SQF Townhall Questions and Answers
SQF Unites, November 16, 2022
7 Important Topics & 27 Questions & Answers
You have questions, we have answers! Below we have grouped Questions & Answers by topic from an interactive Town Hall Q&A session.
The SQFI Technical Team is always approachable if you have questions or need assistance, contact us at sqfi.com and we can assist you.
The Food Allergy Safety, Treatment, Education, and Research (FASTER) Act – Sesame as a New Allergen
- On January 1, 2023, sesame will officially become the ninth major food allergen. What will be the FDA’s stance on finished products that are in the manufacturers’ inventory, food distributors’ inventory, and on retail shelves on January 1st that do not have sesame listed in the contains statement?
- Is the FDA granting waivers on finished products manufactured before January 1, 2023?
- Is the FDA granting waivers on packaging labels that do not meet the labeling requirements or must the labels be destroyed?
The US Senate, (S. 578), the Food Allergy Safety, Treatment, Education and Research (FASTER) Act, added sesame as the 9th food subject to mandatory allergen labeling. January 1, 2023, is the date by which food companies are required to declare the presence of sesame on food packaging labels. The FDA has not indicated that this will be extended, or the date changed.
Data and Statistics
Is there any data available for average scores in each food sector category?
We currently don’t post average scores for each food sector category. The data is available, and we can provide it upon request.
What Non-Conformances (NC) are considered major?
The definition of a major non-conformance is in the SQF Code, Appendix 2. A major non-conformance is a failure of a system element, a systemic breakdown in the food safety management system, a serious deviation from the requirements, and/or absence of evidence demonstrating compliance to an applicable system element or Good Operating Practices. It is evidence of a food safety risk to products included in the scope of certification.
In other words, a major non-conformance is when there is a breakdown of controls that is more than likely going to lead to a system element breakdown. For example, a site that does not have a training program would receive a major non-conformance to the training requirement vs multiple minor non-conformances to the various training elements. Another example is if a site has had multiple instances of improper record-keeping practices, the auditor may issue one major non-conformance versus multiple minor non-conformances.
Could you please share the top 10 minor, major, and critical non-conformances in 2022?
Food Safety Culture was identified as a top minor/major non-conformance at the implementation of Edition 9. In 2021, this was 22 majors and in 2022, 10 majors. With minors being 385 in 2021 and 231 in 2022.
Root Cause: Auditors misunderstood the new code requirement and were requiring a food safety culture plan, procedure, or program.
Improvement: The auditor training course and quarterly professional update meetings were used to include an emphasis on this code requirement meaning.
For more information on the top non-conformances please see the Townhall presentation handout.
Have you considered creating a database that would allow us to search audit findings by FSC and element – to chart for trends and drill into auditor finding comments so we can proactively address problems? The top non-conformances or score trends by FSC don’t always give enough guidance to know what the problems are.
We are always looking for good ideas to share data to improve food safety. We will consider this as an opportunity for future improvements or as a webinar idea for 2023.
Are there any stats about unannounced audits to share with those skeptical of the process?
There is not a significant difference between scores of sites receiving an announced recertification audit versus those receiving an unannounced audit.
Are the top non-conformances broken down by food sector category?
The top responses are for all SQF audits. The majority of the SQF audits are using the Food Safety Code: Food Manufacturing which is why most of the listed non-conformances are for either module 2 or module 11.
What is the average score for sector 18?
The average score for FSC 18 Edition 9 audits is 93.63. However, there are many factors that affect the average score of sites, and using this as a comparison to one particular site or setting food safety targets should be done with caution.
Why is a degree required to be an auditor if they have over 20 years of experience in the industry?
GFSI requires a degree to demonstrate technical competence which requires SQF to include that as part of the auditor application requirements. SQF offers exemptions to the university degree requirement pending sufficient evidence, such as alternative training courses, industry experience, or audit experience, to deem equivalency.
Is there a particular area that SQF auditors will focus on in the next year?
SQF is encouraging auditors to build continuous improvement through professional development in areas of specific competencies. Whether this is improving interview skills or writing reports, SQF auditors should identify their professional development needs based on their competencies.
With auditor shortage, what tools do you give auditors for burnout prevention?
With the growth of the SQF Program, auditors are needed in all food sector categories and SQF is calling for more industry experts to apply to become auditors. SQF has shifted to a virtual training format to create more accessibility to training and is proposing a change to the audit requirement to align with the GFSI auditor competence requirements. Additionally, SQF has aligned the food sector categories to the GFSI industry scopes allowing auditors to qualify for multiple food sector categories. Certification bodies are doing their part as well, such as allowing for remote auditing options and reducing the burden of travel on the auditor.
You mentioned auditor surveys. Are they sent to the practitioner, or do we have to go to the site to fill them out? I’d love to give feedback.
We ask our CBs to send out the survey link to the SQF Practitioner after every audit. The site survey is one part of the feedback process, however, there are other ways to share your feedback. Please visit sqfi.com if you have any input to the SQF Program.
As a senior auditor, I look at attracting more food-minded individuals to take up our profession. How does SQFI hope to support the need to qualify individuals that are not eligible for a scholarship?
The intent of the scholarship program is to create an awareness of auditing as a career. This has been a successful program since 2010 not only for the award winners but for our industry with many award winners pursuing auditing as a career. With the support of the FMI Foundation, SQF will continue this tradition for the foreseeable future. To encourage industry experts outside of academia, SQF plans to offer more programs and outreach to encourage industry experts to consider auditing as a career.
Are you exempt from the traceability rule if you purchase a product such as cheese and do not further process it and the supplier has a kill step?
If a site introduces a kill step of a food listed on the food traceability list, then there is no need to continue with the traceability rule. For more information on the traceability rule, please visit the SQFI website: https://www.sqfi.com/resource-center/fda-and-fsma-resources/get-started-on-food-traceability-compliance/
SQF Edition 9 Code Questions
With small food manufacturers booming thanks to social media, does SQFI have any plans to help ensure food safety from online sellers or small businesses who may not be able to afford the normal auditing progress?
SQFI has created a solution for small and medium-sized suppliers who don’t have a robust food safety management program in place or simply want to take their existing program to the next level. The SQF Fundamentals Program was developed by SQFI for business owners just like yourself.
The goal of the SQF Fundamentals Program is to help protect your brand from the risk of a recall and satisfy your buyer’s requirements. The SQF Fundamentals Program helps to facilitate retailer acceptance of entrepreneurs like you, providing food safety security and acceptance along the supply chain.
The SQF Fundamentals Codes were developed using the GFSI Global Markets Program toolkit, which meets retailers’ and buyers’ requirements for small and medium food producers. Built as a stepwise approach, The SQF Fundamentals Program is designed to help you integrate robust food safety standards into your existing practices while creating a pathway to achieving globally accepted GFSI certification.
Most others I know no longer use the quality module; how do we get value from that module?
The quality of your product is your brand. SQFI has created a Quality Program for those sites that desire to go above and beyond food safety. The Quality Program is designed to monitor and control food quality related threats, saving time and money. This program is most suited for sites that have already implemented a successful, robust SQF Food Safety Plan.
The SQF Quality Code uses the Codex HACCP method to identify and control quality threats, and addresses process controls to monitor product quality, identify deviations from control parameters, and define corrections necessary to keep processes under control. In short, it helps protect and retain your brand.
How should a company that uses your name to manufacture another product but is not a co-manufacturer be treated from SQF’s perspective? Ex. A popcorn company uses a seasoning with your product and brand name.
Licensing your brand is not food safety related and is therefore not affected by the requirements of the SQF Code. However, the license agreement may want to address how the licensee will address food safety issues and how they will inform your company of any food safety issues associated with your company’s branded product.
Food defense with the IA rule is not connected to the site security ideas we focused on in the sessions. With SQF being global, not everyone is under IA, will site security remain the focus?
The food defense requirements within the SQF code are not regulatory specific. A threat assessment must be conducted to identify all potential threats with the goal of preventing food adulteration caused by a deliberate act.
Is there any data as to the risks of suspicious package delivery to a facility? A bomb is horrible but what impact on food safety is involved?
We do not have any data regarding suspicious package delivery.
We may start selling some of our byproducts to a supplier to pet food manufacturers. Are there any requirements we must meet or documentation we need to maintain?
The byproduct would need to be identified on your flow chart as an output and included in your food safety plan. Any identified hazards would need to be addressed.
How can we share best practices or ask questions with others within our industry? Does SQFI currently offer or plan to create a forum where we can promote knowledge exchange? We loved the knowledge swaps!
The knowledge swaps are a popular segment of the SQF conference each year. We will keep this in mind as we plan events for 2023.
Is it ok to assume or think someone is ill and what if they don’t tell you?
I have seen webinars with LeAnn discussing medical screenings where it is stated that asking employees if they are sick isn’t required and that a passive program is acceptable, but auditors will not accept that as compliant. What is truly acceptable?
The requirement to not permit people sick with foodborne illness into any areas where food is exposed was a requirement prior to the medical screening addendum. The addendum simply requires that this process/procedure be documented. The auditor should be asking for the documented process/procedure.
SQF Code Updates/ Edition 10
Questions 25, 26
- Will there be an SQF Code Edition 9.1 or will we be waiting for SQF Code Edition 10 to eventually come out?
- How can my company get involved with the SQF team in developing the standards and new programs?
There are no current plans for a new version or edition update. Planning for edition 10 will take place in 2023 with the development work being conducted in 2024. Pending no major updates with GFSI or other external factors, edition 10 will be released in 2025.
SQF welcomes the expertise of our stakeholders for any new program standards and version and edition updates. We will be calling for technical working group members to participate in the edition 10 development and update process mid-2023.
2023 SQF365 and 2024 SQF Unites Plans
- Will we have the event next year in person?
SQFI recognizes the need for food safety professionals to be together for idea sharing and collaboration – and our investment in community activities plays an important role for us.
For 2023, we will be hosting the SQF365 Program, which focuses on bringing together the community for regional live events and online digital seminars. We will be announcing the 2023 calendar of these activities by mid-February. The regional events will include events in Canada, LATAM, Japan, and Oceania Focus Days.
The SQF Community is made up of practitioners, professionals, auditors, Certifying Bodies, consultants, service providers. All these food safety professional areas make up our wider SQFI community. And it’s a community that has really been growing. Over the past year we’ve grown to more than 12,000 sites across the globe. That’s even more people to share with, more connections to make, more conversations to have. Facilitating connections and sparking energy and sense of community is important to SQFI.
That’s why in 2023, we’ll be meeting you where you are, creating more opportunities to connect through a series of regional events and virtual discussions under a new program, SQF365.
In the first part of 2024, we will host SQF Unites again in person in the U.S. We’ll be using the feedback we received from the 2023 Orlando post event survey to adjust the event experience to meet community needs.