SQF Certification for Food Packaging Plants

April 2014

Dr. Bob Strong - Senior Consultant - SAI Global (Americas)

 Our Presenter Today
Dr. Bob Strong
Senior Consultant SAI Global Assurance Services
Ph.D. and BSC in Chemistry and an accomplished food safety
trainer for numerous food safety manager certification courses
Driving force behind our food safety operations in the areas of
Good Manufacturing Practice (GMP), Good Agricultural Practice
(GAP) and supplier assurance programs, including SAFE, SQF and BRC
44 years of experience in the food industry, while working for national and
international companies in quality assurance, product development and
auditing. He is an oft-requested seminar speaker in the areas of GMP and
HACCP
In addition, he is a GMP/HACCP instructor, a Lead Auditor trainer, and is also
certified to consult on the Global Food Safety Initiative by SQF. Dr. Bob is
certified in 20 product categories.
Agenda
What is GFSI?
What is SQF?
Road to Certification for Packaging Plants
Mandatory requirements
Exemptions, when applicable
How to apply for a Variance
Module 2 requirements
Module 13 requirements
Scoring numerical and grade
Road map to Certification
Q&A
Global Food Safety Initiative
Global Food Safety Initiative (GFSI)
Started by CIES (The Food Business Forum) in Paris in 2000
Now called the Consumer Goods Forum (CGF)
400 members, 150 countries
Non-profit foundation
Focus is a simple set of rules for accepting different
standards, establishing harmony between countries &
auditing efficiency by:
benchmarking food safety standards worldwide
facilitating cooperation between standard owners
assurance of quality of certification & accreditation
Global Food Safety Initiative (GFSI )
The GFSI guidance document sets the minimum
requirements for:
Food Safety Management Systems
GMPs, GAPs, GDPs
HACCP
Delivery of Food Safety Management Systems
All standards to get approved must meet these minimum
requirements in the GFSI guidance document
Standards owners can go above and beyond the
requirements to add value
 GFSI Vision
Initially was Once certified, Accepted Everywhere
Is now Safe Food for Consumers Everywhere

Mission: Driving continuous improvement in food safety to

strengthen consumer confidence worldwide

Reduce food safety

Manage cost
risks

GFSI

Develop competencies Knowledge exchange

and capacity building and networking
Initial Companies Involved with GFSI in 2000
Albertsons Migros
Campbells Royal Ahold
Carrefour Sara Lee
Danone Tesco (Fresh and Easy)
Delhaize (Food Lion, Tyson
Hannaford) Wakefern
Hormel Wal-Mart
Kroger
Metro AG
 Governance: GFSI Board of Directors
Chair Vice-Chairs

Board Members

Nestle

Providing strategic direction and supervision of GFSI, and

governance to the GFSI Technical Working Groups
Convergence Means Confidence
Benchmarking work was originally carried out in 2000 on four
food safety schemes (BRC, IFS, Dutch HACCP and SQF) to
reach a point of convergence.

All of the 9 currently approved schemes are completely

aligned with the GFSI Guidance Document Version 6
Requirements issued in 2011.

GFSI Guidelines will be reviewed again in 2014 for possible

updating
GFSI Benchmarked and approved schemes
SQF Code Edition 7.2
About SQF (Safe Quality Food)
Originated as an Australian standard in 1994
Purchased by FMI in 2004 and is now operated by the Safe Quality
Food Institute in the United States
One of the first 4 Schemes approved by GFSI in 2004
3 Certification Levels
Only Scheme offering a Quality Level over and above Food Safety
Current Edition is 7.1 and is available for free from www.sqfi.com
Edition 7.2 will be effective on July 3rd 2014
SQF Levels of Certification

Level 3

Level 2

Level 1
3 Levels of Certification
Level 1
Food Safety Fundamentals (Pre-requisite programs) +
Building and Equipment

Level 2
Adds in the Food Safety Plans (HACCP)
Element 2.4.3 (GFSI Approval level)

Level 3
Adds in the Food Quality Plans
Element 2.4.4 (Above GFSI approval requirement)
SQF Initial Certification Audits
Initial Certification Process requires two separate audits:
Desk/Document audit (Readiness audit)
Facility Audit

Recertification annual audits only require 1 audit which is a

combination of both.

SQF has products and services divided into 35 Food Safety

Categories (FSC) of which Category 27 is Manufacture of Food
Sector Packaging Materials.
SQF Initial Certification Audits
Desk/document audit is a review of all your documented
programs, policies and procedures as required by the SQF Code
for manufacturers of food packaging materials.

Hence this is a review of what you say you do.

This can be done on site or at a mutually agreeable location and

is a non-graded evaluation. All deficiencies in the documentation
identified in this review have to be corrected before the auditor
can return to conduct your facility audit.

In future years there is no separate document review.

SQF Initial Certification Audits
Facility audit is an audit of your total facility as to compliance with
these documented programs, policies and procedures.

The auditor looks at your equipment, building, processes, records,

etc. and this is a graded evaluation.

Hence this is to see if you do what you say and can prove it.

All deficiencies in this audit cause you to lose points and require
that they all be corrected before the Certifying Body can issue you
your SQF Certificate.
Requires an SQF Practitioner
Employed by the Supplier
In a full-time at the facility being certified
In a position to manage the program

HACCP Knowledge
Have completed a HACCP Course
Be competent to implement & manage HACCP plans

SQF Code Knowledge

Be competent to implement & manage SQF Programs
Taking Implementing SQF Systems Course (highly recommended)
Taking and passing the Implementing SQF Systems on-line exam
(highly recommended)
SQF Code requires that you
Say what you do in writing

Do what you say

Have the records to prove it

SQF Code requires
You meet the regulatory requirements of the Country in which
you operate as well as to those of each country that you sell
your product to.

That you meet your Customer requirements.

That you comply with the current edition of the SQF Code.

That you practice Continuous Improvement.

SQF Code requires that
packaging manufacturers
Comply with the requirements of the following SQF Modules:

Module 2: SQF System Elements

Module 13: Pre-requisite programs for the manufacturing
of Food sector packaging
Mandatory Elements
These are SQF sub-elements that are required to be
documented and implemented by everybody.

Cannot be excluded by the facility applying for certification

Cannot be exempted by the Certifying Body
Cannot be marked non-applicable (NA) by the auditor

Applies to Module 2 only

Mandatory Elements (20)
2.1.1 Management Policy
2.1.2 Management Responsibility
2.1.3 Food Safety and Quality Management System
2.1.4 Management Review
2.2.1 Document Control
2.2.2 Records
2.4.1 Food Legislation
2.4.2 -- Food Safety Fundamentals
2.4.3 Food Safety Plan (levels 2, 3)
2.4.4 Food Quality Plan (level 3 only)
Mandatory Elements (20)
2.4.8 Product Release
2.5.2 Validation and Effectiveness
2.5.4 Verification and Monitoring
2.5.5 Corrective and Preventative Action
2.5.7 Internal Audit
2.6.1 Product Identification
2.6.2 Product Trace
2.6.3 Product Withdrawal and Recall
2.7.1 Food Defense
2.9.2 Training Program
SQF Code possible exemptions
Certain sub-elements in these Modules however may not be
applicable to you and so they will not apply

If you only go SQF Level 2 then the following sub-elements do not

apply and the SQF auditor will not expect you to provide any
evidence (programs or records) for these sub-elements.

These sub-elements will apply if you apply for certification at Level 3:

2.4.4. Food Quality Plan
2.8.1. Identity Preserved Foods
SQF Code possible exemptions
Certain sub-elements in these Modules may not be applicable and
if so then they will also not apply.

The following sub-elements may not apply to your facility and the
auditor will agree if you provide evidence that they do not.

2.3.4. Contract Manufacturer program

2.4.7. Rework program
2.8.2. Allergen Management program
13.5.4. Air Supply
13.6.4. Alternate Storage
The SQF Code

SQF System Elements

Module 2
Terms Used in Module 2

Food also means feed, pet food,

or
food contact packaging materials.
Module 2 Elements Overview
2.1 Management Commitment
2.2 - Document Control and Records
2.3 Specification and Product Development
2.4 Attaining Food Packaging Safety
2.5 SQF System Verification
2.6 Product Identification, Trace, Withdrawal and Recall
2.7 Site Security
2.8 Identity Preserved Foods
2.9 Training
Module 2 defines management-level
commitments including
Statement of managements commitment to provide safe, quality
food packaging
Designation of an SQF practitioner
Creation and documentation of organizations food safety plans
(Level 2) and quality plans (Level 3)
Addressing non-conforming products and equipment
Module 2 defines management-level
commitments including
Development and execution of an internal audit process.

Documentation and implementation of a food defense program.

Creation of systems to address food allergens, if applicable.

Execution of an effective and appropriate training program.

2.1 Management Commitment - Overview

Each Module 2 element contains

sub-elements
2.1.1 Management Policy (M)
2.1.2 Management Responsibility (M)
2.1.3 Food Safety and Quality Management System (M)
2.1.4 Management Review (M)
2.1.5 Complaint Management
2.1.6 Business Continuity Planning
2.1 Management Commitment (M)
Success of your SQF System is contingent upon:

A signed commitment by Senior Management at your facility to:

Implement and maintain an effective SQF System
Support ongoing improvement
Provide adequate resources
2.1.6 Business Continuity Management
Documented program that:

Defines the handling of a potential business crisis that may

impact ability to deliver safe, quality food packaging
Prepared by senior management
Defining methods and responsibility
Risk assessment of each type of crisis
Crisis management team (a top nonconformity)
2.1.6 Business Continuity Management
Includes controls implemented so product safety and quality not
compromised
Includes isolation and identification of affected product
Verification of product prior to release
Crisis alert contact list
Sources of legal and expert advice
Internal and external communications
Annual review testing + verification (One of top nonconformities)
Records
Product withdrawal and recall
2.2.1 Document Control Registers
to be Maintained
2.2.1.1 SQF System Documents and Amendments

2.3.2.6 Raw and Packaging Materials Specifications and Labels

2.3.3.2 Contract Service Providers and Specifications

2.3.5.2 Finished Product Specifications

2.2.1 Document Control - Registers
to be Maintained
2.4.5.5 Approved Suppliers and Records of Inspections and Audits
of Suppliers

2.8.2.1 Allergens (if applicable)

2.9.7.1 Training Skills Register

3.2.9.3 Pesticides/Pest Control Chemicals

13.7.1.3 Glass Register

2.4.3 Food Safety Plan (M)
Outlines how facility will control and assure food safety:

Prepared using a HACCP-based method

Cover product and associated processes

Describe the methodology and results of a hazard analysis

4th highest nonconformity is a poor hazard analysis

2.5 SQF System Verification
2.5.1 Responsibility, Frequency and Methods
2.5.2 Validation and Effectiveness (M)
2.5.3 Verification Schedule
2.5.4 Verification of Monitoring Activities (M)
2.5.5 Corrective and Preventative Action (M)
2.5.6 Product Sampling, Inspection and Analysis
2.5.7 Internal Audits (M)
2.5.2 Validation and Effectiveness (M)
Document and implement methods, responsibility and criteria for
ensuring the effectiveness of the pre-requisite programs (PRPs) and
validating any critical food safety (CCPs) and critical quality limits
(CQPs).

Confirm they achieve required results

Critical limits are selected to achieve designated level of control
of identified hazard or threat

Failure to document how you determined your PRPs are effective is

the 10th biggest nonconformity.
2.5.7 Internal Audits (M)
Document and implement methods for scheduling, conducting
internal audits (incl. factory and equipment inspections) (One of
largest nonconformities)

Internal audit schedule

Action taken to correct deficiencies found
Maintenance of records
Results communicated to relevant staff
Staff conducting internal audits trained in internal audit
procedures
Staff independent of the function being audited, where possible
SQF Code Module 13
Good Manufacturing Practices for Production of Food
Packaging Materials

Based on Edition 7.2 effective 7/3/14

Module 13 Elements
13.1 Site Requirements and Approval
13.2 Construction and Control of Product Handling and Storage
Areas
13.3 Personnel Hygiene and Welfare
13.4 Personnel Processing Practices
13.5 Water and Air Supply
13.6 Storage and Transport
13.7 Control of Foreign Matter Contamination
13.8 Waste Disposal
13.9 Exterior
All items in Section 13 are Shalls
Exclusions to these requirements or alternate methods of control are
permitted, however they need to be supported by a detailed risk
analysis outlining the basis for any exclusion and demonstrating food
packaging safety is not compromised.

The risk assessment must contain:

A description of the element of the standard and the hazards
which need to be addressed.
The control protocol which the facility will implement to ensure
the identified hazards are controlled.
Validation that the protocols are properly implemented and
effective.
Not all Module 13 sub-elements need
documenting
13.1.1 Premises Location
13.1.2 Construction and Operational Approval
13.2.1 Materials and Surfaces
13.2.2 Floors, Drains and Waste traps
13.2.3 Walls, Partitions, Doors and Ceilings
13.2.4 Lighting and Light Fittings
13.2.5 Dust, Fly and Vermin Proofing
13.2.6 Ventilation
13.2.10 Equipment, Utensils and Protective Clothing
Not all Module 13 sub-elements need
documenting
13.3.2 Hand Washing facilities
13.3.3 Clothing provided (if applicable)
13.3.6 Staff Amenities
13.3.7 Change rooms/Locker rooms (if applicable)
13.3.8 Sanitary Facilities
13.3.9 Lunch Rooms
13.3.10 First Aid
13.6.1 Storage Conditions for packaging materials and products
13.6.2 Storage Conditions for equipment
13.9 Exterior
Following programs do need documenting
13.2.7. Premises and Equipment
Maintenance
Document plan showing methods and responsibility
Minimize risk of product contamination
Needs to include maintenance and repair of warehouse, equipment and buildings
Routine maintenance in accordance with Maintenance schedule
Document, review, incorporate into maintenance control schedule all equipment
failures
Follow personnel hygiene and welfare (see13.3)
Remove all tools, debris once maintenance completed
Inform the area Supervisor so appropriate hygiene and sanitation can be
completed
Need to document annually how you determine your maintenance program is
effective
13.2.8. Calibration
Document and implement showing methods and responsibility for
calibration and re-calibration of measuring equipment used for any
monitoring activities (Calipers, etc.).

Document and implement procedures to address the disposition of

potentially affected product if equipment is found to be out of
calibration.

Protect equipment from damage and unauthorized Adjustment.

Need to document annually how you determine your calibration

program is effective.
13.2.9. Management of Pests and
Vermin
Document and implement showing methods and responsibility
for integrated pest management.

Premises, surrounds, ancillary storage areas, machinery and

equipment kept free of waste or accumulated debris so as not
to attract pests and vermin.

Need to document annually how you determine your pest

control program is effective.
13.2.11. Cleaning and Sanitation
Document and implement methods and responsibility for cleaning food
packaging processing equipment and food packaging storage areas,
transport equipment and staff amenities and toilet facilities.
Consider:
What is to be cleaned
How it is to be cleaned
When it is to be cleaned
Who is responsible for the cleaning
Responsibility and methods for verification of
effectiveness
Need to document annually how you determine your sanitation
program is effective.
13.3. Personnel Hygiene and Welfare
13.3.1 Personnels health

13.3.4 Jewelry and Personal Effects

13.3.5 Visitors
13.3.1 Personnel
Personal health
Do not handle product if suffering from or being a carrier of
infectious diseases
Note health questionnaire, screening
Cuts and lesions
Do not handle product or food contact packaging materials if
exposed cuts, sores or lesions are present
Cover minor cuts, abrasions with suitable waterproof colored
bandage or bandaid
Personal practices
No smoking, chewing, eating, drinking or spitting in
any food packaging handling or storage areas
Drinking on the processing floor variance.
As the SQF Code prohibits any drinking on the processing floor
as product is exposed you are going to have to apply for a
variance from the Certifying Body prior to your facility audit if you
allow drinking or you will receive a non-conformity.
Variances can only be granted by Certifying Bodies not by
auditors.
Variance request has to be in writing and the Certifying Body has
the right to grant or deny the variance.
Cannot be appealed to SQFI as the SQF Code does not permit
drinking where product is exposed.
13.5.4. Air Quality
Compressed air used in the food packaging operations shall be:

Clean and present no risk to food packaging safety.

Regularly monitored for environmental contaminants.
Test annually for Aerobic Plate Count and Molds and
Yeasts
13.6 Storage and Transport
13.6.1 Storage of Food Packaging
13.6.2 Storage of Equipment
13.6.3 Storage of Hazardous Chemicals and Toxic Substances
13.6.4 Alternative Storage and Handling of Goods
13.6.5 Loading, Transport and Unloading Practices
13.6.6 Loading/Unloading
13.6.4. Alternative Storage and
Handling of Goods
Where goods described in 13.6.1 to 13.6.3 are held under
temporary or overflow conditions that are not designed for the safe
storage of goods, a risk analysis shall be undertaken to ensure
there is no risk to the integrity of those goods or contamination or
adverse affect on food packaging safety and quality.
13.7.2. Control of Foreign Matter
Contamination.
Glass register list glass objects or similar material in food
packaging processing areas showing location.
Containers, equipment, utensils made of glass, porcelain, ceramics,
testing glassware or like material (except where packaging product
packaged is glass/like materials, instruments with glass dial covers,
thermometers).
Regular inspections of processing areas, affirm condition of items in
glass registry.
Inspect glass instrument dial covers, MIG thermometers at start and
finish of each shift in processing areas if they cannot be eliminated or
protected to confirm they have not been damaged.
NON-CONFORMITIES
SCORING
GRADING
Minor Nonconformity
A Minor Nonconformity shall be corrected, verified and closed
out within thirty (30) calendar days of the completion of the
Facility Audit

Extensions may be granted by the Certification Body where

there is no immediate threat to product safety and quality, and
alternative, temporary methods of control are initiated
Major Nonconformity
A Major Nonconformity shall be corrected and appropriate
Corrective Action verified and closed out within fourteen (14)
calendar days of the completion of the Facility Audit
Critical Nonconformity
A Critical Nonconformity raised at a Certification Audit results
in an automatic failure of the audit & the Supplier must reapply
for certification

The Auditor shall immediately advise the Supplier and Notify

the Certification Body

(If re-application occurs within 6 months and with the same

CB, no desk audit is required)
SQF Non-conformances
These non-conformances can occur during the Desk
(Document) audit or during the Facility (Site) audit. ONLY
FACILITY AUDIT IS SCORED.
Scoring effect of facility non-conformances on the possible
score of 100.
Critical (Minus 50 points)
Major (Minus 10 points)
Minor (Minus 1 point)
All non-conformances should be corrected before an SQF
Certificate will be issued however if all minor nonconformities
have not been corrected a certificate can still be issued within 45
days of last day of facility audit.
Audit Score
Score Rating Certification Audit
Frequency
96 - 100 E Excellent Certificate issued 12 monthly
re-certification
audit.

86 - 95 G Good Certificate issued 12 monthly

re-certification
audit.
70 - 85 C Complies Certificate issued 6 monthly
surveillance audit
required.
0 - 69 F Fails to No certificate Considered to
comply issued have failed the
SQF Audit.
The SQF Certification Process
Select a Identify the
Select an
Certification Scope of
Body Certification Auditor

Identify the
Scope of the Desk Audit Facility Audit
Audit

Maintenance
The Audit Granting
of
Report Certification Certification
SQF Annual Meeting 2014
Renaissance Hotel
Sea World
Orlando
Oct 28-30th, 2014

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Dr. Bob Strong

Senior Consultant
513-349-5398
Bob.Strong@saiglobal.com

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