The “GFSI in the Age of FSMA” three-part series wrapped up in early December, providing the food safety community insight on how leading GFSI schemes align with, and help prepare for, compliance with FSMA. The series was presented by SafetyChain with media partner FoodSafetyTech.
Each GFSI scheme leader from SQF, BRC and FSSC 22000 discussed how their schemes align with FSMA in several key areas, including Supply Chain Controls, migrating Food Safety Plans from HACCP to HARPC, and audit readiness. While each scheme leader provided insights and details on how their scheme aligns with FSMA, common key themes across all three sessions included:
- FSMA’s focus on prevention vs. reaction is similar and aligns with GFSI’s objectives; Scheme certifications and ongoing compliance is centered around continuously assessing risks and putting preventive measures in place to mitigate those risks
- GFSI’s global approach surrounding a company’s food safety program—to ensure better supply chain controls internally, upstream and downstream prepares companies to manage FSMA’s increased focus on both domestic and foreign supplier compliance
- GFSI stringent documentation and recordkeeping requirements—along with unannounced audit protocols—are a strong foundation to help food and beverage companies prepare for FSMA’s “if it isn’t documented you didn’t do it” mantra
The GFSI scheme leaders also spoke about the importance and opportunity companies have to leverage technology tools to help more effectively manage the complexities and requirements of GFSI and FSMA compliance. Series participants were able to see an example of how these automation tools work and the impact they can have on managing a robust food safety program via a post session demo of SafetyChain Software.
Archived recordings of all three sessions—SQF in the Age of FSMA, featuring Robert Garfield, Senior VP, SQF; BRC in the Age of FSMA, featuring John Kukoly, Director, BRC Americas; and FSSC 22000 in the Age of FSMA, featuring Jacqueline Southee, U.S. Liaison, FSSC 22000—are available and can be accessed here.
“Over a period of time, things have changed for the corner suite, and many CEOs and presidents of corporations understand that with the media today and the way that FDA has improved its ability to focus on contamination, something needed to happen,” said Robert Garfield, senior vice president at SQFI during the recent “SQF in the Age of FSMA” webinar. “It’s not everything that we wanted…but it’s a rule that brings the regulations up to where they need to be in this century.”
GFSI leaders will be available during the Food Safety Consortium conference. On Wednesday, November 18, don’t miss the session, “The Role of Technology in Ensuring Accessible, Actionable Data to Tackle FSMA Compliance”. LEARN MOREGarfield discussed the role of SQF certification in FSMA compliance during part one of the 2015 GFSI Leadership webcast series. Hot topics included:
- Foreign supplier verification program alignment
- Building a food safety plan, including HACCP to HARPC migration
- Being audit ready and record keeping requirements
- Environmental monitoring
- “Farm-to-fork” and safety controls
- SQF scheme changes to align with FSMA
- How SQF fills in the gaps in FSMA requirements
The next webinar takes place Friday, October 30 and covers the alignment of BRC certification with FSMA. John Kukoly, director of BRC Americas, is the featured speaker. Register here for the complimentary webinar.
The Global Food Safety Initiative Board of Directors is pleased to announce that SQF has achieved recognition against the Guidance Document Sixth Edition for the scope of Storage and Distribution (J). This is in addition to the scopes for which SQF has already achieved GFSI recognition (AI, BI, C, D, EI, EII, EIII, EIV, F, L and M). The GFSI Guidance Document’s Scope J, Provision of Storage and Distribution Services, is the latest extension to the scopes covered by the GFSI benchmarking requirements, and includes the management of safety schemes for storage facilities and the distribution vehicles for food and feed.
Scopes of Recognition
The GFSI Benchmark Committee was led by Kevin Swoffer, director, KPS Resources Ltd with the support of Cloeann Durham, Sr. Director Quality ; CCBCC, The Coca-Cola Company and Bizhan Pourkomailian, Director Food Safety and Supplier Workplace Accountability, McDonald’s.
“The GFSI Board is delighted to recognize yet another food safety scheme against the GFSI requirements for storage and distribution activities. SQF now offers another option to companies looking for food safety management solutions in this part of the supply chain,” said Cenk Gurol, Aeon, Chairman of the GFSI Board.
“SQFI is pleased to announce the recognition and benchmarking of our Storage and Distribution of Food Products Program by GFSI. We are excited to offer these highly anticipated benchmarked modules to our stakeholders so they can be assured they are transporting and storing perishable and non-perishable food and feed products safely,” said LeAnn B Chuboff, Senior Technical Director, SQFI.
The Safe Quality Food (SQF) program is recognized by retailers and foodservice providers around the world as a rigorous, credible food safety management system. It is the only certification system recognized by the Global Food Safety Initiative (GFSI) that offers certificates for primary production, food manufacturing, distribution and agent/broker management. This enables suppliers to assure their customers that food has been produced, processed, prepared and handled according to the highest possible standards, at all levels of the supply chain.
The Global Food Safety Initiative (GFSI) is a business-driven initiative for the continuous improvement of food safety management systems to ensure confidence in the delivery of safe food to consumers worldwide. GFSI was launched in 2000 following a number of food safety crises when consumer confidence was at an all-time low. Its collaborative approach to food safety brings together international food safety experts from the entire food supply chain at technical working group and stakeholder meetings, conferences and regional events to share knowledge and promote a harmonized approach to managing food safety across the industry.
The Global Food Safety Initiative (GFSI) was founded to deliver equivalence and convergence between effective food safety management systems through its benchmarking process and continues to flourish in doing so. Benchmarking is a “procedure by which a food safety‐related scheme is compared to the GFSI Guidance Document”. The benchmarking process determines equivalency against an internationally recognized set of food safety requirements, based on industry best practice and sound science. These requirements are developed through a consensus building process by key stakeholders in the food supply chain and can be found in the GFSI Guidance Document Sixth Edition, freely available for download on www.mygfsi.com.
Another four people who had the outbreak strains have died, and one woman who had the outbreak strain had a miscarriage. However, officials at the Centers for Disease Control and Prevention said Jan. 12 they are waiting for confirmation from state authorities that listeria was the cause of death in those cases.
Initially the outbreak was only associated with caramel and candy apples from companies that Bidart had supplied.
However, three of the 32 sick people in the U.S. reported eating whole or sliced “green” apples before becoming ill, according to the CDC. All but one of the sick people in the U.S. had to be hospitalized.
As of Jan. 10, 25 of the 28 sick people interviewed by health officials reported eating caramel or candy apples before becoming ill.
Bidart Bros. officials recalled their entire 2014 crop of granny smiths and galas shipped from its Shafter, facility, notifying customers in a letter on January 6. A special website, www.bidartapplerecall.com, has been set up to help people and companies related to the recall and outbreak.
So far, no details have been revealed about who received the apples from Bidart or what volumes were shipped. “Bidart Bros. is contacting all of their retailers with specific instructions as to how to return those apples to Bidart Bros.,” according to a news release from Bidart Bros. that was posted on the FDA’s website Jan. 9.
Public health warnings and recalls are in effect in Canada and several brands of caramel and candy apples are under recall, as is the entire 2014 crop of granny smiths and galas from Bidart Bros., according to the Canadian food Inspection Agency. Sliced apples marketed by Scotian Gold Co-operative Ltd. are also now included in the Canadian recall. The Scotian Gold sliced apple products were distributed to retailers in New Brunswick, Newfoundland and Labrador, Nova Scotia and Prince Edward Island, according to the recall notice.
The CDC report shows the first confirmed illness in the U.S. began on Oct. 17. As of the agency’s Jan. 10 report, the most recent confirmed case started Dec. 12. More cases could be confirmed because listeria can take up to 70 days to develop into a detectable infection. The testing and reporting process takes an average of two to four weeks, further delaying the reports to CDC.
In a recent webinar, Robert Garfield, Senior Vice President of the Safe Quality Food Institute talked about the SQF standard, changes made in 2014, what is expected in 2015, and how companies can use SQF to be better prepared to comply with rules proposed under the Food Safety Modernization Act. We present below some excerpts from the webinar, organized under the 2014 GFSI Leadership Series. The next webinar in the series will focus on FSSC 22000. Click here to register.
Where is SQF going in 2015 and beyond?
Garfield: The standard is going to be focused on enhanced compliance programs and improving the database reporting systems. For instance, if it concerns someone in the bakery or dairy industry, we would like to know how they are doing versus the industry as a whole. We are hoping that better database reporting can help with this, especially when it comes to non-compliances.
Another area we are working on is establishing Cooperative Agreements. In 2014, we finalized an agreement with the American Feed Industry Association and we are working with their food safety program. We are hoping to not just work cooperatively with the private sector, but also with various government agencies and other stakeholders.
Other areas we are growing in 2015 are expanding our language alternatives, subject matter training and developing industry specific guidance.
There are many changes proposed to food safety regulations and food safety schemes such as SQF. How will companies be affected by these changes and why is embracing these changes so important to industry?
Garfield: Embracing all these changes is critical for the food industry to do everything they possibly can to ensure that they are making and selling a safe product. At the end of the day, there is no one ‘magic bullet’ solution to food safety. Embracing these changes to food safety rules and standards will help the CEO and management team sleep better at night, knowing that they are doing what they can to protect their product, their brand name and their consumers. Also, companies need to understand that the regulatory climate will completely change in the next few years, so it’s critical for companies to start acting now to meet these new requirements that will start being in effect from October 2015.
How can companies start preparing today for tomorrow’s SQF?
Garfield: I tell companies and retailers I talk to that if they are interested in doing SQF because they want to be ‘GFSI certified,’ that’s the wrong reason to do this. To get started, management commitment and changing the culture of the entire company is critical. Starting from the CEO and going all the way to the man operating machinery on the floor, you should aim to get a commitment to food safety, where food safety management is the most important issue for the company. If you start working on that today, you can accomplish great things for the company in not just reducing recalls, but improving the overall functioning of that company.
How can SQF help prepare companies for FSMA?
Garfield: The first step is to look at the Preventive Controls and the Fresh Produce rules and see how these apply to your company. I suggest hiring an independent expert to take a look at your facility and see how your company fares against these rules and have a better understanding about where you will be when these rules are finalized by October 2015. While you will have one to three years to comply with these rules after that point, you need to get the management buy in and strong food safety management systems in place now. Start now, and don’t wait for the final rules to be announced.
Listen to this complimentary webinar today to learn more about how SQF differs from other food safety programs, unannounced audits, changes with allergen control standards, and how to become SQF certified. Click here to access the recording.
2014 GFSI Leadership Series continues with FSSC 22000: The Road Ahead. Click here to register for this informative webinar on Friday, September 26, 2014, featuring Jacqueline Southee, U.S. Liaison, FSSC 22000, who will talk about what’s new for FSSC 22000 this year, where FSSC 22000 is going in 2015 and beyond, how you will be affected by the changes, and how to start preparing today. Plus Jacqueline will take your questions live!
Food Safety Tech: We’re very excited to have you kick off the SafetyChain/Food Safety Tech GFSI Leadership Webcast Series with your August 22 webinar, “SQF – The Road Ahead” webinar. Can you start by telling us what is new with SQF today? What are some of the things you’ll be talking about in terms of current changes?
Bob Garfield: We’re very busy here. We have a new version of our code, 7.2, which was introduced in the beginning of July. GFSI benchmarks standards every 3 years. Historically, SQF hasn’t waited for every 3 years to revise our code. This is the second time since our last benchmark that we will be revising our code based on the best science and technology that our stakeholders are putting forward. We’re pretty excited about that. We’ve added in some things that we think are important for all suppliers and people using the SQF code to keep them at the leading edge of science, technology, and the needs of buyers. That’s the primary one, but there are a bunch of things that I will be talking about as well in the webcast, including new modules on produce, feed, and pet food.
FST: We’re sure that unannounced SQF audits will be a topic of many questions during the webcast. What are some of the key takeaways attendees will leave the webinar with on this topic?
Garfield: Change is always difficult for some organizations. I understand why, but going through the SQF process is not to just get a certificate on the wall. We know from our stakeholders that it’s a commitment to food safety management, all the time, from the top to the bottom of a facility’s management. A facility needs to be audit-ready all the time, and we believe that the unannounced audit protocol that we are establishing will allow facilities to accomplish that audit readiness goal. We are fully aware that regulators and other food safety stakeholders are more and more looking at unannounced audits as the direction that food auditing needs to take in order to ensure consumers that what we are doing is the best it can be. It’s the most that we can do to ensure the safety of the food supply.
FST: You will also be talking about the direction of SQF in 2015 and beyond? Is there a “theme” or specific set of business drivers that are driving future changes to SQF?
Garfield: Yes, there is. The business driver that is the primary focus of SQF is exactly what our executive committee from the Food Marketing Institute has told us – that the value proposition for SQF is to improve safety internationally as much as possible. Retailers are the closest that anyone can get to consumers. They believe that the purpose and the scope of SQF has to be continuous improvement to make food safety as close to foolproof as possible.
FST: What are some of the things we’ll learn in the webinar about why embracing change is critical to the ongoing success of SQF?
Garfield: Change is always critical and important. Embracing change is critical to the success of SQF because it is not a stagnant standard. It changes as science and technology evolve. Food safety and food safety management in particular are two areas that are constantly evolving as we learn more about how to protect the food supply chain, and we continuously update the code to make improvements that reflect this. Change is critical to the success of SQF. We are constantly evolving the code – it’s a process that must be ongoing.
FST: We know that you’ll be providing advice on how companies can start today to prepare for tomorrow’s SQF. Can you tell us some of the topics you’ll be addressing in this part of the webinar?
Garfield: To clarify, SQF doesn’t provide advice – we provide guidance with the SQF code. As we continue to evolve the code, we also evolve our guidance to support that process. I’ll be talking about things we do to help our users and stakeholders to evolve their own knowledge. For example, I’ll discuss our advanced practitioner course that we’ve just started to offer to help practitioners gain better understanding and know-how about how to manage food safety at their facilities.
FST: It has been said that SQF certification is a very good start to preparing for FSMA compliance. What are some of the key points you’ll be addressing when it comes to FSMA compliance?
Garfield: It is a good start. SQF is an international code and there are things in the code that are equal to or above what FSMA is requiring. There are also areas that are different. This is why we’ve hired Dr. David Acheson to do a comparison of our code against FSMA’s proposed preventive control and produce rules. Both of these comparisons are available on our website at www.sqfi.com. We’ll be able to make more comparisons/gap analysis when the final rules come out in 2015. As I discussed with FDA, we’ll look at the final rules and see how we match, exceed, or may need to do some work on our particular code if we think it’s appropriate.
The global food industry is already feeling the destabilizing and disruptive effects of climate change. Drought and wildfire are ravaging California while flooding is inundating the Midwest. With the effects of climate change projected to amplify, companies are becoming increasingly aware of vulnerabilities to their business. In addition, current modes of food production are seen as a major driver of environmental problems such as deforestation, desertification, eutrophication and fisheries collapse. All of this is set to the backdrop of a booming world population, rapid urbanization, diminishing natural resources, and critically stressed ecosystems.
Food companies are increasingly becoming aware of these challenges and are looking for innovative ways to adapt their business models to account for them. One approach is to incorporate sustainability into business strategy and planning.
Sustainability is a conceptual framework that has the potential to mitigate business vulnerabilities while simultaneously reducing the stress that food production has on social and natural resources. In general terms, sustainability is the endurance of systems and processes. More specifically, it integrates ecology, economics, politics, and culture. Connecting environmental stewardship with a solid business plan while advancing social justice is an innovative as well as profitable approach to streamlining business operations.
There are different methods to assess sustainability, with the most common being the Triple Bottom Line and Circles of Sustainability. These methods are multi-dimensional and allow for the inclusion of complex qualitative issues. Sustainability has also been deceptively referenced in a number of marketing campaigns aimed at altering how a company is publicly perceived, not how it operates. This is a practice known as greenwashing.
In the upcoming series of articles, topics such as co-management, food waste, water conservation, agriculture, and others will be observed through an interdisciplinary lens, tying food safety with sustainability. Given the connection to the entire food production process from farm to fork, food safety professionals are poised to lead in sustainability. Many of the systems already developed to detect, prevent, and trace contamination can be retooled and applied toward sustainability. Elements of food safety programs and auditing schemes such as HACCP, GFSI, and SQF could be adapted to cover environmental and social benchmarks.
Food companies must develop more sustainable solutions in an effort to protect food safety and natural resources. Businesses, driven by C-suite oversight and stakeholder initiative, need to co-manage food quality, safety, and sustainability in a collaborative approach. Decision making at every step in the supply chain should comprehensively approach food safety, quality, and sustainability where possible.
Andrea Moffat is the Vice President of the corporate program at Ceres, a non-profit organization that publishes findings on corporate sustainability and progress. She believes that, “Businesses need to look at sustainability and food safety as part of their core business framework in identifying risks and competitive advantages. We are beginning to see teams of executives involving sustainability issues in setting sales and revenue targets.”
By reaching across borders within a company and working toward these benchmarks, businesses can improve operations while maintaining customer loyalty and brand confidence. At the end of the day, food safety professionals are stewards of public health. Sustainability offers food safety professionals the opportunity to expand their influence on public health and safety.
Uncertainties around climate change are now threats for businesses in every sector. The food industry is witnessing the effects of climate change on vital natural resources, and thus business planning now. Food companies are beginning to look at sustainability as an opportunity to improve business operations at the moment and in the future. The upcoming articles will focus on the interconnectedness of food safety and quality with sustainability.
Stay tuned for more articles on this topic.
Beyond achieving compliance with the SQF program requirements, internal audits help drive continuous improvement and can facilitate a food safety culture throughout all levels of an organization. Gary Smith, Senior Technical Director at SAI Global, discusses 5 key factors to successfully conducting an internal audit.
What is the SQF Standard: Item 2.5.7 Internal Audit?
This requirement includes 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. Companies must have an internal audit schedule with scope and frequency and records of internal audits, corrections, and corrective actions. The internal audit must be conducted by staff trained in internal audit procedures and the audit results must be communicated to relevant management.
In the SQF program, a major nonconformance indicates a systematic failure where an element is failing or not existing. Some common major nonconformances include not having a schedule of internal audits, having verification and validation activities defined but not having an internal audit program, not having a facilitator for an internal audit program assigned, and having the internal audit only cover GMPs, but not the SQF system. Some of the minor nonconformances include not having an internal auditor training for the lead auditor, not defining how results are to be communicated to leadership, not taking corrective actions for internal audits, or not having records of corrective actions.
5 Keys to Success
- Reach out to leadership. Work with your leadership to define objectives of the internal audit program with management to facilitate management commitment. Build the internal audit program with management objectives. Remember, it’s not the QA’s program certification, it’s the entire company’s.
- Formalize the audit process. Set an audit schedule and keep to it. Assign an audit team with responsibilities. Use an audit checklist. Develop an audit plan. Conduct interviews during the audit. Conduct opening and closing meetings with staff.
- Communicate well. Regularly provide updates to leadership at routine meetings. Provide the audit plan and checklist to auditees one week prior to the audit. Take photos of good practices and nonconformances. Provide the audit results in a timely manner.
- Manage internal audits as its own program. Have standard operating procedures describing the responsibilities and procedures. Have the facilitator be trained as a lead auditor and appropriate training for all team members. Include as many people as possible in the audit team from all departments within the company.
- Use corrective action management program for all internal audit findings. Keep an internal log of all your internal nonconformances. Use root cause analysis to understand why nonconformances occur and include internal audit findings, regulatory audit findings, nonconforming products, and customer complaints in the corrective action management plan.
A strong internal audit program will help drive continuous improvement. It will help promote ownership of the entire SQF system and promote a food safety culture within the organization. Lastly, a strong internal audit program can improve the external audit score.
For more information, see this archived webinar: SQF 5 Tips for Conducting a Successful Internal Audit
The Global Food Safety Initiative is a set of standards created to assure confidence that food products meet international standards. GFSI sets the minimum requirements for Food Safety Management Systems, GMPs, GAPs, GDPs, and HACCP. All standards to get GFSI approval must meet the minimum requirements outlined in the GFSI guidance document. There are currently nine approved GFSI schemes, however only four apply to packaging.
Safe Quality Food or SQF, as it is more commonly referred to, originated as an Australian standard in 1994. It was purchased by The Food Marketing Institute in 2004 and is now operated by the Safe Quality Food Institute in the US. It was one of the first four GFSI approved schemes. It’s currently in edition 7.1 and is available from sqfi.com. Edition 7.2 will become effective July 3, 2014.
SQF offers three levels of certification: Level 1 is basically the fundamentals of food safety; Level 2 requires at a minimum HACCP analysis and possibly a HACCP plan; and Level 3 requires a quality plan. GFSI approval only requires Level 2 SQF certification.
SQF initial certification audits
The initial certification process requires two separate audits. The readiness audit reviews documents, programs, policies, and procedures to make sure that they match the SQF requirements. The auditor may look back through up to two years of records. SQF code also requires practicing continuous improvement and that the facility meets the regulatory requirements of the country in which the facilities operates as well as those of each country where product is sold.
The second audit is a facility audit. This audit assesses how the facility is in compliance with the documented programs, policies, and procedures. The auditor will look at your equipment, building, processes, and records and will perform a graded evaluation. All deficiencies in this audit will need to be corrected before the Certifying Body can issue a SQF Certificate. For packaging plants, this audit usually takes two days but can take longer. Recertification only requires one annual audit that is a combination of the readiness audit and facility audit.
SQF certification requires that facilities employ a full-time SQF practitioner that is in a position to manage the program. This person must have completed an accredited HACCP course and be competent to implement and manage HACCP plans. They must also have SQF code knowledge and be competent to implement and manage SQF programs. While not required for certification, taking an SQF implementation course is highly recommended.
SQF for food packaging manufacturers
SQF has products and services divided into 35 food safety categories of which Category 27 is “Manufacture of Food Sector Packaging Materials.” The two modules of SQF code that require compliance from packing manufacturers are Module 2, SQF System Elements and Module 13, Pre-requisite Programs for the Manufacturing of Food Sector Packaging. The other modules do not relate to packaging and will not be part of the audit of a packaging facility.
The following are SQF mandatory sub-elements that are required to be documented and implemented by everybody. They cannot be excluded, exempted, or marked as non-applicable by the auditor. There are only mandatory elements in Module 2; there are no mandatory elements in Module 13.
A minor nonconformity must be corrected within 30 days 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.
A major nonconformity must be corrected and appropriate corrective action verified and closed out within 14 days of the facility audit.
A critical nonconformity raised at a certification audit results in an automatic failure of the audit and the supplier must reapply for certification.
Nonconformities can occur during the document audit or during the facility audit, but only the facility audit is scored. Out of a possible 100 points, a critical nonconformity will deduct 50 points, a major nonconformity will deduct 10 points, and a minor nonconformity will deduct 1 point each. All nonconformities 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. A score of 96 to 100 is ‘excellent’ (E), 86 to 95 is ‘good’ (G), 70 to 85 is ‘complies’ (C), and 0 to 69 is ‘fail’ (F). A certificate will be issued for grades of excellent, good, and complies. Excellent and good grades require a 12-month recertification audit and a grade of complies requires a six-month recertification audit.
The above article has been adapted from an archived webinar, hosted by SAI Global and presented by Dr. Bob Strong. For more details, please click here.