SQF Food, 2.5.2 Verification Activities
Hey all,
I am working through desk audit information and running into a bit of a wall with the verification. Code reads:
2.5.2.1 A verification schedule outlining the verification activities, their frequency of completion and the person responsible for each activity shall be prepared and implemented
My questions are these. Would we be doing this for every PRP and GDP and SQF System Element that we review in the SQF and the HACCP? Will I need to have review sheets created at a lower level for each of these items so that they can be reviewed for verification? How does this differ from the monitoring activities that are found in 2.5.2.2? Are there any current examples out there (most of what I see in the forums is from some time ago and may no longer be accurate)?
Lots of questions I know but this is the first section that has me thinking that there may be dozens of sheets of inspections that should be attached for all of the functions.
Cheers!
I hate that particular clause. It inevitably leads to an auditor asking for a specific checklist of verification activities. I inevitably respond with "which program verification do you want to see". I refuse to maintain a separate list for the auditors benefit when each program has it's own schedule.
Defer to Scampi, know what the definition of a verification activity is, have the intervals defined and proof that they were completed, and be ready to speak to it/explain how your system works to the auditor.
I am of the same thinking, that the auditor will be asking for some sort of master list that will detail all of the information out for them. I am guessing that each item will need to have its own monitoring program.. I can validate the programs annually but I think that I will invariably end up needing to create a separate program for each PRP, GDP or element that I bring attention to in my HACCP and/or SQF books. Would you guys have any examples or anything that you could share to point me in the right direction? Cheers!
FFF,
Do you find that not maintaining a list for the auditors benefit upsets them in any way. I would hate to do this and then suddenly find myself in a combative relationship with the auditor. Or worse I ask them which they want to see and they just say "give us everything."
I have a "verification schedule" that the auditor did ask for yesterday..........however it is a VERY vague list that is simply months of the year across the top and SQF elements down the left with a box saying which element is done when, but it would take 3 days to verify that alone so I don't expect it would ever get that far
I guess my worry was that they would be looking for some sort ofmincredibly detailed form that would reference a bunch of other programs. It all seemed redundant. Did the auditor like your sheet?
Auditor was satisfied..........you should also use it so that you know you've reviewed your entire program yearly, if you don't have a schedule, how would you know?
You also know if you have any down times when you are more likely to review the more challenging parts of your program
Also, any CCP's will have a separate validation/verification schedule.....make sure that is in place
Scampi,
I was just going back to this for review. So I just need a schedule (something vague) that lets me know that elements are being verified, their frequency and the responsible party? So I won't need a monitoring sheet that I have filled out everyday by employees on the floor? It would create an incredible amount of paperwork if I need to have a lot of monitoring. As of now I have what you mentioned - the spreadsheets with months, activities and checkmarks for every PRP and SQF System Element.
Secondly, I have validation programs for each one of my PRPs but not for anything else. They look like this:
Validation Summary Report - Allergen Control.docx 18.45KB 462 downloads
Should I be creating these for system elements such as Document Control and Product Trace?
Thanks!
Basically your validation schedule would be the same for HACCP, each section needs an annual review that's why I keep it vague, but each element has sub-elements that may also need re-evaluated
You should have a POLICY for doc control and trace and in the policy it lists associated document so no, I wouldn't be creating a report for those (depending on how many fingers are in that cookie jar of course) but if it's just you and 1 other person who can issue docs than no
The product trace exercises are the yearly evaluation............just ensure your policy states that if there is a change to the HACCP system, another trace exercise will also be performed
Also, you may want to add the list of associate docs to your validation programs so that when you do perform it, you havn't missed anything. It sounds like a big job now,but you'll like come next annual review
That makes sense. So I will be verifying all of the elements but that doesn't necessarily mean that I will need to validate every system element through a specific, signed-off form. I found a verification schedule in the forums that looks like this:
Monitoring & Verification Activities.pdf 325.42KB 717 downloads
Is this overkill? The code does call for every item to be spelled out in the sense of who is doing the verification and how often it is done. I like the one that I have now but it may need to be upgraded to something in between the vague of the current versus the complex of this form.
Thanks for the assist.
Looks great!!!!
at my PP we had actual reassessment forms for each sub-element. It would tell you to grab 5 random records etc and you wrote them all in (but this was in a complex poultry operation where 10 million things could go wrong) and that took 3 days/week of my time
You don't even need a separate record to VERIFY a CCP.........let's say you take the SOP out on the floor to verify employee A is performing task as per the SOP......you simply record the date time etc on that form. As long as it matches what you say you will do........so the nice file that you attached in pdf works perfectly and MAKES sense for your operations
as to the code it also says something really strange
That makes sense. So I will be verifying all of the elements but that doesn't necessarily mean that I will need to validate every system element through a specific, signed-off form. I found a verification schedule in the forums that looks like this:
Monitoring & Verification Activities.pdf
Is this overkill? The code does call for every item to be spelled out in the sense of who is doing the verification and how often it is done. I like the one that I have now but it may need to be upgraded to something in between the vague of the current versus the complex of this form.
Thanks for the assist.
I've used a similar form to this in the past, only slightly simpler with the who, how, and frequency. Do what works with how you have your system set up and your history with your auditor. If it helps you to include guidance and specific documents to reference, or if your auditor has suggested you use that format, then include those too. I think if you have the who, what, how, and frequency of verification documented in some useable way, they won't throw too much of a fit. Our auditor had no qualms with ours.
as to the code it also says something really strange
2.5.2.2 The methods, responsibility and criteria for verifying monitoring of Good Manufacturing Practices, criticalcontrol points and other food safety controls, and the legality of certified products, shall be documented andimplemented. The methods applied shall ensure that personnel with responsibility for verifying monitoringactivities authorize each verified record. ?????????????????? WTH does that mean..........to me that reads people should be checking their own work???
I've always interpreted that as managers checking monitor's work and verifying then signing off on monitor's record, just with a very complicated wording. I could be wrong. :dunno:
So you are saying that I can verify the activities/elements using this program, couple it with having "monitoring" documents signed or checked on the floor AND THEN validate only my PRPs in the format from my earlier post I will completely satisfy 2.5.1 and 2.5.2. Basically running the whole process through Monitor, Verify and the PRPs through Validate. I will need to create a bunch of extra documents but that doesn't necessarily mean that every single system requirement will require them all. Am I on the right track with this line of thinking?
MsMars you and I both know that's what SHOULD occur, but if you're new to SQF how in gods name could you ever figure out what that is supposed to mean!! I mean it's laughable.........and they wonder why facilities have a hard time????
So today I have resolved to do a verification and validation of every system element in SQF and every PRP in my HACCP Plan. It will be a ton of paperwork but once it is done it will be done. Stop me if this is overkill lol
It isn't overkill Brendan, it's what's required
Alot of items will only take a minute...........like a PRP for laundered uniforms.........your program says an outside vendor supplies the smocks........you didn't have any issue last 12 months, smocks always available..........you're done!
AND if this isn't done, how do you really know if A) all of it is required? and B) any of it is actually working
This is where you usually find out some random (but important) process has changed and you didn't know (i always blame maintenance and Ops lol)
Thanks Scampi,
I think the pain I was running into was whether or not everything needed to have a verification plan AND a validation. I reread the manual and my gut told me to just do it.
I will post my reports once I have them finished. maybe it will save someone else from the nightmare lol
sorry maybe I missed something...............you don't need to VALIDATE everything.......this is where SQF muddied the water with the incorrect definitions
CCP and CP should be validated, but you only ever need to do that once...........so let's say a blast freezer needs VALIDATED to ensure it can meet time/temp requirements under worst case scenario..........you would run data loggers all over the place, review the data and yep, blast freezer is capabale of above........that's a VALIDATION
Then once/year, you would look specifically at the program and records for that step (blast) to ensure it ALWAYS met the requirement...........you've VERIFIED that it is STILL working
FFF,
Do you find that not maintaining a list for the auditors benefit upsets them in any way. I would hate to do this and then suddenly find myself in a combative relationship with the auditor. Or worse I ask them which they want to see and they just say "give us everything."
Sorry for the late reply.
It has depended on the auditor. Typically I turn it against them and keep asking them what program they want to see verified. I have had them get testy so you have to be willing to stick it on this point. I have a list of things worth fighting about and ones not worth fighting about. I'd found this one to be worth it because it adds unnecessary documentation to my program for no benefit other than the auditor's. If I saw an additional benefit I would make another checklist.
That makes sense. So I will be verifying all of the elements but that doesn't necessarily mean that I will need to validate every system element through a specific, signed-off form. I found a verification schedule in the forums that looks like this:
Monitoring & Verification Activities.pdf
Is this overkill? The code does call for every item to be spelled out in the sense of who is doing the verification and how often it is done. I like the one that I have now but it may need to be upgraded to something in between the vague of the current versus the complex of this form.
Thanks for the assist.
Good work!!
Would you not also include pre-operational inspections (daily) as verification of the cleaning program, and that, or other means, for verifying the effectiveness of waste disposal? See SQF code " 11.2.13.5 Pre-operational inspections shall be conducted following cleaning and sanitation operations to ensure food processing areas, product contact surfaces, equipment, staff amenities and sanitary facilities and other essential areas are clean before the commencement of production. Pre-operational inspections shall be conducted by qualified personnel' AND " 11.9.1.9 Reviews of the effectiveness of waste management will form part of daily hygiene inspections and the results of these inspections shall be included in the relevant hygiene reports"
I note this thread focuses on "Verification"(Ve). However this unavoidably involves an appreciation of the difference between Validation(Va) and Ve. Otherwise a post tends to become unintelligible.
A, IMO, logical and readable explanation of Validation is the classic document issued by FSIS, ca 2014. Frequently posted on this Forum.
I assume the SQF/Va/Ve situation in Ver8 is unchanged from ver7.2.
It seems that the terms validation and verification are still being intermingled as arbitrarily as always.
This topic has been a SQF/SQF auditor, notorious headache for at least 10 years.
A few years back SQF changed their official viewpoint on Validation at the time of issuing ver.7.2. Unfortunately many of their auditors were (and possibly still are) unable to follow the change. Subsequently SQF acknowledged the internal confusion and published a definitive statement as to the intended interpretation on their website. May even still be there.
Just as an example, PRPs were/are(?) definitively not required to be validated. Only verified. But some auditors will probably, adamantly, still disagree. Net result - for a quiet life, no choice but to provide what the auditor expects to see.
Verification is relatively less controversial but still open to conflicting viewpoints as to the data employed.
There are one or two quite comprehensively scoped attachments previously posted here (ver 7.2) on what SQF auditors typically expect to see to represent "Verification". Notably, IIRC, one excel document from Marshall (mgourley).
I strongly suggest to do a little searching.
I cannot offhand imagine why SQF would want people to validate a control point. Is it specifically stated to be so required ?
Similarly, unless specifically stated to be required, Validations logically do not need routinely repeating unless some significant change has occurred to the specific item involved. Verifications maybe more likely to require updating but depending on the item. In the case of a CCP, monitoring is presumably giving self-verification.
I agree Charles
Everyone ought to follow Codex HACCP verification and validation systems and ignore the SQF confusion entirely (the definitions in SQF 8 do not clarify things at all)
https://articles.ext...dation-of-haccp
VerificationWebster defines verification as “To establish the truth, accuracy, or reality of.” The National Academy Committee on Microbiological Criteria further defines verification for HACCP for Foods (NACMCF, 1997) as “Those activities other than monitoring that determine the validity of and compliance with the HACCP plan.” Several tasks should be identified as verification activities for the HACCP system. These include verification of prerequisite programs, verification of the critical control points, and verification of the overall HACCP plan. In addition, the regulations in 9 CFR 417 identifies verification activities that which will be performed by the USDA inspectors. Companies may also consider involving outside experts in an audit or may send personnel to suppliers of food ingredients to verify HACCP and food safety plans.
Validation
Validation is also part of Principle 6, Establish Verification Procedures. Validation is defined as “to support or corroborate on a sound or authoritative basis” or to “establish validity of the HACCP plan by supplying factual proof.” Within HACCP, validation is “the element of verification focused on collecting and evaluating scientific and technical information to determine if the HACCP plan, when properly implemented, will effectively control the hazards” (NACFMF, 1997). Validation can be accomplished by conducting in-plant studies, providing literature citations, and conducting pathogen inoculation studies in controlled laboratory settings.