Appeal SQF Storage & Distribution NC
I recently had an auditor give me a NC on the following:
12.2.5.2 Non-Conformance: Chemical products (detergents, sanitizers, soaps, etc.) were found placed on food products at dry storage locations #G25-41-11 and #G24-88-12. The site chemical control policy states that chemical goods should not be placed on or over food products.
The code reads -
12.2.5.2 - Detergents and sanitizers shall be suitable for use in a food and storage and handling environment, labeled according to regulatory requirements, and purchased in accordance with applicable legislation. The organization shall ensure:i.The site maintains a list of chemicals approved for use;ii.An inventory of all chemicals purchased and used is maintained;iii.Detergents and sanitizers are stored as outlined in element 12.6.4;iv.Safety Data Sheets (SDS) are provided for all detergents and sanitizers purchased; andv.Only trained staff handle sanitizers and detergents.
The finding should actually apply to code 12.6.1 Receipt, Storage and Handling of Goods. Since the auditor noted this down as the incorrect code, would this qualify as a means to appeal the finding?
So, you want to file an appeal because it was miss-coded?
If true, don't botther - cause you'll get giged for 12.6 as well then. 12.2.5.2 being a sub code eludes to another plus has points on it's own.
And by the way - does your policy actually have the word "should" in it - if so, I must say that I am surprized this non-action word was not caught as well as the potential miss-coded call?
So, you want to file an appeal because it was miss-coded?
If true, don't botther - cause you'll get giged for 12.6 as well then. 12.2.5.2 being a sub code eludes to another plus has points on it's own.
And by the way - does your policy actually have the word "should" in it - if so, I must say that I am surprized this non-action word was not caught as well as the potential miss-coded call?
Policy states "shall" so in other words yes.
12.2.5.2 - Detergents and sanitizers shall be suitable for use in a food and storage and handling environment, labeled according to regulatory requirements, and purchased in accordance with applicable legislation. The organization shall ensure:
i.The site maintains a list of chemicals approved for use;
ii.An inventory of all chemicals purchased and used is maintained;
iii.Detergents and sanitizers are stored as outlined in element 12.6.4;
iv.Safety Data Sheets (SDS) are provided for all detergents and sanitizers purchased; andv.Only trained staff handle sanitizers and detergents.
12.2.5.2 is requiring the chemicals to be stored as specified in 12.6.4 (referencing the entire section, not going down to the 4th decimal level), so the finding under 12.2.5.2 in of itself is fine.
To go a step further, I'd argue the auditor did you a favor. Had he listed the finding under, say, 12.6.4.2, it could make argued that it opened the door to be a major instead of a minor:
12.6.4.2 Hazardous chemicals and toxic substances shall be stored:
i. In an area with appropriate signage; (failed)
ii. Accessible only by personnel trained in the storage and use of chemicals; (failed)
iii. Separated from the distribution storage area so as not to present a hazard to staff, product, packaging, or product handling equipment; (failed)
iv. In their original containers, or in clearly labeled secondary containers if allowed by applicable legislation; and SQF Food Safety Code: Storage and Distribution, Edition 9 61 PART B: The SQF Food Safety Code: Storage and Distribution – Module 12 (can't say, insufficient information)
v. Stored so that there is no cross-contamination between chemicals. (borderline failed)
It's one thing when they find you're storing chemicals in the wrong cabinet. Finding chemicals sitting atop product unattended opens the door to asking whether a disgruntled employee mixed them with other chemicals or adulterated product in your storage area. It shows the chemicals were fully out of control within your facility.
• A major non-conformance is a failure of a system element (3.5 out of 5 items not met seems to count), a systemic breakdown in the food safety management system (violated SQF and your own SOP), a serious deviation from the requirements (nothing happened but a jerk auditor would say that something could have...), and/or absence of evidence demonstrating compliance to an applicable system element or Good Operating Practices. It is evidence of a food safety risk to products included in the scope of certification (sitting atop product, yep).
I'm kind of taking it to an extreme level to prove a point. I've consulted for a handful of firms atop running a couple QA departments, so I'm all for defending something to try and avoid a finding, but I think I'd take this lump and move on.
12.2.5.2 - Detergents and sanitizers shall be suitable for use in a food and storage and handling environment, labeled according to regulatory requirements, and purchased in accordance with applicable legislation. The organization shall ensure:
i.The site maintains a list of chemicals approved for use;
ii.An inventory of all chemicals purchased and used is maintained;
iii.Detergents and sanitizers are stored as outlined in element 12.6.4;
iv.Safety Data Sheets (SDS) are provided for all detergents and sanitizers purchased; andv.Only trained staff handle sanitizers and detergents.
12.2.5.2 is requiring the chemicals to be stored as specified in 12.6.4 (referencing the entire section, not going down to the 4th decimal level), so the finding under 12.2.5.2 in of itself is fine.
To go a step further, I'd argue the auditor did you a favor. Had he listed the finding under, say, 12.6.4.2, it could make argued that it opened the door to be a major instead of a minor:
12.6.4.2 Hazardous chemicals and toxic substances shall be stored:
i. In an area with appropriate signage; (failed)
ii. Accessible only by personnel trained in the storage and use of chemicals; (failed)
iii. Separated from the distribution storage area so as not to present a hazard to staff, product, packaging, or product handling equipment; (failed)
iv. In their original containers, or in clearly labeled secondary containers if allowed by applicable legislation; and SQF Food Safety Code: Storage and Distribution, Edition 9 61 PART B: The SQF Food Safety Code: Storage and Distribution – Module 12 (can't say, insufficient information)
v. Stored so that there is no cross-contamination between chemicals. (borderline failed)
It's one thing when they find you're storing chemicals in the wrong cabinet. Finding chemicals sitting atop product unattended opens the door to asking whether a disgruntled employee mixed them with other chemicals or adulterated product in your storage area. It shows the chemicals were fully out of control within your facility.
• A major non-conformance is a failure of a system element (3.5 out of 5 items not met seems to count), a systemic breakdown in the food safety management system (violated SQF and your own SOP), a serious deviation from the requirements (nothing happened but a jerk auditor would say that something could have...), and/or absence of evidence demonstrating compliance to an applicable system element or Good Operating Practices. It is evidence of a food safety risk to products included in the scope of certification (sitting atop product, yep).
I'm kind of taking it to an extreme level to prove a point. I've consulted for a handful of firms atop running a couple QA departments, so I'm all for defending something to try and avoid a finding, but I think I'd take this lump and move on.
As mentioned previously, its actually not 12.6.4.2 but 12.6.1. These were not loose chemical bottles that a sanitation associate left unattended. These were packaged and palletized received product stored in reserve locations in the warehouse. Pallet locations that happened to be stored above food product.
I get your point :) I was just wondering if it was worth appealing even if it didn't apply to that particular section. Thank you!
It's not pico to argue about what number the NC should have.
As mentioned previously, its actually not 12.6.4.2 but 12.6.1. These were not loose chemical bottles that a sanitation associate left unattended. These were packaged and palletized received product stored in reserve locations in the warehouse. Pallet locations that happened to be stored above food product.
I get your point :) I was just wondering if it was worth appealing even if it didn't apply to that particular section. Thank you!
Oh I gotcha now, that is a different case then. Still a finding valid though, so probably not worth the effort to try and appeal. SQF would probably just revise the CB's report to the better fitting code.
I recently had an auditor give me a NC on the following:
12.2.5.2 Non-Conformance: Chemical products (detergents, sanitizers, soaps, etc.) were found placed on food products at dry storage locations #G25-41-11 and #G24-88-12. The site chemical control policy states that chemical goods should not be placed on or over food products.
This looks like you got the minor because you weren't following your own policy.
12.6.4 just calls out hazardous chemicals and toxic substances, so I'm guessing the chemicals were not hazardous or toxic? If not, that might be what saved you from further non-conformities.
Hi kestraduh,
Given you have acknowledged that it is a NC and corrective action is needed, I can’t see any upside to an appeal.
Personally, based on the information given, I think the auditor is correct:
12.2.5.2 iii. Detergents and sanitizers are stored as outlined in element 12.6.4;
12.6.4.2 Hazardous chemicals and toxic substances shall be stored:
iii. Separated from the distribution storage area so as not to present a hazard to staff, product, packaging, or product handling equipment;
Kind regards,
Tony