SQF & FSMA Plan
Does having a complete SQF module 2 & module 9/11 plan meet the requirements for FSMA? Off the top of my head I think the differences is critical control points vs preventive control points?
CCP counts under the definition of their preventative controls, but they also want to know about the PRPs you're using to control the less significant hazards (I think they like the phrase "process controls" for those)
I generally find that strong programs built around your GFSI scheme, this case being SQF modules 2 and 9/11, will usually get you most of the way to being FSMA compliant. I recommend you run a specific FSMA checklist against your FSQMS to ensure you are compliant. One example is FSMA requires a Preventative Controls Qualified Individual (PCQI) to develop and apply your programs, where SQF requires the person to be a SQF Practitioner, and the two aren't necessarily identical as FDA requires the person to undergo training equal to the program they've approved.
Example checklist I found online with some great information for each question:
humanfoodsafety_for_processors_update_12_19_17.pdf (ncrfsma.org)
CCP counts under the definition of their preventative controls, but they also want to know about the PRPs you're using to control the less significant hazards (I think they like the phrase "process controls" for those)
I generally find that strong programs built around your GFSI scheme, this case being SQF modules 2 and 9/11, will usually get you most of the way to being FSMA compliant. I recommend you run a specific FSMA checklist against your FSQMS to ensure you are compliant. One example is FSMA requires a Preventative Controls Qualified Individual (PCQI) to develop and apply your programs, where SQF requires the person to be a SQF Practitioner, and the two aren't necessarily identical as FDA requires the person to undergo training equal to the program they've approved.
Example checklist I found online with some great information for each question:
humanfoodsafety_for_processors_update_12_19_17.pdf (ncrfsma.org)
Thank you. I am a SQF practitioner and also PCQI certified. However, Im just really learning the SQF system. I did complete an online course but fully understand the nuances until I start developing the system. I think I'll focus on SQF first, then use an FSMA checklist to fill in the gaps as you recommend.
See attached, SQF has an addendum out just for the purpose of aligning with FSMA.
Attached Files
the sqf expectation is that you also meet regulatory requirements. Because the standards are meant to cover many countries they use the term "legislation". The facility is responsible for understanding those regulations. So, it you are meeting "legislation' you are in compliance with both. It just not spelled out how to do it for each country.
"Comply with customer and regulatory requirements to supply safe food"
"The site shall ensure that at the time of delivery to customers finished products shall comply with food safety legislation applicable in the country of manufacture and sale. This includes compliance with legislative requirements applicable to maximum residue limits, food safety, packaging, product description, net weights, nutritional, allergen, and additive labeling, labeling of identity preserved foods, any other criteria listed under food legislation, and to relevant established industry codes of practice."
"A food defense plan shall be documented, implemented, and maintained based on the threat assessment (refer to 2.7.1.1). The food defense plan shall meet legislative requirements as applicable and shall include at a minimum:"