Filling out Nonconformances to return to SQF auditor

Having difficulties coming up with root cause and root cause evidence for the auditor.

We had minors due to not having the correct bandages, or not including the scope of certification (a bunch of little things like this)

What would the best way to create a root cause/root cause evidence

I read on here about using:

Misinterpretation

oversight

We got colored bandages, but they weren't metal detectable. We didn't think this was an issue since we don't have metal detectors. So would the root cause be misinterpretation of the code? what would the root cause evidence be?

Sorry if this seems jumbled.

Thank you for all the advice.

Edition 8, clause 4.3.1.3?

We got colored bandages, but they weren't metal detectable. We didn't think this was an issue since we don't have metal detectors. So would the root cause be misinterpretation of the code? what would the root cause evidence be?

 

 

Sorry if this seems jumbled.

 

Thank you for all the advice.

Challenge that one. Your auditor was incorrect to issue it. Assuming you're under module 11 for human food. The affected clause is:

11.3.1.3 Personnel with exposed cuts, sores or lesions shall not be engaged in handling or processing products or handling primary packaging materials or food contact surfaces. Minor cuts or abrasions on exposed parts of the body shall be covered with a colored bandage containing a metal strip or an alternative suitable waterproof and colored dressing.

 

The module 11 Guidance specifically states:

Bandages are to be brightly colored to ensure they can be easily seen and include a metal strip for ease of detection, if the site uses metal detection.

 

So challenge that one, they auditor is not following the code or SQF's guidance.

Not including something in the scope of certifiation, we're going to need more detail. Did you plan to include all areas of your business and forgot to list them all?

NON-CONFORMANCE: The facility has not identified the SQF food sector category applicable to its scope of certification (14).

On your bandage issue:

Yup, all the "Bandage" requirement in the other sections are pretty much the same: you got BRC audited it seems  :sleazy:

The clause itself is open to interpretation: "alternative suitable" is in the clause... arguing the point remotely via email and throwing the Guidance document at the auditor can be rather... awkward.

I have had issues with auditors for doing this; and there is no mechanism to really address it (that is an entire other discussion) apart from convincing them of their error during the audit 

-B

I am not worried about the bandage issue. We have fixed the nonconformances. But when filling out the form to return to the auditor I just don't know how to address the root cause. As they are such simple fixes that didn't really require a root analysis.

With the food sector. We got a minor because we did not state that we were under sector 14.

I guess I'm confused on that one...how did your CB assign an appropriate auditor to you if they had no idea what your category was? That requirement doesn't show up anywhere in the "Code" other than establishing which modules apply and that it needs to be communicated to your CB.

Bandage root cause: I'd be a little sassy and state that the auditor interpreted the code differently than us. The preventive action would be to work with the CB and determine why our interpretation was incorrect.

I literally have a root cause response I submitted last year that states:

"During the audit and in post-audit review, it was noted that in neight the SQF Code (7.2) section 2.7.1, nor in the associated guidance for implementation and auditing makes reference toa requirement for a formal risk assessment as part of the food defense plan. The guidance specifically states that the firm must provide responsibilities and methods of protecting specific areas including employee identification, visitor access, physical security, chemical storage, sensitive areas, storage of materials, transportation, and tamper evident packaging. All of these areas were addressed in our plan, which is further supported by SOP's covering visitor procedures, receipt of materials, etc. Root cause: this requirement was not available in either the SQF code nor the guidance for implementation and auditing, therefore we had no way of knowing that this was required."

 

It is quite humorous (I chuckle) because the NC's we've had, after the RCA, was "management misunderstanding of code requirements" or "misinterpretation..."

So yes, you can absolutely use this.