. Creation & Document Control of SOP/SSOPs 2. Training & Education of Personnel 3. Personnel Practices – hygiene, product handling 4. Maintenance of Grounds 5. Pest Control 6. Safe Water Supply & Plumbing 7. Cold Storage Monitoring 8. Transport – product shipping and distribution 9. Microbial Testing 10. Pre-inspection procedures – cleaning & sanitation Based on FDA Regulation 21 CFR110.10 Additional (GFSI): Supplier Approval - Waste Management – Sustainability Practices 11. Control of physical (foreign material) contaminants 12.Hold & Release Program - adulteration 13.Cleaning Chemical Handling 14.Preventative Maintenance Program – equipment 15.Product Recall and Trace-back 16.Mock Recall 17.Calibration & Verification Procedures - equipment 18.Handling Regulatory Inspections
- 11. © Scientific Certification Systems | 11© SCS Global Services | 11 Training is Recognized as a Key Preventive Control Ongoing and targeted training on issues such as: • Allergen control • Cleaning and sanitation procedures • Incoming ingredient receipt protocol • Monitoring of employees and management • Supplier needs • Requirements of various internationally recognized food safety standards, such as SQF
- 12. © Scientific Certification Systems | 12© SCS Global Services | 12 First Step: SQF Training Promotes understanding of the SQF Code. Creates knowledge base to facilitate the successful implementation of an SQF system. Shows how a HACCP-based approach manages food safety and quality hazards in an operation. Discusses new regulatory and safety requirements. Meets SQFs training requirement.
- 13. © Scientific Certification Systems | 13© SCS Global Services | 13 SQF Training Center Offerings Course: Implementing SQF Systems (2-day) former 2000 standard covers Post farm-gate (GMP) For whom? Employees responsible for designing, implementing and maintaining the Code. Course Outline • Introduction to SQF • Implementing SQF Training • Preparing for SQF Certification • SQF Certification Process • Implementing an SQF System • SQF System Elements (Module 2) • GMPs and Post-Farm Gate (Module 11 and its derivatives)
- 14. © Scientific Certification Systems | 14© SCS Global Services | 14 Prerequisite HACCP Training 2-day or equivalent training + exam for Practitioner and other employees Must demonstrate understanding of HACCP principles and processes, and their role.
- 15. © Scientific Certification Systems | 15© SCS Global Services | 15 Training and Educational Options Public courses In-house courses Online SQFI Consultants SQF Resources online – Code, updates, checklists, guidance documents, food sectors, audit duration…
- 16. © Scientific Certification Systems | 16© SCS Global Services | 16 Global Food Safety Training 2013
- 17. © Scientific Certification Systems | 17© SCS Global Services | 17 Employee Training Program 3 Levels Senior Mgmt Middle Management/ QA Professionals All Employees / Workers SQF Elements BCP, Management Commitment & Review GMPs/GAP HACCP training SOP/SSOPs /WINs Documentation Training Records Topics covered, trainer, name and signature of attendees Refresher Training Annual /seasonal (as needed)
- 18. © Scientific Certification Systems | 18© SCS Global Services | 18 SQF Audit and Certification
- 19. © Scientific Certification Systems | 19© SCS Global Services | 19 Definition of the SQF System “A RISK management and PREVENTATIVE system that includes a Food Safety plan and Quality Plan at Level 3 implemented and operated by a supplier to ASSURE food safety and quality (Level 3).” SQF Code Edition 7. p. 152
- 20. © Scientific Certification Systems | 20© SCS Global Services | 20 SQF Requirements Management Commitment – Overview 2.1.1 Management Policy 2.1.2. Management Responsibility 2.1.2.4. Designation and responsibilities of SQF Practitioner 2.1.2.7. Staff knowledge of their roles in assuring food safety and quality 2.1.4. Management Review 2.1.5. Complaint Management 2.1.6. Business Continuity Planning Implement and maintain effective SQF Systems Support ongoing improvement
- 21. © Scientific Certification Systems | 21© SCS Global Services | 21 SQF Requirements Management and Supervisors Requirement 2.2.1 Document Control 2.3.1. Product Development 2.4.5 Incoming Goods 2.5.7 Internal Audits Responsibility QA Manager / SQFP R&D Manager Purchasing Manager QA Manager / SQFP
- 22. © Scientific Certification Systems | 22© SCS Global Services | 22 SQF Requirements Management and Supervisors Requirement 2.6.1. Withdrawal and Recall 2.8.2. Allergen Program 11.2.9. Premises and Equipment Maintenance 11.2.13. Cleaning and Sanitation 11.3. Personal Hygiene Responsibility CEO & Crisis Team Warehouse, Production, and Sanitation Managers Maintenance Manager Sanitation Manager All Managers
- 23. © Scientific Certification Systems | 23© SCS Global Services | 23 SQF Requirements Food Safety and QA Professionals 1.5. Designate SQF Practitioner
- 24. © Scientific Certification Systems | 24© SCS Global Services | 24 SQF Requirements Management SQF System Verification 2.5.1. Responsibility, Frequency and Methods 2.5.1. Validation and Effectiveness 2.5.3. Verification Schedule 2.5.4. Verification of Monitoring Activities 2.5.5. Corrective and Preventative Action 2.5.6. Product Sampling, Inspection and Analysis 2.5.7. Internal Audits SQF Practitioner / QA Requirement Responsibility
- 25. © Scientific Certification Systems | 25© SCS Global Services | 25 SQF Requirements Management Language / Literacy 2.9.5.1. Training materials and the delivery of training shall be provided in language understood by staff – note common languages + literacy
- 26. © Scientific Certification Systems | 26© SCS Global Services | 26 What’s the difference between Quality Control (QC) and a full-fledged Quality Management System (QMS)?
- 27. © Scientific Certification Systems | 27© SCS Global Services | 27 Quality Control (QC) Challenges Fact: Low skilled workers Inspectors backing up workers Inspectors accountable for Food Safety and QA Worker focus is productivity Creates friction within company QC model doesn’t focus on waste management Management outside of QA is not accountable for Food Safety and QA
- 28. © Scientific Certification Systems | 28© SCS Global Services | 28 Quality Management Systems (QMS) Model Senior management committed to Food Safety All management accountable for Food Safety and QA QA/SQFP play a control and support role Worker role is productivity combined with Food Safety and QA SQF training programs in place and effective to train lower skilled workers QMS model focuses on CI and waste reduction
- 29. © Scientific Certification Systems | 29© SCS Global Services | 29 The Cost of Quality Prevention Costs – Investment in Quality Activities designed to ensure that the product or service meets the customer’s requirements. Appraisal Costs Costs of inspecting, checking, testing, a product or service to ensure that required quality is achieved. Failure Costs Incurred when a product or service fails to achieve specified level – internal (product is within your control) and external (product is outside your control).
- 30. © Scientific Certification Systems | 30© SCS Global Services | 30 QC vs. QMS EF = External Failure IF = Internal Failure AC = Appraisal Costs PC = Prevention Costs
- 31. © Scientific Certification Systems | 31© SCS Global Services | 31 Planning for Certification Success Audit assesses each facility by interview and examination of records. Poor training results could result in a finding for non- conformance and a delay in certification, while time- consuming corrective actions are taken. Other non-conformances for packaging companies often include: Ineffective pest control procedures Inadequate worker sanitation facilities/procedures Inadequate cleaning or sanitation of equipment, production space, or storage of packaging product
- 32. © Scientific Certification Systems | 32© SCS Global Services | 32 Benefits of SQF Certification Meets retailer and other supply chain partner requirements Saves money through waste reduction (Raw Materials, Product, Labor) Increases productivity and net revenue (QC vs. QMS) Increases employee morale / reduces turn-over Reduces risk and liabilities associated with Food Safety scares
- 33. © Scientific Certification Systems | 33© SCS Global Services | 33 Choose SCS for your SQF Training, Auditing, and Certification Needs Food safety experts for three decades. SCS Food & Agriculture Team: Chip Wood, Director Business Development, cwood@scsglobalservices.com Heena Patel, Food Safety Auditing Dir, hpatel@scsglobalservices.com Carole Langston, Account Manager, clangston@scsglobalservices.com Diane Dulmage, Training Manager, ddulmage@scsglobalservices.com 510-452-8000 || www.scsglobalservices.com/food-and-agriculture
Editor's Notes
- Add logos instead of names; add other food logo (our NOP)
- Under contract to FDA, Eastern Research Group, Inc. (ERG) conducted an extensive literature review and an expert elicitation of current food safety problems and the range of preventive controls needed to address them.
- training imperative by including it among preventive controls necessary to ensure food safety.FDA is requesting comment on whether it should mandate training for employees and supervisors, including a requirement for records that document trainingWhat kind of produce does the proposed produce safety rule apply to?The proposed rule covers most fruits and vegetables while they are in their raw or natural (unprocessed) state. It would not apply to raw agricultural commodities that are rarely consumed raw, those produced for personal or on-farm consumption, and (with certain documentation) those destined for commercial processing, such as canning, that will adequately reduce microorganisms of public health concern.PS.3 How would the proposed rule define “farm”?The proposed rule would define “farm” to mean a facility in one general physical location devoted to the growing and harvesting of crops, the raising of animals (including seafood) or both. “Farm” includes (i) facilities that pack or hold food, provided that all food used in such activities is grown, raised, or consumed on that farm or another farm under the same ownership; and (ii) facilities that manufacture/process food, provided that all food used in such activities is consumed on that farm or another farm under the same ownership.PS.4 How would the proposed rule define “mixed-type facility” and “farm mixed-type facility?The proposed rule would define “mixed-type facility” to mean an establishment that engages in both activities that are exempt from registration under section 415 of the Federal Food, Drug, and Cosmetic Act (FD&C Act), and activities that require the establishment to be registered. An example of such a facility is a “farm mixed-type facility” which is an establishment that grows and harvests crops or raises animals and may conduct other activities within the farm definition, but also conducts activities that require the establishment to register with FDA under section 415 of the FD&C Act.PS.5 Who would be a “covered farm” under the proposed rule?The proposed rule would define “farm” and “mixed-type facility” (see above). Farms and farm mixed-type facilities that have an average annual monetary value of food sold during the previous 3-year period of more than $25,000 (on a rolling basis) would be “covered farms” under the proposed rule, unless they are eligible for the qualified exemption (see below) and FDA has not withdrawn their qualified exemption.The proposed rule would not apply to farms that have an average annual value of food sold during the previous 3-year period of $25,000 or less. FDA notes, however, that these farms are and will continue to be covered under the adulteration provisions and other applicable provisions of the FD&C Act, whether or not they are included within the scope of this proposed rule.PS.6 What qualified exemption is being proposed for certain farms under the proposed rule? As required by FSMA, certain farms would be exempt from most of the requirements of the proposed rule and would instead be subject to modified requirements. This qualified exemption could be withdrawn under certain circumstances. The following farms would be eligible for the qualified exemption: Farms for which, during the previous 3-year period preceding the applicable calendar year: The average annual monetary value of the food sold directly to qualified end-users during such period exceeded the average annual value of the food sold to all other buyers during that period; ANDThe average annual monetary value of all food sold during such period was less than $500,000, adjusted for inflation.PS.7 How would the proposed rule define “qualified end-user”?The proposed rule would define “qualified end-user” to mean, with respect to a food: The consumer of the food; OR A restaurant or retail food establishment that is located in the same state as the farm that produced the food, or not more than 275 miles from such farm.PS.8 How long will the public have to comment on the proposed rule? The comment period is open for 120 days from the date the proposed rule is published in the Federal Register. See www.regulations.gov.
- See binder for all GMP SOPs
- Under contract to FDA, Eastern Research Group, Inc. (ERG) conducted an extensive literature review and an expert elicitation of current food safety problems and the range of preventive controls needed to address them.
- & now offering Internal Auditing for SQF and GFSI programs
- What does it mean? Work instructions shall be available for all employees who carry out tasks that are part of the SQF System, e.g., contribute to meeting regulatory compliance; the food safety, quality and process efficiency controls Identified in the SQF System and customer specifications. What do I have to do? Instructions can be provided in a number of ways such as: •Written work instructions may be useful when a particular task is complicated (i.e., requiring skilledoperators) or repetitious (e.g., mundane work that generally results in a high turnover of staff and requires a constant training effort). These instructions can serve as a valuable training reference when staff needs to check the correct way of doing a task. Written instructions can be in the form of pre-requisite programs (refer 2.3.1 i) and will be available (if practical) where the task is performed. •Photos and diagrams can be particularly useful to overcome language barriers or when a task involves anumber of different steps. Instructions may be included in the food safety andquality manual (2.1.3), and must be kept up to date as process or System requirements change. 2.9.3 Auditing Guidance Work instructions will be assessed at the initial desk audit and compliance at each facility audit byInterview with key personnel, observation of tasks and examination of records. Evidence may include: •There are specific work instructions for maintenance of food safety plan and associated tasks; •There are specific work instructions for maintenance of pre-requisite programs and other tasks relatedGuidance for Developing, Documenting, Implementing,Maintaining and Auditing an SQF System SQF Code, Edition 7.1 – Module 2: SQF System Elements •There are specific work instructions for adherence to customer specifications; •Work instructions are known and applied by personnel conducting food safety and quality tasks; •Work instructions are updated as changes occur to the process or the SQF System.
- Almost 85 percent of food companies use on-the-job training, which was closely followed by reading policies, refresher courses and traditional classroom-based learning. It is worth noting that e-learning and interactive training were used by 39 percent and 14 percent of companies, respectively. However, with only 66 percent of companies stating they are very satisfied or satisfied with the quality of training undertaken there is clearly room for improvement. The biggest deficiencies identified were a lack of employee understanding and incomplete training records.
- What about the 3 year industry standard Heena?