Don't Forget About Those Corrective Actions!


After passing a third party food safety audit there is a tendency to celebrate. And you should! What a terrific achievement, especially if you've gained certification to a GFSI benchmarked scheme (SQF, BRC, etc.). But your work isn't done just yet. Now it's time for those corrective actions.

Depending on the severity of the non-conformance corrective actions must be closed out within a specific amount of time. For SQF, Major Non-Conformances must be closed out within 14 days and Minor Non-Conformances must be closed out within 30 days. BRC allows 28 days to close out non-conformances, but if the audit score was C/C+ close out is done by means of another site visit within 28 days.

Keep in mind, the audit process is not complete and no certificate can be issued until all corrective actions are closed out. Also, notice that corrective actions must be closed out within the required time frame, not simply submitted. Often times facilities will submit their corrective actions for review on the last day. This does not leave enough time for the auditor to review and close out the non-conformance, especially if the corrective action is inadequate and needs to be redone or expanded upon. 

Not having the corrective actions approved and non-conformances closed out within the required time frame can have terrible consequences. The SQF and BRC standards are very clear that certification cannot be granted in the event that non-conformances are not closed out by the deadline. 

If this were to happen on an initial certification there is a risk of needing another full audit. While some certification bodies may be slightly more lenient than others when handing down this judgement, it is best to never put your facility in this position. Imagine putting all that time, effort, and money into gaining certification only to need to repeat the entire process! 

If deadlines were exceeded on a re-certification audit, the facility's certificate is suspended immediately until non-conformances are closed out. Another full audit may needed (as is mentioned in the BRC Standard Issue 6) or another site visit may be required by the auditor to verify the implementation of the corrective actions. 

In response to this procrastination on the part of certified facilities, NSF is now requiring all corrective actions for BRC audits to be submitted within 21 days. This will give their auditors enough time to review, provide feedback, and close out non-conformances within the 28 day requirement. Don't be surprised if other Certification Bodies follow suit or if this practice expands to include other audit standards. 

Don't forget those corrective actions! Create a detailed corrective action plan with root cause analysis, submit them with enough time to be closed out, and your new certificate should be on its way in no time. Then it's time to celebrate. 

Dealing With SQF Unannounced Audits

October 22, 2014

The addition of the unannounced audit protocol in Version 7.2 of the SQF code presents some big challenges for currently certified suppliers. You will now need to be audit ready at all times, and will not know the exact date of your re-certification audit. 

How will this work? The certification body and supplier will decide on which certification cycle will be unannounced. SQF has mandated that one out of every three re-certification audits be unannounced. This only includes re-certification audits. Surveillance audits will always be announced. 

Once the unannounced audit year has been agreed upon, the supplier will be given a 60 day window in which the audit will take place. The supplier will not know the exact dates of the audit, but they will know the approximate time frame. This 60 day window will always fall 30 days on either side of the anniversary date of the certificate. For example, if a supplier's anniversary date is January 1, the unannounced audit will take place between December 2 and January 30. 

While suppliers should be audit ready at all times, sometimes this is not the case. Unfortunately, suppliers sometimes scramble to get ready for their audit at the last minute. With the unannounced audit protocol, SQF is taking steps to force these suppliers to change this behavior. A SQF System should be practiced day in and day out, not just in the weeks leading up to an audit. 

Hopefully, suppliers that do not live and breathe their SQF System will take this to heart and change their practices. If not, they could be in for a nasty surprise come their unannounced audit year. This could lead their customers to question the legitimacy of their announced audit scores. 

So how can you prepare for these unannounced audits? Increasing the depth and frequency of your internal audits is a good place to start. Take a very critical look at your system on a regular basis to ensure that everything is running smoothly. Create a cross functional audit team to be sure you get an unbiased, independent set of eyes. Increasing the frequency of verification can also help. The more often a record or practice is verified, the less likely it is to go on being done incorrectly. 

Keep instilling a culture of food safety and quality in your employees. Have frequent, short meetings and review the importance of your food safety and quality system. Share areas where improvement is needed, and praise employees who are doing a great job. It is also very important to educate employees on why all of these food safety and quality practices are needed. There is a much greater chance employees will follow these procedures if they both know what to do and why it must be done. 

Don't be intimidated by your unannounced audit. Live and breathe your SQF System and it should be a piece of cake. Good luck!

New SQF Version 7.2 Traceability Requirements

Note: SQF has since backtracked on this requirement. Live traceability tests are no longer a requirement during the audit.

Version 7.2 of the SQF code brings some big changes, not the least of which is a change to the traceability requirements. Live traceability exercises are now a requirement during the audit. 

So how will this work? The auditor will choose a raw material from the supplier's warehouse. The supplier will then have to trace this lot of raw material one up and one back. Starting from receipt of raw material, the supplier will need to trace it through production to the finished products in which it were used, and then trace those finished product to the customer. The amount of raw material or finished product that is still on hand must also be taken into account. 

To exhibit full traceability of the chosen material the amount received must match the amount used plus the amount on hand. Supplier's are typically given until the end of the audit to present these results, but this may vary based on the Certification Body.

This requirement will put a greater emphasis on the need to have an airtight traceability program. This traceability challenge must be done on the spot using whatever product was chosen by the auditor. This means that any ingredient or packaging material the supplier brings in is subject to be traced.


SQF Code Version 7.2

Version 7.2 of the SQF Code, which was recently released by SQFI, brings big changes. This version of the standard goes into effect on July 3, 2014. This means that any initial certification or re-certification audit that takes place on or after this date is subject to version 7.2. 

So what does Version 7.2 bring? The big change is the addition of the unannounced audit protocol. This new protocol requires that one out of every three re-certification audits be unannounced. The audit will fall within 30 days on either side of the re-certification audit date, but the exact date will not given by the certification body. This puts greater emphasis on the need to be audit ready at all times. 

For the full Unannounced Audit Protocol please click here.

Other changes in Version 7.2 can be found throughout the various modules. Changes include:

  • Surveillance audits are now scored. 
  • The requirement that SQF and Certification Body be listed as an essential contact in the Recall Plan. SQF and the Certification Body must be informed in the instance of a food safety incident of a public nature or a recall.
  • Clarification of requirements for co-manufacturers. 
  • Minor scrapes and abrasions must be covered with a colored bandage containing a metal detectable strip. (Don't forget to verify these bandages with your metal detector!)

Download the SQF Code Version 7.2 here.

For more information about the changes in Version 7.2 please click here.