Notifying SQF or regulatory warnings.

We just had our GAP audit and got a minor on 2.4.1.3 stating that "Ensure that it is specified that product owned by customers is to be managed by customers, and how any issues related to the facility (FDA inspection findings of the facility, failed health inspections etc.) will be reported to SQF."

 

I have in our policy that we "will be responsible for notifying SQFI and our certifying body within 24-hours if issued a regulatory warning or in regard to an event."  She clearly said when we were discussing this that "the customer has to send the notifications."

 

We do not own any of our stored products, and only 1 of the 5 customers in our first buildings to go SQF are themselves SQF certified.  If a non-SQF customer has an issue regarding product stored in our warehouse, how would they know to contact SQFI and our certifying body? Also, I don't get how if we have a regulatory issue, the customer would be responsible for the notifications.  Why wouldn't we be responsible for notifying everyone: customers impacted, SQFI, and the CB? If a customer has a regulatory issue that involves us needing to take action (like putting product on hold or dumping product for them) does SQFI and our CB need to be notified since we are only a piece of the process?

 

On a side note, our customer had a representative at our audit and was very chatty with the auditor and I know they glossed over a few things, so I don't know if she just missed what I had in our policy or if this is something I need to actually address.  There are a couple other things we got minors for and her comments pretty much match what was in our documents, so between interruptions to chit chat and her referring to one of our sites by another cities name a number of times, I don't know. 

 

Any other 3PL's have any insight on this?  

I'd file a professionalism complaint in regards to the auditor being chatty with your customer that ultimately led to miss-calls.

 

Clearly, it is the responsibility of the SQF certified entity (your facility) and not the customer to do the notification.

 

You had grounds to pull the auditor aside away from your customer but you didn't and now must deal with the fallout.

 

You do that by filing with both the CB and copy sent (not email) to SQFI.

 

You can not allow customer/auditor interference during an audit.

 

Some of our clients did not originally want to file a complaint nor bar customers from being present during audits but once they did they found that things went much smoother.

The SITE is certified, not the product(s) so it's on you to notify

I'd file a professionalism complaint in regards to the auditor being chatty with your customer that ultimately led to miss-calls.

 

Clearly, it is the responsibility of the SQF certified entity (your facility) and not the customer to do the notification.

 

You had grounds to pull the auditor aside away from your customer but you didn't and now must deal with the fallout.

 

You do that by filing with both the CB and copy sent (not email) to SQFI.

 

You can not allow customer/auditor interference during an audit.

 

Some of our clients did not originally want to file a complaint nor bar customers from being present during audits but once they did they found that things went much smoother.

 

The customer paid for the GAP audit and I have only been doing this 8 months (moved from a hazmat facility to a food facility last year) so still very new to all of this.  I have been present for a handful of AIB audits, but this was my first for SQF.  I would have loved to have not had the customer there and have made my opinion known, but I do not get to make those choices.  The person who did our GAP audit will not be doing our initial, but I get zero say in whether or not the customer will be there.  I am also extremely shy in new situations.
I will definitely be more aware during the next audit and as I get more comfortable with what I am doing will press harder to keep things focused and on-task.  

The SITE is certified, not the product(s) so it's on you to notify

 

Thank you!  That is what makes the most sense to me, so I will just tweak it a bit to address that we have customers who are not SQF certified and hope for the best during the initial audit.

You might want to consider getting some balls or people will walk all over you and take advantage where no advantage should be taken. 

You might want to consider getting some balls or people will walk all over you and take advantage where no advantage should be taken. 

 

Your input is noted, but since you are obviously not interested in being helpful and actually answering the questions I had, feel free to ignore my posts going forward.  

Scampi already explained this, providing the direct code reference as this is what you are (or should be) audited to.  This doesn't prescribe any customer initiating a response on behalf of your facility.  Yes they will contact you, however you are still required to meet this code element.  Sounds like your program is meeting this and the tweak should be extra assurance.  

 

2.6.3.4 SQFI and the certification body shall be notified in writing within twenty-four (24) hours upon identification of a food safety event that requires public notification. SQFI shall be notified at foodsafetycrisis@sqfi.com.

 

Best of luck!  

I think I understand what the auditor was getting at. Your SQF-certified customer was the one present during the audit, correct?

SQF code states multiple times that you not only follow applicable legislation and SQF code, but also customer requirements. So I'm thinking that while chatting away, your customer may have mentioned that they want to be the party to notify SQF in the result of a regulatory event or warning. Thus the comment from the GAP auditor. Although if your customer requires that, they should have informed you earlier and an agreement should have been in place...

 

In that case, I would add to your policy/procedure that you are the ones to notify SQF/CB in any such events occurring at your site unless there is a documented customer requirement that both parties have acknowledged and signed. Such an event must directly involve that specific customer's product only; if it affects multiple customers' products, your site will notify all customers involved, as well as SQF and the CB.

 

Then I would follow-up with this customer and ask what they require, then get it in writing and signed by both parties.

 

You said it's not your decision if the customer is present...I'm guessing senior management allowed it? If you can, try explaining to them what happened during the GAP audit and how you're concerned it may have a negative impact on your initial certification audit. I have never experienced having a customer present to witness a scheduled third-party audit...that seems incredibly unusual to me.

 

Good luck!

I think I understand what the auditor was getting at. Your SQF-certified customer was the one present during the audit, correct?

SQF code states multiple times that you not only follow applicable legislation and SQF code, but also customer requirements. So I'm thinking that while chatting away, your customer may have mentioned that they want to be the party to notify SQF in the result of a regulatory event or warning. Thus the comment from the GAP auditor. Although if your customer requires that, they should have informed you earlier and an agreement should have been in place...

 

In that case, I would add to your policy/procedure that you are the ones to notify SQF/CB in any such events occurring at your site unless there is a documented customer requirement that both parties have acknowledged and signed. Such an event must directly involve that specific customer's product only; if it affects multiple customers' products, your site will notify all customers involved, as well as SQF and the CB.

 

Then I would follow-up with this customer and ask what they require, then get it in writing and signed by both parties.

 

You said it's not your decision if the customer is present...I'm guessing senior management allowed it? If you can, try explaining to them what happened during the GAP audit and how you're concerned it may have a negative impact on your initial certification audit. I have never experienced having a customer present to witness a scheduled third-party audit...that seems incredibly unusual to me.

 

Good luck!

 

Yes, the customer that is SQF certified was present and they are the ones requiring (and paying for) us to get SQF certified in the building that stores their products.  This is all new to our company and we've only been working on this about 6 months (they were told last summer of the SQF expectation).  I was moved into this role from another non-food warehouse about 8 months ago.  It's been a LOT of learning for me. and my boss, who is part of senior site management and was at the GAP audit, only has AIB experience.  I will share with upper management that customer presence is not normal and see about having them not be there next time around, but with the customer paying for it initially, I don't know how far I can push that.

 

This whole process has been very stressful, especially since I loved what I had been doing for the last 10ish years (a client shut down and we were all moved to other warehouses).  I only first got my food handlers permit a couple years ago and that was for a volunteer gig, so when I say that I am new to this, I am really new.  I knew what FDA and USDA stood for, but that was about it.  

 

I'm pretty embarrassed by how we did on the GAP audit, but the auditor said she thought we'd been working on this for over a year and other senior site managers had a "it doesn't really count" attitude, so I realize how much worse it could have been.  I just wanted 1 thing I created be really really good, and there were more than that and one that she absolutely loved, which I actually adapted from something I found on this forum that was shared about 15 years ago, so this forum has been a godsend.  I don't think I would have survived this long without it.