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.
