Did you know that in 2018 there were about 6000 SQF audits globally? When I read that, I was struck by how many sites are audited to the standard. You may be aware that in 2018 the new edition 8 of SQF went into effect, which affected all of those sites worldwide. Although the standard remained largely the same in spirit, there were some significant structural changes and as many of you discovered there were some very notable changes in the requirements too.
A Little Bit About SQF
According to the owners of the scheme, “The Safe Quality Food (SQF) Program is a rigorous and credible food safety and quality program that is recognized by retailers, brand owners, and food service providers worldwide. Recognized by the Global Food Safety Initiative (GFSI), the SQF family of food safety and quality codes are designed to meet industry, customer, and regulatory requirements for all sectors of the food supply chain – from the farm all the way to the retail stores”.
Every year SQFI (the organization that manages the SQF food safety standards) issues summary data about the year’s audits, which includes information regarding the certification bodies, auditees, industry recalls, and other relevant information. Our team reviews the data they share, both as part of our auditor calibration process, and to gauge our performance to see where we might improve. I’m always drawn to their list of top non-conformities because it’s precious information to share with our customers. So, let’s take a look at this past year’s list of top non-conformities and examine what we, as an industry, might glean to improve our performance in the coming year.
Top 10 Major Non-Conformities
- 18.104.22.168 Food Fraud Program
- 22.214.171.124 Environmental monitoring
- 126.96.36.199 Cleaning and Sanitation
- 188.8.131.52 Food Safety Plan
- 184.108.40.206 Validation and Effectiveness
- 220.127.116.11 Internal Audits and Inspections
- 18.104.22.168 Food Safety Plan Monitoring
- 22.214.171.124 Identified Pest Activity Risk
- 126.96.36.199 Maintenance Program
- 188.8.131.52 Metal Detector Management
Several of these findings are in new sections or sections which have new requirements. For example, food fraud (which, by the way, is in alignment with new requirements under FSMA), new environmental monitoring requirements, and pest activity. Anecdotally, I’ve seen this in my audits as well – many companies have been taken by surprise by a few of the new requirements. As compared to 2017, companies do appear to have a better handle on FSMA requirements as this hasn’t come up as often this year. Yet we do still see some of the same struggles with existing programs such as sanitation, validation, the food safety plan, and internal audits.
Major NCs: Announced Versus Unannounced
In 2018, there were several unique top-10 Major NCs found in unannounced audits which were NOT in the “Top 10” for announced audits:
- 184.108.40.206 Equipment, utensils, and clothing
- 220.127.116.11 Inspections for pest activity
- 18.104.22.168 Foreign Material Control Program
- 22.214.171.124 Food fraud raw material review
- 126.96.36.199 Records of reworking are maintained
The one unique top-10 minor NC in unannounced audits was 188.8.131.52 Allergen management.
What can we gather from this? It represents observational findings, rather than the “system” findings we see in the announced audits. It’s what can go wrong on a day-to-day basis that might be observed in an unannounced audit, and may be less likely to come up when we’re more prepared for the audit. This list of non-conformities indicates to me that the unannounced audits are working as a check on how things look in our usual day-to-day operations.
I should mention that 20% of audits in 2018 were unannounced.
Top 10 Minor Non-Conformities
- 184.108.40.206 Food defense plan
- 220.127.116.11 Equipment, utensils, and clothing
- 18.104.22.168 Staff engaged in food handling
- 22.214.171.124 Food fraud program
- 126.96.36.199 Cleaning and sanitation
- 188.8.131.52 Walls, floors and ceilings
- 184.108.40.206 Food safety plan – flow diagram
- 220.127.116.11 Records
- 18.104.22.168 Floors, drains and waste traps
- 22.214.171.124 Management review
As with Major non-conformities, we see the appearance of several new requirements in the top non-conformities. We aren’t testing our food defense plans as we should, we haven’t fully implemented the monthly management review meetings, and we aren’t meeting the mark in the new food fraud program requirements. And again, we still find ourselves faced with some of the old familiar challenges – recordkeeping, sanitation, HACCP flow diagrams, and the condition of items and our facility.
OK, So What’s Next?
Based on the above there are a few recommendations I can make to keep your programs in shape.
- Get training if needed – You need to make sure you understand any new requirements. If you are uncertain about where or when to get trained, check on upcoming SQF training with us on our events page.
- Train your crews – They can’t meet the requirements if they don’t understand them. Many companies find themselves short-staffed or facing employee turnover. Training is where you find one of the most significant returns on your time.
- Internal audits – They’re your best tool for verifying how your programs are doing and keeping your employees aware of what’s expected. Make sure members of different departments are involved, and your program does a thorough evaluation of your processes. Never had an internal auditor program, check out our new web-based internal auditor course to get started.
- Test your food defense system – This is a new requirement.
- Revisit food fraud – Make sure your food fraud program is in place and meets the new requirements. If you’re not sure where you stand, contact us for help.
- Environmental monitoring – This is a major focus now, both with SQF and for FDA. Make sure your program has what it needs. Again, for more information check out our web-based course on this subject.
- Attend Safe Food California – Jeannette Litschewski, Specialist for SQFI Technical Affairs, will be speaking on the Most Common SQF Audit Non-Conformities. If you’re interested in attending, please visit www.safefoodcalifornia.com to register.