How do I adjust to SQF Requirement 2.4.2.1?

Finishing a danger evaluation for a compliance exemption

I recurrently obtain ‘how-to’ questions from folks working within the meals business so the HACCP Mentor Ask Me! Sequence is all about offering solutions to your meals security, high quality and enterprise compliance questions. To kick off episode 1, I’m going to cowl the right way to full a danger evaluation associated to acquiring a compliance exemption. This can be a requirement of SQF Requirement 2.4.2.1.

JoAnn, who’s positioned in Chesterfield, Michigan is about to
begin her firm’s annual assessments. The bakery enterprise is licensed to SQF
and JoAnn has requested for enter into complying with SQF requirement 2.4.2.1.
Let’s firstly see what the usual requires earlier than I get into how a meals
enterprise can comply.

SQF Requirement 2.4.2.1

SQF Requirement 2.4.2.1 – The location shall make sure the Good Manufacturing Practices described in modules 3, 4, 9, 10 or 11 (as relevant) of this Meals Security Code are utilized, or exempted based on a written danger evaluation outlining the justification for exemption or proof of the effectiveness of other management measures to make sure that meals security isn’t compromised.

What does it truly imply?

The way in which the SQF code has
been written for these sections is that the clauses are primarily based on an business
sector. Nonetheless, not all manufacturing websites in a specific business
sector will undertake all the said GMP processes.

For instance, a enterprise
won’t have chilly storage, so, subsequently, they might not should adjust to
the necessities for chilly storage.

Sadly, the SQF reference to “utilized, or exempted based on a written danger evaluation” isn’t aligned to what we all know as being a “danger evaluation” as per ISO 31000. Due to this, the motion to take could also be complicated. Briefly, all it’s asking you to do is present due trigger and doc what’s related to your corporation and what’s not.

Find out how to adjust to 2.4.2.1

To fulfill compliance
with this clause:

1. Checklist all the clauses in a desk  
2. Decide what GMPs are relevant to your meals enterprise (primarily based on the necessities on your SQF Code Class). A easy Sure / No will suffice.
3. If you happen to reply ‘No’ to any of those, present the rationale or justification why the clause doesn’t apply.
4. If you happen to reply ‘Sure’ to any of those, and your meals enterprise desires to implement another management (from the one listed within the clause) you’ll need to state what that management is (protecting in thoughts the identification of the hazard that’s attempting to be managed). 

The designation of another management is the place it begins to get difficult and triggers the necessity for a real danger evaluation to be undertaken.

Implementing various
controls

To offer you an instance, Clause 3.6.5.2 states that “Processing utensils and packaging shall not be saved in areas used to retailer hazardous chemical compounds and poisonous substances”. To adjust to this, you wouldn’t retailer processing utensils and packaging the place hazardous chemical compounds and poisonous chemical compounds are saved. This is sensible to forestall chemical contamination of these utensils and packaging. 

Now possibly, by some
weird logic, you consider you possibly can higher management this potential for chemical
contamination through one other technique. Let’s say, your various management will
be to wash all processing utensils and packaging prior to make use of. The thought
course of being – if by likelihood the utensils did grow to be contaminated, it’s all
good, as a result of we’re going to clear it earlier than use anyway.

Finishing a danger
evaluation

You’d then have to
do a danger evaluation which incorporates:

• The hazard
• The reason for the hazard
• The chance of that hazard occurring
• The consequence of that hazard occurring (pre and publish management)
• The general danger of the hazard (primarily based in your chosen danger evaluation device)

You’d additionally have to validate that your various technique of management will truly work (to cease the potential for chemical contamination).

Proof for
implementation

As a part of the implementation course of for this management, your corporation would want to have documented procedures, verification checks (to help that the management has been applied) and workers coaching. Data and documentation must be obtainable to help your implementation.

Wrap As much as Ask Me!

Alright, hopefully, my clarification has helped to demystify your compliance duties for SQF Requirement 2.4.2.1. An enormous thanks to JoAnn for sending within the query and thanks for listening.

When you have a query to ask, simply as JoAnn did, all you must do is go to haccpmentor.com/askme and click on the Submit Query button. You possibly can depart your query there for me to evaluate and who is aware of, your query may very well be within the highlight in an upcoming episode of Ask Me!