Expecting the Unexpected

by Jeff Chilton
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Audit-ready, every day should be the goal of every organization.

Unannounced audits are a major new addition to SQF (Safe Quality Food) Code Edition 7.2 which became effective July 3, 2014. Robert Garfield, SQF Institute senior vice president, states, “unannounced audits will elevate the SQF Program to the next level by providing a standard that will prepare SQF-Certified suppliers to be audit-ready at any time. We believe that each facility must be prepared every day for an assessment.” SQF chose to be the leader by becoming the first internationally recognized third-party assessment program to require unannounced audits. Meat and poultry companies that choose to be certified under the SQF scheme fall under Food Sector Category 8 for Processing of Manufactured Meat or Poultry and/or Food Sector Category 7 for Slaughterhouse, Boning or Butchery Operations.

“Audit-ready, every day” should be the goal of every company. The robust programs, record-keeping requirements and compliant plant conditions should be part of normal operating conditions. Suppliers should operate in compliance with SQF requirements every day with a high confidence level in their food-safety and quality-management systems. However, the fact is most companies can put on the dog-and-pony show needed to score well during a planned third-party audit. The challenge is to sustain those conditions and compliance levels all year.

As a Certified SQF auditor and SQF consultant, I believe the unannounced audit protocol will be another good motivator to keep all of us in the food industry moving in the right direction. Recent negative incidents in plants located in the US and China reinforce that surprise inspections add additional value because conditions are not always followed as expected.

Components of success

How can you be audit ready, every day? There are five key components for success: SQF System Ready, Documents Ready, Training Ready, Plant Ready and People Ready. All of these activities must be complete within the 30-day mark of your SQF certificate expiration date.

SQF System Ready means continually sustaining your SQF system throughout the year by keeping procedures and SQF system requirements current. The SQF system requires annual review of all procedures, management review meeting, business continuity plan test, HACCP reassessments, food quality plan reassessments, SQF system internal audit and prerequisite program verification/validations. It is imperative that all these activities are performed and documented at least 30 days prior to your SQF certificate expiration date before the unannounced audit may occur.

Documents Ready means all required records are current, complete and available. Records include those previously listed and ongoing program records for customer complaints, HACCP records, food-quality plan records, vendor audit records, non-conforming products, product release, product inspections, plant inspection internal audits, mock recalls, allergen validations, training records, maintenance pm and work orders, calibrations, sanitation inspections and validations, pest-control records, receiving/shipping records and glass and brittle plastic inspections records.

Training Ready means all annual required refresher training has been completed. Refresher training must be completed on the topics of GMP’s, SQF, HACCP, allergens and food defense at a minimum. The training register must be kept current to document all training required and provided to employees. In addition, specialized training must be documented for the SQF practitioner HACCP training, crisis-management team training and internal auditors.

Plant Ready means the facility meets structural requirements, employees comply with GMP requirements and products are processed and handled appropriately. This is generally the most challenging area for plants to sustain. Maintenance of the structural facility requires strong preventive-maintenance and work-order processes. Monthly plant inspections as part of the internal audit process should routinely identify and correct issues with floors, walls, doors and ceilings. GMP compliance, product handling and product processing procedures should be an ingrained part of the company culture and monitored daily through QA, sanitation SOPs and HACCP inspections.

People Ready means everyone understands their roles and responsibilities within the SQF system. All employees should be able to recite what SQF means and how it impacts their jobs. Employees with direct responsibilities for monitoring and verifying SQF related programs must be able to explain their duties and record keeping responsibilities during interviews. The SQF unannounced audit process will make having appropriately trained back up personnel more important for all key positions including the SQF practitioner. It is critical that plants have more than one SQF practitioner designated to be ready for audits and assure SQF practitioner responsibilities are fulfilled if the primary person is out for any reason.

Unannounced audits

Part A, Section 4.5 of the SQF Code Edition 7.2 defines the guidelines for unannounced audits. The code requires that the supplier undertake one unannounced audit within each three-year certification cycle. Suppliers and Certification Bodies are expected to work together to define the year the unannounced audit will take place within the three-year cycle. Suppliers can narrow down the expected dates when the unannounced audit will occur first by knowing the audit must take place within the 60-day re-certification window which is the anniversary date of the initial certification audit +/- 30 days.

Suppliers also have the option of negotiating black-out dates with their Certification Body to define one or two weeks when the unannounced audit should not occur within that 60- day window in the event that the facility may not be operating, seasonal production issues or if key staff are not available. SQF audits are typically two to three days at least so you also know if the auditor has not arrived by Wednesday in a particular week, the audit is not likely to happen that week. So you could go as far to narrow the potential days down from 60 days to consider there are 40 production days within those two months, remove 10 days with potential black-out dates, remove 16 days for Thursdays and Fridays over the eight-week period, then it really leaves 24 potential days that that unannounced audit will occur.

SQF has published information regarding the unannounced audit process that includes a list of expectations for suppliers and expectations for auditors. SQF has clearly instructed auditors that plant inspections should start within 60 minutes of arrival at the facility to get a realistic picture of plant conditions and record keeping practices during unannounced audits. SQF also makes it clear in the code that if suppliers choose to deny entry to the auditor at the unannounced audit, your SQF certificate will be immediately suspended.

Some proactive suppliers are having consulting firms perform unannounced second-party audits to assess their true readiness for an unannounced audit. In light of the recent events involving a Chinese meat-processing company headquartered in the US and huge fines of a California meat and poultry distributor, it is certainly a good idea to have unannounced second- and/or third-party audits to assess the true operating conditions within a facility.

LeAnn Chuboff, senior technical director of SQFI, states, “Being audit-ready is more than just the sum of the parts, more than having your programs in place, your equipment cleaned, your employees coached, etc. Being audit-ready means having an organization that is firing on all cylinders supported by a culture of proactive excellence.”

In conclusion, SQF Certified Suppliers should not dread the unannounced audit process. Suppliers should use this process as a motivator to assure they are indeed audit-ready, every day. This process is good for all stakeholders involved to assure the integrity of the system and promote continuous compliance and approval. Our food-safety and quality-management systems must be able to withstand inspections of any type at any time to truly be successful.

Jeff Chilton is President of Chilton Consulting Group and is a Certified SQF Auditor, SQF Consultant and SQF Trainer.

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