SQF 9 Food Manufacturing – Module 11 clarification
We had our annual SQF audit, and one of the NCs was that we did not inspect our Soda Ash railcar during receiving. We are a chemical plant that produces a food product from some ingredients including bulk Soda Ash. The SQF standard cited for this is 11.6.5.1, but in that standard it specifically calls out food only. Bulk Soda Ash is not considered a food at this point and must undergo a synthesis process where there is no risk of any bacterial contaminants or foreign materals making it into the final product from the Soda Ash.
Would these railcars still require inspection per 11.6.5.1 given this?
Yes.
I am assuming this was explained to the auditor during the closing meeting, and they still felt they would give it as a finding?
At this point I would take one of two routes:
- Contest the finding citing exactly what you've cited here, maybe adding in info on how you keep this non food grade item segregated from any food deliveries -OR-
- Update your soda ash receiving doc to include ANYTHING that has to be checked (COA to purity standards, etc.)
I worked in a chem plant that took in anhydrous ammonia, hydrochloric and sulfuric acids. NONE of them food grade. We used them to make food grade salts. While I wasn't SQF in that facility, many auditors did attempt to shoehorn us into similar requirements and the fact we checked a COA (for purity) typically sufficed as our 'receiving program'. I don't see why that wouldn't also suffice for SQF.
However, all that being said, I'd probably just contest this one with the auditing body. It's not food when you take it in...
We had our annual SQF audit, and one of the NCs was that we did not inspect our Soda Ash railcar during receiving. We are a chemical plant that produces a food product from some ingredients including bulk Soda Ash. The SQF standard cited for this is 11.6.5.1, but in that standard it specifically calls out food only. Bulk Soda Ash is not considered a food at this point and must undergo a synthesis process where there is no risk of any bacterial contaminants or foreign materals making it into the final product from the Soda Ash.
Would these railcars still require inspection per 11.6.5.1 given this?
By your own description you produce food using this ingredient, so the argument that this material is not edible at this stage seems very weak. I can imagine the potential for chemical contamination that would certainly pose a food safety risk at later stages if container integrity or unloading conditions were not controlled or monitored adequately.
Take a recent example like lead in cinnamon making its way into children's apple sauce. Far enough up the chain someone though it was a good idea to use lead to boost their stats. Extrapolating that to your situation I can imagine a toxic mineral with similar organoleptic or reactive properties entering a chemical refining process if no one is checking seals, or monitoring containers for contamination.
This just needs a simple check that the container and product has been checked and that the product has not been cross contaminated. Check to ensure no pest activity/contamination, dry, free from foreign matter, cross contamination from other chemicals, agriculture contaminates, (allergen!!!) etc.
We've had deliveries of products cross contaminated with soy/peanut/seeds etc, because the containers were not properly cleaned before being filled with product. If we didn't check the container at receipt and before unloading we would never have known.
Write a simple procedure and then get a stamp made up that you stamp the delivery docket with to say container has been checked and is compliant and then signed off. The check can also cover off food defence as well to ensure the rail car has not been tampered with and the product is what it says it is.
Yes. Adulteration or contamination would be hard to detect without inspection
Then this in the news,
Chinese state-run grain stockpiler Sinograin was using the same tanker trucks to transport both fuel and food oil products, without any cleaning process between. Some of the oil may ultimately be packaged into small bottles for foreign sales.
An inspection of the tankers prior to filling with food grade oils should have captured and prevented this, but may be a bit harder to detected at delivery. Maybe they did the inspection but chose to ignore.