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In July, the Safe Quality Food (SQF) Institute published an article citing the most common non-conformances encountered during certification audits. Interestingly, the transition to SQF edition 9 has changed the number and types (i.e., critical, major, minor) of non-conformances SQF is seeing, with non-conformances related to pest prevention, Food Safety Plan, cleaning and sanitation, and management review and internal audits topping the list.
KTL’s food safety experts break down SQF’s top non-conformances and what you can do to address them.
Prioritizing Pest Prevention
According to SQF, pest prevention is the leading non-conformance under edition 9, with both critical and major findings. Exposure to pests—and the diseases they carry—creates the risk of food contamination and the spread of infectious diseases. Companies need a pest prevention program, whether managed internally or by a third-party contractor, that integrates sufficient measures to minimize pest populations. This may include mechanical preventions and controls, waste minimization, or controlled use of pesticides.
- Review any findings with your food safety team and the pest control contractor, if used. Include frequent review of the approved chemicals or chemicals used for any treatment and ensure the site has access to copies of their safety data sheets (SDSs). Corrective and preventive actions (CAPAs) should be applied to act right away on any open observations. CAPAs should be regularly monitored and tracked to closure. If a third-party contractor is used, open observations should be discussed with the contractor; they may have helpful information on how to handle a pest issue.
- Review pest control trending data at monthly management review meetings. This will help ensure pest prevention data is tracked and monitored. It can also help identify larger, more systemic issues that might necessitate additional CAPAs to resolve the problems.
- Incorporate evaluation of pest prevention performance into the validation and verification schedule.
- Validation should include review of inspection records (at each visit), an annual assessment by the food safety team or pest control provider, and review of trends at the annual management review meeting.
- Verification should include a monthly visual inspection during internal good management practices (GMP) inspections. A simple check to ensure these inspections are thorough enough can involve putting a business card in a tin can for pest control to find and identify on the report.
SQF Tip Sheet: Pest Prevention
Strengthening the Food Safety Plan
The Hazard Analysis and Critical Control Points (HACCP) Food Safety Plan is the foundation of the SQF System. Given this, it makes sense that non-conformances related to the Food Safety Plan always top the list. SQF indicates that many of these findings are now being marked as critical with edition 9. The most common non-conformances include missing hazard analysis, incomplete ingredient hazard analysis, and misidentification of critical control points (CCPs).
- Review and update the HACCP Plan at least annually or whenever there is a change to operations (e.g., ingredients, processes, equipment, etc.) to ensure all inputs and outputs are identified and appropriately managed.
- Use a risk ranking chart to identify risks; determine their severity and likelihood; and document when a hazard is controlled by a GMP, CCP, or other preventive control (PC).
- Use specification sheets and known information about ingredients to facilitate the identification of hazards during the hazard analysis. Ensure copies of any studies or guidance documents are available to the HACCP team and any applicable updated scientific consensus is reviewed. Hazards should be specifically identified rather than just listed as general categories (e.g., biological, chemical, etc.).
- Document everything in a food safety management system (FSMS). Recordkeeping proves that all requirements of the Plan are met.
SQF Tip Sheet: HACCP Food Safety Plan
Emphasizing Cleaning and Sanitation
Cleaning and sanitation methods vary based on the nature of operations, as well as the microbiological and allergen risks. Regardless, every facility needs to develop, implement, and document a cleaning and sanitation program that fits their production processes. According to SQF, this area remains second on the list of major findings in edition 9.
- Understand all the areas and equipment that need to be cleaned and sanitized in the facility. Pay attention to the condition of floors, ceilings, walls, doors, etc. to ensure you are maintaining a hygienic and safe environment.
- Create a robust cleaning and sanitation, preventive maintenance, and maintenance schedule. Regular maintenance of equipment, utensils, and building materials is crucial to prevent non-conformances.
- Incorporate monitoring of the cleaning and sanitation program into the validation and verification process:
- Validation: Review sanitation records and logs, environmental monitoring records, and trending data to identify areas of concern.
- Verification: Conduct visual inspections and records review. Consider swab testing to monitor compliance and trends, especially if using a contracted company for cleaning and sanitation. Review GMP inspection findings and CAPAs at monthly management meetings and track to closure.
SQF Tip Sheet: Cleaning and Sanitation
Management Review and Internal Audits
SQF includes management review (220.127.116.11) as minor nonconformance, highlighting the importance of incorporating food safety culture into the review process. Internal audits remain a crucial way to identify areas of improvement, though they are now on the minor non-conformance list.
- Set objectives/goals for the year and monitor the performance of these objectives at monthly and annual management review meeting. Resources should be allocated appropriately based on trends identified in these meetings to reach goals and ensure the overall effectiveness of the food safety culture.
- Conduct regular GMP inspections, trend results, review them during management meetings, and identify CAPAs, as necessary.
- Distribute food safety questionnaires to personnel to gather input. Review results during management review meetings and use the data collected to create action plans for maintaining or improving scores.
- Conduct a comprehensive internal audit at least annually and address any identified gaps in compliance. Internal audit findings should be reviewed at monthly and annual management review meetings. CAPAs should be assigned for findings, and data can be used to refine food safety objectives/goals.
Knowing and truly understanding the requirements of the SQF Code—or any of the Global Food Safety Initiative (GFSI) certification standards—is essential to avoiding non-conformances. Paying particular attention to the identified top non-conformances can help facilities to proactively mitigate these risks, strengthen food safety culture, and improve overall compliance.