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SQF 2.5 Verification and Validation

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Best Answer , 09 May 2023 - 10:45 AM

lol so the SQF - Validation and Effectiveness.pdf that Charles sent is for "Validating" not for verifying.  So, I would have to add the elements in it to the verification schedule, if not already there, and then validate them and the CCP limits.

 

I am going to talk myself through this to try and get some self-clarity.  Anyone please correct me if I am wrong.

 

  1. Internal Audits - Pretty simple - I am going to use the SQF provided checklist.
  2. Verification - I will use the verification schedule, that I have in OP, and the daily records to verify that the activities are being completed.  Some of the elements do not have records to check but I have methods in my verification schedule that give guidance on how to check those items.  I can put records of all of those checks in our meeting minutes and maintain the other sheets in our files.
  3. Validation - I can use the Validation Sheets that Charles sent me for each PRP but also for each major section, not already created by the sheets, as validation paperwork for each major system element group (ie. Management Commitment 2.1, Document Control 2.2, Food Safety System 2.4, etc.).

This is a pretty serious document-heavy part of the process.  BUT  maybe this is it.  Let me know what you all think.  Thanks.

 

Cheers!


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Charles.C

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Posted 10 May 2023 - 03:36 AM



lol so the SQF - Validation and Effectiveness.pdf that Charles sent is for "Validating" not for verifying.  So, I would have to add the elements in it to the verification schedule, if not already there, and then validate them and the CCP limits.

 

I am going to talk myself through this to try and get some self-clarity.  Anyone please correct me if I am wrong.

 

  1. Internal Audits - Pretty simple - I am going to use the SQF provided checklist.
  2. Verification - I will use the verification schedule, that I have in OP, and the daily records to verify that the activities are being completed.  Some of the elements do not have records to check but I have methods in my verification schedule that give guidance on how to check those items.  I can put records of all of those checks in our meeting minutes and maintain the other sheets in our files.
  3. Validation - I can use the Validation Sheets that Charles sent me for each PRP but also for each major section, not already created by the sheets, as validation paperwork for each major system element group (ie. Management Commitment 2.1, Document Control 2.2, Food Safety System 2.4, etc.).

This is a pretty serious document-heavy part of the process.  BUT  maybe this is it.  Let me know what you all think.  Thanks.

 

Cheers!

Hi Brendan,

 

Few thoughts -

 

 

Re - No. 2 - Some care may be required as to what you specifically meant by "completed". I assume that the term "completed"  (eg OP attachment) implies coverage of items (a-d)(notably [d]) below in this quote from Tip Sheet 16.

 

Verification activities should be outlined in a verification schedule, which should include [a] a description of verification activities, [b] monitored frequency of completion, [c] designated responsible personnel, and [d] proof of proper implementation and record keeping (see example at end of this Post).

 

 

Re -  No. 3 - It does appear that SQF still accepts that Review-type activities (eg audit) may also be used to "Confirm Effectiveness of Prerequisites" (aka Validation) within section 2.5.1 (Validation and Verification), eg from Tip Sheet 16 -

 

Critical food safety limits are said to be validated when they have been confirmed by scientific analysis. Prerequisite programs and other food safety controls, however, are confirmed by observation, inspection or audit to ensure that they are achieving the desired result. It is required that Critical Control Points (CCPs) and Critical Quality Points (CQPs) be validated at an agreed upon frequency.

(Note the above textual distinction for PRPs between "validated" and "confirmed")

 

In the case of PRPs it appears that the same audit might perhaps satisfy  both "Validation" and Verification (eg see Tip Sheet 16, 2(e). !

 

PS - the "Va and Effectiveness" attachment in Post 20 (Credit erin)  also had a paired document giving details of the individual PRP "Validations" . JFI this is  attached below.

 

Attached File  Validation Summary Sheets.pdf   1.28MB   31 downloads

 

PPS - JFI I repeat a paragraph from Scampi's original link -

 

Both verification and validation are required or else food-safe outcomes may not be achieved.

Validation Without Verification...

Hand washing with soap is a valid method for removing dirt/grime from hands. However, if verification does not occur and employees do not actually wash their hands, then it doesn't matter how scientifically-proven the strategy is.

Verification Without Validation...

Hand washing without soap is not a valid method for cleaning hands. Even if a manager verifies that hand washing is occurring as required, it doesn't matter because hand washing without soap is not a valid method for cleaning hands

 

 

the above is intended to illustrate this definition of Verification -

 

Verification means conducting a review to confirm a process was performed correctly. Verification answers the question "How do you know it actually happened?"

 

Example: A manager in a cookie factory reviews production records to confirm that the cookies were baked to the temperature described in the recipe.


Kind Regards,

 

Charles.C


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Posted 10 May 2023 - 03:56 PM

Hi Brendan,

 

No intention to rain on your (SQF) Parade but IMHO SQF's handling of Validation/Verification is basically flawed particularly for the reasons outlined in Post 18.

 

IMO it succeeds in creating one heck of a mess (eg this thread) when other  alternative approaches (eg more accurately based on Codex) offer more logical (and simpler) solutions/Procedures.

 

SQF's  attempted partial correction of the flaws (eg "Validation" > "Confirm Effectiveness") was introduced  around ver.7 but seems to have also auditorially failed despite SQF's continuing textual re-iteration. The failure was possibly "admitted" by the appearance of the word "validate" in the intro of ver9/Clause 2.5.1 replacing the  "ensure" of ver 8.1.

 

Regardless, I agree that Post 25 probably makes the best of an unfortunate situation.

 

PS - 2 more attachments which IMO make interesting reading -

Attached File  BRC-SQF - Which PRPs Need to be Validated.pdf   550.58KB   21 downloads

(ex techni-k)

Attached File  TUV,Verification_Whitepaper,2017.pdf   7.43MB   16 downloads

 

 


Kind Regards,

 

Charles.C


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Posted 02 October 2024 - 05:18 PM

 

Based on my understanding of your explanation here, I think your daily checks and walkthroughs would count as verification activities.  You're doing a regular check that the procedures are being followed.  Later checking those records, along with other program elements, would count as an audit of that program.  Personal example:  I've had daily/weekly checks that pest control traps are where they're supposed to be, that door closers function and door seals are intact, and that the PCO came when scheduled, as part of my pest control verification.  Once per quarter, I would review the information from checks, trend the information from captured pests, review incident logs for pest problems, and check my pest control program against the published SQF standard to make sure that the pest control was under control and in compliance with the SQF standard.  This quarterly review is an audit, and if the program is working well over the course of a year to control pests, I would consider that the program has been validated.

 

 

 

To your other post about verification schedule vs internal audit schedule:

  • Verification Schedule:  I've built a spreadsheet that outlines all of my programs and lists what verifications/checks we do and how frequently we do them.  ATP tests done daily or after each sanitation run + a startup inspection daily as a verification of sanitation, pest traps checked weekly, storage area inspections done weekly, temperature probes for x area checked every two hours, etc.
  • Internal Audit Schedule:  Separate spreadsheet describing all internal audits you perform and their frequency.  GMP audit done monthly to include checking training records are complete, check results from weekly inspections, check program meets standards.  Pest control audit performed quarterly to check PCO performance, trend captures data, review weekly checks, check program meets standards.  So on, so forth.

 

 Can you share how you do it, the sheets examples?



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Posted 02 October 2024 - 06:05 PM

 Can you share how you do it, the sheets examples?

 

I don't have anything specific that would help, unfortunately.  It's been a few years since I built something like I described, and my current role doesn't have me working with my plants on this type of prep.  Sorry!





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