SQF Audits - Top 10 Non-conformances of 2014

SQF Top 10 Non-Conformances of the Year

Copyright Alchemy Systems LP. All rights reserved.

Holly MockusProduct Manager

Alchemy

LeAnn ChuboffSr. Technical Director

Safe Quality Food Institute

Speakers


Agenda

Identify top non-conformances

from desk audits

Review on Top 10 non-

conformances from last 12

months (Data for Version 7.2)

Module 2

Module 11

Food safety risks from top non-

conformances


Top Non-Conformances From Desk Audits

Desk audits conducted: Level 1 - 11; Level 2- 727; Level 3 - 307

Clause Compliant Minor Major OIP Percentage

2.4.3.1 Food Safety Plan (2D, 3D) (M)(full program) 672 275 50 32 48.40

2.6.3.1 Product Withdrawal and Recall (2D, 3D) (M) (full program) 724 249 26 29 38.002.1.6.2 Business Continuity Planning (2D, 3D) (elements of the program) 729 248 4 24 34.602.1.6.3 Business Continuity Planning (2D, 3D) (testing annually) 721 246 3 29 34.502.1.2.8 Management Responsibility (2D) (M) (job descriptions food safety backup) 534 165 7 20 28.502.3.3.2 Contract Service Providers (2D, 3D) (register of service providers) 778 207 3 26 27.002.4.5.4 Incoming Goods and Services (2D) (approved supplier program) 547 146 1 9 26.902.5.7.1 Internal Audits (3D) (M) (full program) 268 25 3 9 19.60


Top Non-Conformances From Module 2 – Facility

Audits

Audits conducted: level 1 – 27; level 2 – 2967; level 3 - 3648

Clause Compliant Minor Major OIP Percentage

2.4.3.1 Food Safety Plan (2, 3) (M) (full program) 5114 1107 159 219 24.95

2.2.2.2 Records (2, 3) (M) (legible and reviewed) 5545 871 23 165 16.10

2.5.7.1 Internal Audits (3) (M) (full program) 3242 306 12 87 11.922.8.2.1 Allergen Management (2, 3)(full program inc validation) 5221 567 28 113 11.402.1.6.3 Business Continuity Planning (2, 3) (annual testing) 5777 641 0 145 11.10

2.4.4.1 Food Quality Plan (3) (M) (full program) 3206 331 15 87 10.802.6.3.1 Product Withdrawal and Recall (2, 3) (M) (full program) 5959 497 13 110 8.602.5.5.2 Corrective and Preventative Action (2, 3) (M) (records of investigation and CA) 6054 420 8 68 7.102.6.2.1 Product Trace (2, 3) (M) (effectiveness of traceability, annual test) 6104 380 18 107 6.502.3.3.1 Contract Service Providers (3) (specifications of service and training) 3349 184 0 70 6.20


SQF Audit Top 10 Primary ResponsesMinor Major Critical

11.2.12.1 Equipment, Utensils and

Protective Clothing2.4.3.1 Food Safety Plan (2, 3) (M) 2.4.3.1 Food Safety Plan (2, 3) (M)

2.4.3.1 Food Safety Plan (2, 3) (M)2.4.3.1 Food Safety Plan (2D, 3D)

(M)

11.7.6.2 Detection of Foreign

Objects

11.2.3.1 Walls, Partitions, Doors and

Ceilings

2.5.1.2 Responsibility Frequency

and Methods (2D)2.2.2.2 Records (2, 3) (M)

11.2.2.1 Floors, Drains and Waste

Traps

2.5.2.1 Validation and Effectiveness

(2D) (M)

2.3.1.5 Specification and Product

Development (2, 3)

2.2.2.2 Records (2, 3) (M) 11.2.13.1 Cleaning and Sanitation 10.2.13.4 Cleaning and Sanitation

11.2.7.1 Dust, Fly and Vermin

Proofing11.7.4.1 High Risk Processes

11.7.5.3 Control of Foreign Matter

Contamination

11.2.11.1 Management of Pests

and Vermin

11.2.13.1 Cleaning and Sanitation 2.8.2.1 Allergen Management (2, 3)

11.4.1.1 Staff Engaged in Food

Handling and Processing Operations

11.7.6.2 Detection of Foreign

Objects

2.1.6.3 Business Continuity

Planning (2, 3)

11.7.5.1 Control of Foreign Matter

Contamination

6


Top Non-Conformances From Module 11 – Facility

Audits

Audits conducted - 4631

Clause CompliantMinor Major OIP Percentage

11.2.12.1 Equipment, Utensils and Protective Clothing (condition of equipment and utensils) 3146 1307 25 111 29.02

11.2.3.1 Walls, Partitions, Doors and Ceilings 3480 996 7 111 21.83

11.2.2.1 Floors, Drains and Waste Traps (floors) 3476 890 8 226 19.52

11.2.7.1 Dust, Fly and Vermin Proofing (outer openings) 3651 841 5 96 18.42

11.7.5.3 Control of Foreign Matter Contamination (Temporary repairs) 3684 778 1 103 17.06

11.2.13.1 Cleaning and Sanitation (SSOPs) 3647 771 34 149 17.50

11.4.1.1 Staff Engaged in Food Handling and Processing Operations (Employee hygiene) 3846 679 7 67 14.92

11.2.11.1 Management of Pests and Vermin(pest control program) 3904 555 30 105 12.73

11.2.9.2 Premises and Equipment Maintenance (food contact zone repairs) 3959 534 2 105 11.65

11.7.5.4 Control of Foreign Matter Contamination (glass policy) 3987 517 5 86 11.36


Risk From Top Non-Conformances That Can Affect

Product Recalls

Module 2 Module 11

2.4.3.1 Food Safety Plan (2, 3) (M) (full program)2.2.2.2 Records (2, 3) (M) (legible and reviewed)

2.5.7.1 Internal Audits (3) (M) (full program)

2.8.2.1 Allergen Management (2, 3)(full program inc validation)

2.1.6.3 Business Continuity Planning (2, 3) (annual testing)

2.4.4.1 Food Quality Plan (3) (M) (full program)

2.6.3.1 Product Withdrawal and Recall (2, 3) (M) (full program)

2.5.5.2 Corrective and Preventative Action (2, 3) (M) (records of investigation and CA)2.6.2.1 Product Trace (2, 3) (M) (effectiveness of traceability, annual test)

2.3.3.1 Contract Service Providers (3) (specifications of service and training)

11.2.12.1 Equipment, Utensils and Protective Clothing (condition of equipment and utensils)

11.2.3.1 Walls, Partitions, Doors and Ceilings

11.2.2.1 Floors, Drains and Waste Traps (floors)

11.2.7.1 Dust, Fly and Vermin Proofing (outer openings)

11.7.5.3 Control of Foreign Matter Contamination (Temporary repairs)

11.2.13.1 Cleaning and Sanitation (SSOPs)

11.4.1.1 Staff Engaged in Food Handling and Processing Operations (Employee hygiene)

11.2.11.1 Management of Pests and Vermin(pest control program)

11.2.9.2 Premises and Equipment Maintenance (food contact zone repairs)

11.7.5.4 Control of Foreign Matter Contamination (glass policy)


Discussion on Audit Results

Not all audit criteria specifically relates to food safety

management (industry best practices, product

quality, dependent on risk)

Auditors can audit and identify non-conformances

which are observable and auditable

Rarely see product contamination, cannot see

microorganisms

Rarely see cross-contact, observe conditions

which may allow it

Approved supplier program, important in risk

management, focus is more on approval criteria


Discussion on Audit Results (cont.)

Food safety management systems top non-

conformance in both program and practice –

driving awareness of improving HACCP plans

Both industry and auditors must continue to

focus on food safety risks, audits are a tool to

manage those risks, but focus must include

training, awareness and education activities to

continue to drive improvement

Standards are reviewed to continually focus the

criteria on food safety risks and product quality

risks


NCRs

that are

being

raised

NCRs

that are

being

missed

Many key issues are

being raised

Some key issues are

being missed

We are doing well…..

…. We need to do better

Renovate

Repair

Refresh

Training Makes it all Happen

Holly Mockus Product Manager, Alchemy


Renovate

Business continuity plan annual tests –

scheduled or not

Employee interviews? – Get ‘em talking

Records – check them every day as they are

turned in

Traceability – mock trace exercises – and make

them hard!

GMP’s – observe, correct, reinforce, coach

Internal audit – robust, structured, preventive!

Temporary repairs

Foreign material exclusion procedures

Facility condition

Allergen management


Repair

Don’t treat the symptoms – fix the root

cause

Ensure the ‘fix’ is effective

Document, Document, Document

Tell the story – paint the picture

Poor documentation is as bad as no

documentation

Get credit for all the great things your

facility does

Live it, breathe it, keep it top of mind

Lead through training……..


Refresh

“Effective leaders are, first and foremost, good teachers.”

“A leader who is through learning is through. You must never become satisfied with your ability or level of knowledge.”

- John Wooden. “Wooden on Leadership”

A leader who is through teaching is through. Never become satisfied with the

ability or level of knowledge of your workforce.


Training - a Journey Not a Destination

Knowledgeable, Empowered, Engaged Workforce

The more you teach – the more they will want to learn

Use every opportunity to educate

Awareness keeps it top of mind

‘HOW’ begins the journey – ‘WHY’ builds the culture

Coach through positive reinforcement

Hold people accountable

BUILD YOUR CULTURE!


Q & A

Alchemy Systems

www.alchemysystems.com

Safe Quality Food Institute

www.sqfi.com