SQF Certification for Food Packaging Plants

Dr. Bob Strong - Senior Consultant - SAI Global (Americas)

April 2014

Our Presenter Today Dr. Bob Strong • Senior Consultant – SAI Global Assurance Services

• Ph.D. and BSC in Chemistry and an accomplished food safety trainer for numerous food safety manager certification courses

• Driving force behind our food safety operations in the areas of Good Manufacturing Practice (GMP), Good Agricultural Practice (GAP) and supplier assurance programs, including SAFE, SQF and BRC

• 44 years of experience in the food industry, while working for national and international companies in quality assurance, product development and auditing. He is an oft-requested seminar speaker in the areas of GMP and HACCP

• In addition, he is a GMP/HACCP instructor, a Lead Auditor trainer, and is also certified to consult on the Global Food Safety Initiative by SQF. Dr. Bob is certified in 20 product categories.

Agenda • What is GFSI? • What is SQF? • Road to Certification for Packaging Plants • Mandatory requirements • Exemptions, when applicable • How to apply for a Variance • Module 2 requirements • Module 13 requirements • Scoring numerical and grade • Road map to Certification • Q&A

Global Food Safety Initiative

Global Food Safety Initiative (GFSI) Started by CIES (The Food Business Forum) in Paris in 2000

• Now called the Consumer Goods Forum (CGF) • 400 members, 150 countries • Non-profit foundation

Focus is a simple set of rules for accepting different standards, establishing harmony between countries & auditing efficiency by:

• benchmarking food safety standards worldwide • facilitating cooperation between standard owners • assurance of quality of certification & accreditation

Global Food Safety Initiative (GFSI ) The GFSI guidance document sets the minimum

requirements for: • Food Safety Management Systems • GMPs, GAPs, GDPs • HACCP • Delivery of Food Safety Management Systems

All standards to get approved must meet these minimum requirements in the GFSI guidance document

Standards owners can go above and beyond the requirements to add value

GFSI Vision Initially was Once certified, Accepted Everywhere

Is now Safe Food for Consumers Everywhere

Mission: Driving continuous improvement in food safety to strengthen consumer confidence worldwide

Reduce food safety risks Manage cost

Develop competencies and capacity building

Knowledge exchange and networking

GFSI

Initial Companies Involved with GFSI in 2000 • Albertson’s • Campbell’s • Carrefour • Danone • Delhaize (Food Lion,

Hannaford) • Hormel • Kroger • Metro AG

• Migros • Royal Ahold • Sara Lee • Tesco (Fresh and Easy) • Tyson • Wakefern • Wal-Mart

Governance: GFSI Board of Directors

Providing strategic direction and supervision of GFSI, and governance to the GFSI Technical Working Groups

Chair Vice-Chairs

Board Members

Nestle

Convergence Means Confidence Benchmarking work was originally carried out in 2000 on four

food safety schemes (BRC, IFS, Dutch HACCP and SQF) to reach a point of convergence.

All of the 9 currently approved schemes are completely aligned with the GFSI Guidance Document Version 6 Requirements issued in 2011.

GFSI Guidelines will be reviewed again in 2014 for possible updating

GFSI Benchmarked and approved schemes

SQF Code Edition 7.2

About SQF (Safe Quality Food) Originated as an Australian standard in 1994

Purchased by FMI in 2004 and is now operated by the Safe Quality

Food Institute in the United States

One of the first 4 Schemes approved by GFSI in 2004

3 Certification Levels

Only Scheme offering a Quality Level over and above Food Safety

Current Edition is 7.1 and is available for free from www.sqfi.com

Edition 7.2 will be effective on July 3rd 2014

SQF Levels of Certification

Level 3

Level 2

Level 1

Level 1 • Food Safety Fundamentals (Pre-requisite programs) +

Building and Equipment

Level 2 • Adds in the Food Safety Plans (HACCP) • Element 2.4.3 (GFSI Approval level)

Level 3

• Adds in the Food Quality Plans • Element 2.4.4 (Above GFSI approval requirement)

3 Levels of Certification

Initial Certification Process requires two separate audits: • Desk/Document audit (Readiness audit) • Facility Audit

Recertification annual audits only require 1 audit which is a combination of both.

SQF has products and services divided into 35 Food Safety Categories (FSC) of which Category 27 is “Manufacture of Food Sector Packaging Materials”.

SQF Initial Certification Audits

SQF Initial Certification Audits Desk/document audit is a review of all your documented programs, policies and procedures as required by the SQF Code for manufacturers of food packaging materials. Hence this is a review of what you say you do. This can be done on site or at a mutually agreeable location and is a non-graded evaluation. All deficiencies in the documentation identified in this review have to be corrected before the auditor can return to conduct your facility audit. In future years there is no separate document review.

SQF Initial Certification Audits Facility audit is an audit of your total facility as to compliance with these documented programs, policies and procedures. The auditor looks at your equipment, building, processes, records, etc. and this is a graded evaluation. Hence this is to see if you do what you say and can prove it. All deficiencies in this audit cause you to lose points and require that they all be corrected before the Certifying Body can issue you your SQF Certificate.

Requires an SQF Practitioner Employed by the Supplier • In a full-time at the facility being certified • In a position to manage the program

HACCP Knowledge • Have completed a HACCP Course • Be competent to implement & manage HACCP plans

SQF Code Knowledge • Be competent to implement & manage SQF Programs • Taking “Implementing SQF Systems” Course (highly recommended) • Taking and passing the “Implementing SQF Systems” on-line exam

(highly recommended)

SQF Code requires that you Say what you do in writing

Do what you say

Have the records to prove it

SQF Code requires You meet the regulatory requirements of the Country in which

you operate as well as to those of each country that you sell your product to.

That you meet your Customer requirements.

That you comply with the current edition of the SQF Code.

That you practice Continuous Improvement.

SQF Code requires that packaging manufacturers Comply with the requirements of the following SQF Modules:

• Module 2: SQF System Elements • Module 13: Pre-requisite programs for the manufacturing

of Food sector packaging

Mandatory Elements These are SQF sub-elements that are required to be documented and implemented by everybody.

• Cannot be excluded by the facility applying for certification • Cannot be exempted by the Certifying Body • Cannot be marked non-applicable (NA) by the auditor

Applies to Module 2 only

Mandatory Elements (20) 2.1.1 – Management Policy 2.1.2 – Management Responsibility 2.1.3 – Food Safety and Quality Management System 2.1.4 – Management Review 2.2.1 – Document Control 2.2.2 – Records 2.4.1 – Food Legislation 2.4.2 -- Food Safety Fundamentals 2.4.3 – Food Safety Plan (levels 2, 3) 2.4.4 – Food Quality Plan (level 3 only)

Mandatory Elements (20) 2.4.8 – Product Release 2.5.2 – Validation and Effectiveness 2.5.4 – Verification and Monitoring 2.5.5 – Corrective and Preventative Action 2.5.7 – Internal Audit 2.6.1 – Product Identification 2.6.2 – Product Trace 2.6.3 – Product Withdrawal and Recall 2.7.1 – Food Defense 2.9.2 – Training Program

SQF Code possible exemptions

Certain sub-elements in these Modules however may not be applicable to you and so they will not apply

If you only go SQF Level 2 then the following sub-elements do not apply and the SQF auditor will not expect you to provide any evidence (programs or records) for these sub-elements.

These sub-elements will apply if you apply for certification at Level 3:

2.4.4. Food Quality Plan 2.8.1. Identity Preserved Foods

SQF Code possible exemptions Certain sub-elements in these Modules may not be applicable and if so then they will also not apply.

The following sub-elements may not apply to your facility and the auditor will agree if you provide evidence that they do not.

2.3.4. Contract Manufacturer program 2.4.7. Rework program 2.8.2. Allergen Management program 13.5.4. Air Supply 13.6.4. Alternate Storage

The SQF Code

SQF System Elements Module 2

Terms Used in Module 2

“Food” also means “feed,” “pet food,” or

“food contact packaging materials.”

Module 2 – Elements Overview 2.1 – Management Commitment 2.2 - Document Control and Records 2.3 – Specification and Product Development 2.4 – Attaining Food Packaging Safety 2.5 – SQF System Verification 2.6 – Product Identification, Trace, Withdrawal and Recall 2.7 – Site Security 2.8 – Identity Preserved Foods 2.9 – Training

Module 2 defines management-level commitments including Statement of management’s commitment to provide safe, quality

food packaging Designation of an SQF practitioner Creation and documentation of organization’s food safety plans (Level 2) and quality plans (Level 3) Addressing non-conforming products and equipment

Module 2 defines management-level commitments including Development and execution of an internal audit process.

Documentation and implementation of a food defense program.

Creation of systems to address food allergens, if applicable.

Execution of an effective and appropriate training program.

2.1 Management Commitment - Overview

2.1.1 – Management Policy (M) 2.1.2 – Management Responsibility (M) 2.1.3 – Food Safety and Quality Management System (M) 2.1.4 – Management Review (M) 2.1.5 – Complaint Management 2.1.6 – Business Continuity Planning

Each Module 2 element contains sub-elements

2.1 Management Commitment (M) Success of your SQF System is contingent upon: A signed commitment by Senior Management at your facility to:

• Implement and maintain an effective SQF System • Support ongoing improvement • Provide adequate resources

2.1.6 Business Continuity Management Documented program that:

• Defines the handling of a potential business crisis that may

impact ability to deliver safe, quality food packaging • Prepared by senior management • Defining methods and responsibility • Risk assessment of each type of crisis • Crisis management team (a top nonconformity)

2.1.6 Business Continuity Management

• Includes controls implemented so product safety and quality not compromised

• Includes isolation and identification of affected product • Verification of product prior to release • Crisis alert contact list • Sources of legal and expert advice • Internal and external communications • Annual review – testing + verification (One of top nonconformities) • Records • Product withdrawal and recall

2.2.1 Document Control – Registers to be Maintained 2.2.1.1 SQF System Documents and Amendments 2.3.2.6 Raw and Packaging Materials Specifications and Labels 2.3.3.2 Contract Service Providers and Specifications 2.3.5.2 Finished Product Specifications

2.2.1 Document Control - Registers to be Maintained 2.4.5.5 Approved Suppliers and Records of Inspections and Audits of Suppliers 2.8.2.1 Allergens (if applicable) 2.9.7.1 Training Skills Register 3.2.9.3 Pesticides/Pest Control Chemicals 13.7.1.3 Glass Register

2.4.3 Food Safety Plan (M) Outlines how facility will control and assure food safety:

• Prepared using a HACCP-based method

• Cover product and associated processes

• Describe the methodology and results of a hazard analysis

• 4th highest nonconformity is a poor hazard analysis

2.5 SQF System Verification

2.5.1 – Responsibility, Frequency and Methods 2.5.2 – Validation and Effectiveness (M) 2.5.3 – Verification Schedule 2.5.4 – Verification of Monitoring Activities (M) 2.5.5 – Corrective and Preventative Action (M) 2.5.6 – Product Sampling, Inspection and Analysis 2.5.7 – Internal Audits (M)

2.5.2 Validation and Effectiveness (M) Document and implement methods, responsibility and criteria for ensuring the effectiveness of the pre-requisite programs (PRPs) and validating any critical food safety (CCPs) and critical quality limits (CQPs).

• Confirm they achieve required results • Critical limits are selected to achieve designated level of control

of identified hazard or threat Failure to document how you determined your PRPs are effective is the 10th biggest nonconformity.

2.5.7 Internal Audits (M) Document and implement methods for scheduling, conducting internal audits (incl. factory and equipment inspections) (One of largest nonconformities) • Internal audit schedule • Action taken to correct deficiencies found • Maintenance of records • Results communicated to relevant staff • Staff conducting internal audits trained in internal audit

procedures • Staff independent of the function being audited, where possible

Good Manufacturing Practices for Production of Food Packaging Materials

SQF Code Module 13

Based on Edition 7.2 effective 7/3/14

Module 13 Elements 13.1 – Site Requirements and Approval 13.2 – Construction and Control of Product Handling and Storage Areas 13.3 – Personnel Hygiene and Welfare 13.4 – Personnel Processing Practices 13.5 – Water and Air Supply 13.6 – Storage and Transport 13.7 – Control of Foreign Matter Contamination 13.8 – Waste Disposal 13.9 – Exterior

All items in Section 13 are “Shalls” Exclusions to these requirements or alternate methods of control are

permitted, however they need to be supported by a detailed risk analysis outlining the basis for any exclusion and demonstrating food packaging safety is not compromised. The risk assessment must contain:

• A description of the element of the standard and the hazards which need to be addressed.

• The control protocol which the facility will implement to ensure the identified hazards are controlled.

• Validation that the protocols are properly implemented and effective.

Not all Module 13 sub-elements need documenting 13.1.1 – Premises Location 13.1.2 – Construction and Operational Approval 13.2.1 – Materials and Surfaces 13.2.2 – Floors, Drains and Waste traps 13.2.3 – Walls, Partitions, Doors and Ceilings 13.2.4 – Lighting and Light Fittings 13.2.5 – Dust, Fly and Vermin Proofing 13.2.6 – Ventilation 13.2.10 – Equipment, Utensils and Protective Clothing

Not all Module 13 sub-elements need documenting 13.3.2 – Hand Washing facilities 13.3.3 – Clothing provided (if applicable) 13.3.6 – Staff Amenities 13.3.7 – Change rooms/Locker rooms (if applicable) 13.3.8 – Sanitary Facilities 13.3.9 – Lunch Rooms 13.3.10 – First Aid 13.6.1 – Storage Conditions for packaging materials and products 13.6.2 – Storage Conditions for equipment 13.9 – Exterior

Following programs do need documenting

13.2.7. Premises and Equipment Maintenance • Document plan showing methods and responsibility

• Minimize risk of product contamination • Needs to include maintenance and repair of warehouse, equipment and buildings

• Routine maintenance in accordance with Maintenance schedule

• Document, review, incorporate into maintenance control schedule all equipment failures

• Follow personnel hygiene and welfare (see13.3)

• Remove all tools, debris once maintenance completed • Inform the area Supervisor so appropriate hygiene and sanitation can be

completed

• Need to document annually how you determine your maintenance program is effective

13.2.8. Calibration Document and implement showing methods and responsibility for

calibration and re-calibration of measuring equipment used for any monitoring activities (Calipers, etc.).

Document and implement procedures to address the disposition of potentially affected product if equipment is found to be out of calibration.

Protect equipment from damage and unauthorized Adjustment.

Need to document annually how you determine your calibration program is effective.

13.2.9. Management of Pests and Vermin Document and implement showing methods and responsibility

for integrated pest management. Premises, surrounds, ancillary storage areas, machinery and

equipment kept free of waste or accumulated debris so as not to attract pests and vermin.

Need to document annually how you determine your pest control program is effective.

13.2.11. Cleaning and Sanitation Document and implement methods and responsibility for cleaning food

packaging processing equipment and food packaging storage areas, transport equipment and staff amenities and toilet facilities.

• Consider:

What is to be cleaned

How it is to be cleaned

When it is to be cleaned

Who is responsible for the cleaning

Responsibility and methods for verification of effectiveness

Need to document annually how you determine your sanitation program is effective.

13.3. Personnel Hygiene and Welfare 13.3.1 – Personnel’s health 13.3.4 – Jewelry and Personal Effects 13.3.5 – Visitors

13.3.1 Personnel Personal health

• Do not handle product if suffering from or being a carrier of infectious diseases

• Note – health questionnaire, screening Cuts and lesions

• Do not handle product or food contact packaging materials if exposed cuts, sores or lesions are present

• Cover minor cuts, abrasions with suitable waterproof colored bandage or bandaid

Personal practices • No smoking, chewing, eating, drinking or spitting in

any food packaging handling or storage areas

Drinking on the processing floor variance. As the SQF Code prohibits any drinking on the processing floor

as product is exposed you are going to have to apply for a variance from the Certifying Body prior to your facility audit if you allow drinking or you will receive a non-conformity.

Variances can only be granted by Certifying Bodies not by auditors.

Variance request has to be in writing and the Certifying Body has the right to grant or deny the variance.

Cannot be appealed to SQFI as the SQF Code does not permit drinking where product is exposed.

13.5.4. Air Quality Compressed air used in the food packaging operations shall be:

• Clean and present no risk to food packaging safety. • Regularly monitored for environmental contaminants. • Test annually for Aerobic Plate Count and Molds and

Yeasts

13.6 Storage and Transport 13.6.1 – Storage of Food Packaging 13.6.2 – Storage of Equipment 13.6.3 – Storage of Hazardous Chemicals and Toxic Substances 13.6.4 – Alternative Storage and Handling of Goods 13.6.5 – Loading, Transport and Unloading Practices 13.6.6 – Loading/Unloading

13.6.4. Alternative Storage and Handling of Goods Where goods described in 13.6.1 to 13.6.3 are held under temporary or overflow conditions that are not designed for the safe storage of goods, a risk analysis shall be undertaken to ensure there is no risk to the integrity of those goods or contamination or adverse affect on food packaging safety and quality.

13.7.2. Control of Foreign Matter Contamination.

Glass register – list glass objects or similar material in food packaging processing areas showing location.

Containers, equipment, utensils made of glass, porcelain, ceramics, testing glassware or like material (except where packaging product packaged is glass/like materials, instruments with glass dial covers, thermometers).

Regular inspections of processing areas, affirm condition of items in glass registry.

Inspect glass instrument dial covers, MIG thermometers at start and finish of each shift in processing areas if they cannot be eliminated or protected to confirm they have not been damaged.

NON-CONFORMITIES

SCORING

GRADING

Minor Nonconformity

A Minor Nonconformity shall be corrected, verified and closed out within thirty (30) calendar days of the completion of the Facility Audit

Extensions may be granted by the Certification Body where there is no immediate threat to product safety and quality, and alternative, temporary methods of control are initiated

Major Nonconformity A Major Nonconformity shall be corrected and appropriate

Corrective Action verified and closed out within fourteen (14) calendar days of the completion of the Facility Audit

Critical Nonconformity A Critical Nonconformity raised at a Certification Audit results

in an automatic failure of the audit & the Supplier must reapply for certification

The Auditor shall immediately advise the Supplier and Notify the Certification Body

(If re-application occurs within 6 months and with the same CB, no desk audit is required)

SQF Non-conformances These non-conformances can occur during the Desk

(Document) audit or during the Facility (Site) audit. ONLY FACILITY AUDIT IS SCORED.

Scoring effect of facility non-conformances on the possible score of 100.

• Critical (Minus 50 points) • Major (Minus 10 points) • Minor (Minus 1 point)

All non-conformances should be corrected before an SQF Certificate will be issued however if all minor nonconformities have not been corrected a certificate can still be issued within 45 days of last day of facility audit.

Audit Score Score Rating Certification Audit

Frequency 96 - 100 E – Excellent Certificate issued 12 monthly

re-certification audit.

86 - 95 G – Good Certificate issued 12 monthly re-certification audit.

70 - 85 C – Complies Certificate issued 6 monthly surveillance audit required.

0 - 69 F – Fails to comply

No certificate issued

Considered to have failed the SQF Audit.

The SQF Certification Process

Select a Certification

Body

Identify the Scope of

Certification Select an Auditor

Identify the Scope of the

Audit Desk Audit Facility Audit

The Audit Report

Granting Certification

Maintenance of

Certification

SQF Annual Meeting 2014

Renaissance Hotel

Sea World Orlando

Oct 28-30th, 2014

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Public training On-site training eLearning courses http://www.saiglobal.com/training/assurance/eLearning/

ISO 9001 Essentials for Everyone

Introduction and Refresher to HACCP Food Safety Systems

Upcoming SQF Public Training Courses SQF Internal Auditing

Date Location May 8-9 Dallas

May 21-22 Charlotte

Jun 10-11 Chicago

June 25-26 Boston

Aug 14-15 Chicago

Sept 4-5 Boston

Sept 25-26 Orlando

Oct 2-3 Los Angeles

Oct 23-24 St. Louis

Oct 27-28 Vancouver

HACCP For Food Processors

SQF Code Edition 7.2 - Implementation Course Date Location

May 1-2 St. Louis

May 8-9 Boston

May 14-15 Los Angeles

May 15-16 Chicago

May 22-23 Boston

June 5-6 Vancouver

June 12-13 Calgary

June 26-27 Toronto

July 17-18 Baltimore

July 24-25 Vancouver

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Date Location

May 6-7 Baltimore

May 12-13 Los Angeles

May 13-14 Chicago

May 20-21 Boston

June 3-4 Vancouver

June 10-11 Calgary

June 24-25 Toronto

July 15-16 Baltimore

July 22-23 Vancouver

July 29-30 Orlando

Advanced Practitioner Training Course SAI Global is pleased to announce the following dates and locations for this new 2-day course. SQF Advanced Practitioner Training Date Location May 5-6 Chicago May 22-23 Toronto June 24-25 Dallas July 7-8 Vancouver July 22-23 Los Angeles Aug 7-8 Montreal Aug 12-13 Orlando

Date Location Sept 8-9 Toronto Sept 16-17 Boston Oct 9-10 Charlotte Oct 23-24 Calgary Nov 20-21 Vancouver Dec 2-3 Chicago

Training & Improvement Solutions

10% Discount* Code: SQFPACKAGING10

*Not valid for eLearning or on-site courses

www.saiglobal.com/courses

Assurance Services SAI Global can offer on-site consulting for SQF including:

Design of your entire program On-site GAP analysis HACCP program facilitation Program review & development Allergen program review and validation Product specification building

Food Safety Services TRANSFER your GFSI, HACCP, etc. today! Local auditors, Global reach:

SQF BRC FSSC 22000 IFS HACCP GMP-SAFE

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Dr. Bob Strong Senior Consultant 513-349-5398 Bob.Strong@saiglobal.com