I am having trouble interpreting parts 2.1.2.10 and 2.1.2.11 of the SQF code, both parts are new to Edition 8
We recently went through our unannounced re-certification audit and we received a Non-Conformance because "The documented 'Management Responsibility' does not exist outlining the control measures in continued operation in the event of organizational or personnel changes within the company and the 'Black-Out' dates were not documented."
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The SQF code:
2.1.2.10 Senior site management shall ensure the integrity and continued operation of the food safety system in the event of organizational or personnel changes within the company or associated facilities.
2.1.2.11 Senior site management shall designate defined blackout periods that prevent unannounced re-certification audits from occurring out of season or when the site is not operating for legitimate business reasons. The list of blackout dates and their justification shall be submitted to the certification body a minimum of one (1) month before the sixty (60) day re-certification window for the agreed upon unannounced audit.
The SQF 2.1.2 Implementation Guidance:
"What does it mean" section of the guidance
Blackout periods are defined as blocked out seasons or time periods during the year where a site is not in full
operation and therefore, unable to have a fully comprehensive unannounced audit conducted.
"What do I have to do" section of the guidance
For defining these blackout periods where an unannounced audit is not viable at that particular time, a site must
submit dates and justification for their desired black out period at least one (1) month before the sixty (60) day recertification
window of an agreed upon unannounced audit.
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I am not certain if 2.1.2.11 is requiring specific dates that we will blackout or if all we need to do is make some sort of statement like 'Senior Management shall designate defined blackout periods. The list of blackout dates and a justification shall be submitted 30 days prior to the 60 day unannounced audit window.'
I am reluctant to put specific dates in a policy statement because they do not stay the same every year (Christmas is on December 25th but that isn't always a weekday and may not need to be blacked out), we are not having another unannounced audit this year so the blackout dates are not applicable and would just require additional and unnecessary document revisions in my opinion.
Thanksgiving (and Black Friday), Christmas, New Years and our annual inventory fell within our 60 day audit window this year (only 7 days were open after January 2nd, all other available dates would have audited to edition 7.2) When we scheduled the unannounced audit we submitted these specific dates to the certification body. The confirmation page we received for our CB listed the blackout dates and justification on it but the auditor did not accept this as fulfilling the requirements of this element.
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The guidance does not specifically address 2.1.2.10 and I am at a lose as to what is required for it. Do specific control measures need to be adopted and documented?
We have an org. chart and job descriptions that include a provision for alternate/backup coverage in the event of an employees absence as required in other elements of 2.1.2 but that was not what the auditor was looking for.
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We received a 95 on the audit even though we were expecting it to occur before the change to edition 8