SQF 11.7 - Separation of Functions
Has anyone not included 11.7 because they aren't a high risk process and the auditor didn't say anything? Did you still keep the separation of functions topic??
In our Separation of Functions policy, before listing applicable sections of code, we specifically state in the Scope that we have no frozen raw materials, high-risk food, or sensitive areas. We also reference our HACCP Plan. No issues during audits.
We used a flow diagram and risk analysis to determine if any high risk areas had to be called out. That was documented and saved as our Separation of Functions 11.1 document. We decided that our production are which had exposed raw food was the only area that would be high risk, so we included air testing. The meat of it looks like this-
High risk area:
- Adequate segregation from raw material, packaging, and finished product storage areas
- Production area is serviced by dedicated staff.
- This staff is trained to and practices a high standard of personal hygiene to prevent product contamination and cross contact.
- Dedicated protective clothing, tools and equipment are provided.
- Staff change into clean distinctive clothing or temporary protective outerwear when entering production area and as needed if clothing becomes soiled or contaminated
- Ambient air has a baseline test and is tested as minimum of annually or if area or process flow changes