Objectives

• Focus attention on the influences that human error and poor organization have on accidents.
• Continuous improvement in the offshore industry’s safety and environmental records.
• Encourage the use of performance-based operating practices.
• Collaborate with the industry in efforts that promote the public interests of offshore worker safety and environmental protection.

History

La Safety and Environmental Management Program (SEMP) was developed in 1993 as a voluntary adherence to the offshore oil and gas industry. The Minerals Management Service (MMS) was the first entity responsible for regulation, but eventually, the Bureau of Ocean Energy Management Regulation and Enforcement (BOEMRE) took its place. Later, the agency split into three different ones: Office of Natural Resources Revenue (ONRR), Bureau of Ocean Energy Management (BOEM), and Bureau of Safety and Environmental Enforcement (BSEE).

In April 2010, the Deepwater Horizon disaster caused a massive oil spill devastating ocean life and the economy of many coastal communities in Florida, Texas, and Louisiana.

This event prompted the COS to adopt and revise the SEMS program as we know it now, which applies to oil, gas, and sulfur operators on the outer continental shelf.

The SEMS Program

The Center for Offshore Safety (COS) incorporates the American Petroleum Institute’s Recommended Practice 75 (API RP 75) and 30 CFR Part 250, Subpart S, for developing a Safety and Environmental Management System for Offshore Operations and Facilities, including a complete SEMS program. Its principal intent is to hold operators accountable for the safety of the offshore facility, assuring that all contractors and subcontractors have safety policies and procedures in place.

The operators must implement a program that “identifies, addresses and manages safety, environmental hazards, and impacts during design, construction, startup, operation, inspection and maintenance of all new and existing facilities.” There are also elements intended to prevent significant scale events like fires, explosions, and spills that could affect the platform’s safety or the environment.

Elements

• General: Designation of responsibilities, overall training and expertise, and requirement of all written SEMS policies, practices, and procedures.

• Safety and environmental information: Requirements for a written report describing the facility’s design, construction, and operation.

• Hazards analysis: Implementation of a hazard analysis (facility-level) and a job-safety one (operations level) to ensure that all recommendations are resolved and documented.

• Management of change: Development and implementation of written management of change procedures associated with equipment, operating procedures, personnel changes, contractors, materials, and operating conditions. These must include a technical basis for the change and its impact on safety, health, and the environment.

• Operating procedures: Developing and implementing written operating procedures that provide instructions for conducting safe and environmentally sound activities related to initial startup, routine and emergency operations, startup following a turnaround, an emergency shutdown, and bypassing and flagging out-of-service equipment. Operators also require to discuss the safety and environmental consequences of deviating from regular procedures and the hazards presented by the chemicals used in the operations.

• Safe work practices: General requirements for safe work practices, minimization of risks associated with operations, and handling of materials and substances that could affect the environment.

• Cursos: Requirements for a training program, so all personnel receives training according to their duties and aware of potential environmental risks. This training must address operating procedures, safe work practices, emergency responses, reporting of unsafe work conditions, and hazard identification.

• Assurance of quality and mechanical integrity of critical equipment: Applies to all facility equipment and systems that prevent or mitigate uncontrolled releases of hydrocarbon, toxic materials, or others that can have safety or environmental impacts. This part includes provisions for written procedures, training or maintenance personnel, deficiency management, and quality assurance for the design, fabrication, installation, and spare parts for OCS facility equipment.

• Pre-startup review: Environmental review for new and modified facilities. The process must ensure that the construction and equipment comply with specifications and that safety, environmental, operating, maintenance, and emergency procedures are in place.

See also: What you need to know about the SASISOPA certification audit

• Emergency response and control: Implementation of emergency response and control plans. These must include requirements for drilling and evacuation procedures.

• Investigation of incidents: Procedures for investigating incidents that had safety and environmental consequences. The study must determine the nature of the event, the factors that caused its initiation and escalation, and recommend system changes. Near misses are also a reason for starting an investigation.

• Audit: All operators must undergo an independent audit within two years of the initial implementation of the SEMS program and every three years afterward. The operator submits the plan to the BSEE 30 days before the audit; the bureau reserves the right to modify the list of facilities that the operator proposes. The evaluation is performed on 15% of the operator’s platforms. The operators must submit an audit report and a plan for addressing the deficiencies for review within 60 days after the audit.

• Recordkeeping: Operators must ensure that all documents are kept for six years; individual records must be maintained only for two years. These must be ready upon request by the BSEE.

• Stop-work authority: Operators must ensure that they can stop or decline to perform a process that represents an imminent risk to all personnel.

• Ultimate work authority: Operators must have a process that identifies the individual with the final authority at the facility and over the operation. Personnel needs to know who is in charge of a specific operation at all times. This person also needs to have the authority given by the operators to take whatever action is required to mitigate and abate the conditions causing an emergency.

• Employee participation plan: Management must consult with its employees on the development, implementation, and modification of the SEMS program and develop a written plan for how they will participate. Employees must also have access to sections of the SEMS program that are relevant to their Jobs.

• Reporting unsafe work conditions: Operators must implement procedures for all personnel to report dangerous work conditions. The information then must be placed in a visible location.

What happens before, during, and after a SEMS certification audit?

The BSEE is the entity in charge of evaluating the operator’s compliance with the SEMS standard; in other words, protecting worker safety and the environment.

If the inspector finds any violation during a SEMS certification audit, the BSEE can issue an “incident-of-noncompliance”, impose monetary penalties, or rescind the operator’s lease.

Depending on the violation, the BSEE can issue a “warning or shut-in INC” during a SEMS certification audit:

• Warning INC: Violation is not severe. The operator will have to correct it as soon as possible (14 days usually).
• Shut-In INC: Violation is severe and poses a danger to employees and the environment. The suspension of operations will be in the nation’s interest. The breach must be corrected to continue operations.

Penalties can go up to 40,000 USD per day if the violation is not corrected within the specified time, or if it’s a serious threat to employees and the environment.

The operator has 30 days to request a meeting with a reviewing officer, submit information, or pay the fine. Then, the officer will decide if there’s a need for a final penalty. Meanwhile, the BSEE can start disqualification procedures against the offshore operator. If the threat is still there or a dangerous activity has not stopped, the lease or permit could be canceled.

Finally, the BSEE may involve the Department of Justice if there are signs of negligence.

The operator has the right to initiate an appeal process and request a hearing.

Finding the right company to ensure that you meet your SEMS certification audit goals and BSEE’s expectations can be tricky. Still, CICS Americas approach lets you identify risk areas and improve your system for the protection of your employees and the environment.

Source: BSEE

EnVen Energy Corporation, an offshore energy developer, has been awarded a Safety and Environmental Management Systems (SEMS) certificate from the Center for Offshore Safety (COS), showing their dedication to the highest standards for environmental conservation and safety.

“EnVen really went above and beyond the regulatory requirements to demonstrate responsible operations in the Gulf of Mexico. COS and the industry celebrate their commitment and achievement in effectively implementing SEMS and having their corrective action plan verified by an independent third party.”

COS Director, Russell Holmes

The certificate was signed and presented to EnVen during an annual Safe Operations Workshop, in which many of the company’s management and offshore workforce were in attendance.

“I’m proud to accept this SEMS certificate on behalf of EnVen’s offshore workforce who work every day to produce energy safely and responsibly.”

EnVen’s Health, Safety and Environmental Manager, John C. Poole.

EnVen has earned a COS SEMS certificate, joining the other 19 businesses that operate on the U.S. Outer Continental Shelf. While the Bureau of Safety and Environmental Enforcement (BSEE) mandates that offshore operators have a SEMS based on API Recommended Practice 75 and have it audited, a COS-accredited Audit Service Provider must certify that all corrective actions have been taken before a COS SEMS certificate can be obtained.

CICS Americas, the ASP that conducted the audit and confirmed the completion of corrective actions, is one of only five companies accredited by COS to conduct SEMS audits and the only one that is accredited both in the U.S. and Mexico to conduct SEMS and SASISOPA audits.

“EnVen has provided a fantastic model for other operators to follow.”

CICS CEO, Kurt Teuscher

Through leadership, efficient SEMS implementation, and gathering safety and incident data to support the continuous improvement of SEMS, the American Petroleum Institute’s COS has been promoting continuous safety improvement for offshore exploration and production for more than ten years.

The work of COS is based on API RP 75, Safety and Environmental Management System for Offshore Operations and Assets, which offers instructions for setting up, putting into place, sustaining, and continuously enhancing SEMS for offshore natural gas and oil operations.

CICS Americas congratulates EnVen on this outstanding achievement!

For more information about the SEMS Certification and how your company can achieve it, contact us and start your journey toward operational excellence!

Source: COS News

What is the SQF Program?

The Safe Quality Food (SQF) Program is a food safety and quality plan recognized by retailers and foodservice providers worldwide. SQF codes are designed to meet industry, customer, and regulatory requirements for all the food supply chain sectors.

The SQF standard, first developed in Australia in 1994, has been owned and managed by the Food Marketing Institute (FMI) since 2003. The program arrived in the U.S. in 2005. Under pressure from the FMI, retailers all over the country began adopting it in 2007.

Rigorous farm-to-fork safety and quality certification allow producers to ensure their customers that their food products meet the highest possible standards.

The SQF Program guides companies by setting up a comprehensive food safety management system on their farms, warehouses, or facilities by assessing their processes through an annual audit. Passing it results in the SQF certification.

Considerations

The SQF Program has three variants that businesses can choose from depending on their needs:

• SQF Food Safety Fundamentals Program: For small and developing businesses that don’t have a robust food safety management program in place or want to take their existing program to the next level. 
  
  
• SQF Food Safety Program: For sites looking to get a GFSI-benchmarked certification. The SQF Food Safety Program provides sites with a HACCP (Hazard Analysis and Critical Control Points) based approach to ensure their products meet regulations.
  
  
• SQF Food Safety and Quality Program: For companies that have been SQF certified and would like to improve beyond what they have already mastered. 

What’s next? The steps towards the SQF certification audit

1. Choose an employee as the SQF leader: This person needs to receive HACCP training and be competent enough to implement the SQF system requirements and food safety plan.
   
   
2. Document and implement according to the SQF code: To achieve the SQF certification, you must document and implement the system elements and relevant GMP (Good Manufacturing Practices) modules of the SQF code.
   
   
3. Document: Policies, procedures, work instructions, and specifications that meet the system elements and GMP modules of the SQF code.
   
   
4. Implement: Execute all of the above and keep records to demonstrate compliance with the relevant modules of the SQF code.
   
   
5. Choose a certification body: Contact CICS Americas, complete the questionnaire, and return it for a formal proposal. Then, an experienced SQF registered auditor performs the evaluation.
   
   
6. Conduct a pre-audit (optional): This step will allow you to identify all the gaps between your program and the SQF code; in other words, procedures, documentation, and practices that do not satisfy the standard.
   
   
7. Schedule your audit.

The SQF certification audit begins

The SQF certification assessment consists of two steps:

1. Documental audit: Carried out to assess and confirm that the Management System documentation meets all the SQF code requirements. This step can be conducted offsite.
   
   
2. Site audit: carried out to evaluate and verify the effective implementation and maintenance of the Management System.

See also: SQFI Certificate Extension Policy and risk assessments: what you need to know

What happens before, during, and after evaluation day?

• Before: Your assigned auditor sends the audit plan one week before the scheduled visit for your desk audit.
  
  
• During: The auditor tours the site, reviews documents, gathers evidence, has team meetings, and provides the non-conformities (if applicable). The following elements will be evaluated (other items can be considered depending on the type of business):
  • Management commitment.
  • Document control and records.
  • Specification and product development procedures.
  • Food safety system.
  • SQF system verification.
  • Product identification, trace, withdrawal, and recall procedures.
  • Food defense and fraud procedures.
  • Allergen management.
  • Training.
    
    
• After. The report is submitted for technical review and also delivered to you. Then, the Corrective Audit Report is handed. This document contains all the corrective actions required for compliance with the SQF code. Before the 30-day deadline, the auditor approves the corrective actions. Finally, Certificate Decision reviews the documentation. If you achieve a “C-Complies” or higher, you will obtain the SQF certification.

What are non-conformities?

In the SQF certification audit, a non-conformity is any irregularity found in the system that needs to be addressed to comply with the SQF code. The auditor shall advise the business of the quantity, description, and extent of the non-conformities, which can be graded as minor, major, and critical.

The more critical the non-conformity, the sooner it needs to be addressed.

How long will the evaluation take?

La duration depends on the size and complexity of the plant site. 

Basic duration:

• Step 1: one day.
• Step 2: two days.

Scores and rating

A scale of 0 to 100 determines the evaluation score—every non-conformity results in point loss.

Audit Score

A “Fails to Comply” rating indicates that you cannot receive the certification and need to reapply for a new evaluation. SQF certification is valid for one year.

Obtaining an SQF certification means you care about your customers and your food products’ quality and safety.

Source: SQF Institute

Objective

Systematize, coordinate, and secure the procedures and tools that allow the prevention of incidents, creating a better document control, better internal methods, and greater coordination in audits, as well as environmental protection with a prevention approach and operational safety control.

History

After the 2013 Energy Reform in Mexico, regulatory entities restructured to implement the changes within all activities related to the energy industry, such as the offshore operations in shallow or deep waters.

ASEA (Agency for Safety, Energy, and Environment) is one of the institutions that underwent notable modifications. Since the reform, the agency developed a risk management and prevention system to protect people, facilities, and the environment called SASISOPA. All participants in the sector must comply with the regulation.

In August 2014, the government enacted the Agency for Safety, Energy, and Environment of the Hydrocarbons Sector Law, regulating and supervising:

• Industrial and operational safety.
• Dismantling and abandonment of installations.
• Waste and emissions control.

Elements

1. Industrial and operational safety and protection of the environment.
2. Assessment of the physical and operational integrity of the facilities.
3. Risk analysis, preventive measures, incident mitigation, and identification of possible consequences to the population, environment, and facilities.
4. Industrial and operational safety and protection of the environment best practices implementation.
5. Objectives, goals, and metrics to measure performance.
6. Assignment of roles and responsibilities to implement the management system.
7. Training plan.
8. Activity and process control.
9. Internal and external communication mechanisms.
10. Document control.
11. Safety provisions for contractors.
12. Accident prevention and emergency response.
13. Procedures to register, investigate, and analyze incidents and accidents.
14. Monitoring, verification, and assessment of the performance management system.
15. Procedures for internal and external auditing.
16. Legal requirements.
17. Verification results review.
18. Performance report.

General aspects

The SASISOPA implementation must be tailor-made based on the operating condition of the organization.

The process applies to all life cycle of the project: design, construction, operation, shutdown, dismantling, and abandonments.

These are the two key concepts regarding the administrative dispositions of SASISOPA:

• Conformation: a set of documents of the management system per each of the 18 elements that integrate SASISOPA.
• Implementation: gradual start of the operations following the management system, and the deadline described in the program.

Before starting with the development of SASISOPA, it’s essential to define the areas and people responsible for the conformation, implementation, assessment, and improvement of the management system, who will become the technical representatives before ASEA’s eyes.

See also: 7 ways audits create value for your organization

Types

• Industrial: applied to activities in the hydrocarbons sector that go from survey and exploration to storage.
• Commercial: applied to activities related to the sale to the public of natural gas, and distribution and sale of the public of liquefied petroleum gas and petroleum products.

An organization can define the SASISOPA type that needs by determining it’s processes map, knowing the permit granted by the Energy Regulation Commission (CRE for its Spanish acronym), and the stages of the hydrocarbon sector value chain.

The SASISOPA certification audit

ASEA has a list of companies, known as authorized third parties, in charge of the following activities for the operator:

• External auditing.
• Correspondance with SASISOPA report.
• Assessment report of the implementation program.
• Root cause investigation of accidents and incidents.

Regarding the audit’s duration, the operator needs to consider the following:

• Assessment and hiring of the third-party.
• Conformation of SASISOPA and the implementation program.
• Delivery of the report.
• ASEA’s response to obtain SASISOPA’s authorization.
• System implementation.
• Performance evaluation of the system.

An industrial SASISOPA certification audit audit is shaped by:

• Audit plan.
• Verification certificate.
• Verification list.
• Audit report.
• Action plan based on the findings.

For distribution activities, operators need a report issued by the authorized third-party, which must include the pertinent documentation, the technical evaluation of the implementation applied to the project in question, and the correspondence report.

The SASISOPA certification audit helps you protect your personnel, facility, and the environment but also allows you to comply with the regulation and make your business grow.

Source: Gobierno de México

Certification: mere compliance or opportunity for improvement?

If you are a manager or business owner, ask yourself these simple questions: do the systems implemented in my plant site work? Is there a system in place? As a customer, you expect that the bread or chips that you’ll buy meet certain expectations. You already know how they taste and that they are safe to consume just because they are on the supermarket shelf. You take for granted that there wouldn’t be any problem with your product. Why? Because the bread or chips comply with food quality and safety regulations, and certification proves it.

Despite all this, the evaluation to obtain the certification couldn’t eliminate the “obstacle” label for another reason: the auditor. This professional is required not only to evaluate your company’s system but also to contribute to it by pointing risk areas. A bad experience may have to increase your reservations about an audit. More problems instead of a solution!

But times have changed, and the human factor has developed the auditor and the process that he oversees into a valuable temporary asset for any company. An auditor gets the whole picture of the business and its operations by interacting with every level in the company’s hierarchy. He may identify if there’s any lack of commitment about the need for change.

So, in what ways audits create value for your organization? Let’s find out:

Leverage

We are talking about a gateway to a whole new level of possibilities. What if your products could be available everywhere? For example, an SQF certification will let you distribute your product to supermarket chains like Walmart. Your brand will become popular in the industry, and you’ll be able to promote it everywhere you wish. Maybe, when your local competitors found that the certification made the difference, you’ll already be two steps ahead.

No risk of running out of raw material

A certification evaluation will let you improve many aspects of your system, like inventory control. What if you are a victim of unplanned downtime because a key material ran out and nobody noticed it? This omission could cost thousands of dollars to any company. An audit precisely prevents things like this from happening. With an effective system in place, the plant will not have to take emergency measures to address this kind of situation.

Avoidance of legal problems

You might be surprised to know that many businesses are not aware of all the regulations that govern their industry. An audit can avoid a huge fine or even a temporary closure of your company by pointing the compliance error or omissions within your system. After the evaluation, the certification will demonstrate that your organization is law-abiding.

See also: The benefits of a pre-audit during a certification process

New insights

An auditor brings some skills that can be very valuable to any company. His analysis may indicate a problem you even didn’t know about, and not a trivial one, but one with the potential of ruining everything you have built for years. His findings aren’t a way to discredit your operation but a chance to make things better and make crucial decisions. The best evaluation is in which the auditor is considered a partner instead of an enemy.

Business growth

By developing your management practices, allowing you to take advantage of every opportunity, and mitigating risks, an audit will prove vital for your business. When you understand how your system should work, and machinery doesn’t fail as often as before, the whole operation will eventually begin to grow, overcoming some of the previously mentioned obstacles. This point is one of the essential ways audits create value for your organization.

Reputation care

The so feared recalls can destroy your business. Your public image may never recover from a blow like this, and what’s worse, you may have to pay a massive fine for your lack of compliance.  An exhaustive evaluation of your system can prevent the mistakes that result in awful accidents. A certification audit will ensure a minimal chance of your business appearing in the news for all the wrong reasons.

A new culture around compliance

When you approach the third party for auditing, you must choose if your business should undergo the evaluation every six or twelve months. The former may have an unexpected benefit: the creation of a culture of compliance. The frequent assessments will make personnel work evenly and as expected all year long. Eventually, this dynamic will permeate the company’s DNA, and compliance will now be natural.

The global economic landscape has changed rapidly over the last years, as well as the audits. More and more CEOs and managers have realized that this kind of evaluation drives not just innovation but also the possibility of tearing down walls in terms of international commerce. Finally, and most important, an audit brings you the chance to take care of your clients and preserve their trust. These are the ways audits create value for your organization.

References: Corporate Compliance Insights
LDB

You may have to meet a deadline with your client, but that business relationship will only flourish if you are SQF certified. The urgency of getting evaluated can be overwhelming. Still, you have to bear in mind something: the duration of the audit is one thing, but the preparation for it is another entirely different. But this article is about the length of an SQF audit, so we’ll leave the preparation for it for another time.

The duration of an SQF evaluation will vary depending on the complexity and size of the operations, but other factors can impact it. Below you can find approximately how long does an SQF certification audit take

Scope

How many documents are involved in the evaluation? How much time will it take to review them all? The audit scope refers to how deeply the third-party will immerse itself in its client’s system.

An SQF evaluation will look for any non-compliance to the code to ensure that your food products have the required quality. We’re talking about the safety of the customers, so everything has to be in order.

By identifying the scope of the audit, the process will be more structured and have more clarity. You will now know when it will start and finish and precisely how long will it take. This info will also let you know who has to present what during the evaluation.

Size of the site

The duration of the audit depends on how big the plant site and personnel are. Below is a chart with the approximate length; nonetheless, the certification body will be the one to decide based on the scope, risks associated, and complexity of the processes.

Risks associated

Identifying potential hazards its a fundamental step to prevent an incident from occurring. If a recall has happened with a particular ingredient in the recent past, an external entity may conduct an investigation. Allergens are another issue because at least eight of them need to be under control to make a product in the United States. Additionally, keeping track of the supplier’s history is very important.

What about the water supply and the use of pesticides and fertilizers? All of these are risks associated with the manufacturing of food products. The risk areas found will impact the length of the evaluation.

See also: SQFI Certificate Extension Policy and risk assessments – what you need to know

Number of the product lines and complexity of the process

Drafting the scope of the evaluation will let you cover various aspects of the product lines as:

• Capacity utilization.
• Quality of production.
• Production bottlenecks.
• Production costs.
• Wastages and rejections.
• Benchmarking with other units in the same company.
• Overall equipment efficiency.
• Regulatory requirements.

Furthermore, by understanding your expectations, the auditor will find a way to add value to the processes during the product lines evaluation.

The complexity of system design and documentation

The system in your company lets you work efficiently and make the same product all over again. As the product changes, the system also has to. This transformation can become very intricate over time, so keeping track of it with the appropriate documents is very important. These will be the soul of your product in the years to come.

The third-party is in charge of reviewing the design and documentation during an audit. If too many processes are involved, the evaluation could take a little longer.

Cooperation of the personnel

The certification body wants one thing: that you obtain the certification. The latter will only be possible if cooperation comes from all levels of the company. Suppose management is working very hard to achieve this, but some department heads are no that interested or have their minds in other things. The evaluation affects your business as a whole, so it’s essential that everyone, no matter their job positions, understands it. In the end, everyone will benefit from the coveted certification.

As you can see, the duration of an audit can be affected by many factors. Understanding them all will give you a hint of how long does an SQF certification audit take and how you can prepare your team for this effort.

What is a pre-audit?

A pre-audit is an evaluation performed before the actual assessment. You do everything as in the real one, but it has absolutely no value towards the certification. During a pre-audit, the third party reviews all documents to ensure that all procedures are correct. It is very usual for companies to hire a third party to conduct it.

Before undertaking the official evaluation, a pre-audit can be a preparation of sorts. With CICS Americas, 9.5 out of 10 businesses that pass the real audit went through a pre-audit before.

Although a pre-audit is entirely optional, companies see it as their first step in the evaluation process to get a certification. And if that wasn’t enough, you can ask your auditing company to evaluate a specific area in your system in search of any deviance.

What’s the difference between a pre-audit and a desk evaluation?

The desk evaluation is already part of the official audit. During it, the third party reviews the documents, instructives, and processes of each area. Throughout this design stage, the auditor receives all the paperwork that describes the system. Then, during the implementation stage, he visits the site to ensure every process adheres to the design.

The thing is, all the norms tell you what you have to do, but not how. In an official evaluation, the auditing body will only let you know if you comply or not, but not what you need to do. Therefore, a pre-audit will bring upon you all the corrective actions you must take to pass the certification audit with no problem whatsoever.

Benefits

Here are some of the most prominent benefits of a pre-audit during a certification process:

Internal results

It’s worth mentioning that the result of a pre-audit, whichever may be, will remain confidential; just you and the auditing body will know it. This external perspective will let your business work its weak points before the official evaluation. Think of it as a valuable practice that will give you much room for improvement.

Identification of non-conformities

The pre-audit will point to any non-conformities found in the system; a corrective action plan will address them immediately. Also, your company will now have a renewed security to undergo the audit. The implementation will be done faster by knowing which aspects of the system need to change to adhere to the quality code in question. It will be a unique opportunity to turn your attention to problematic areas unknown to you until that moment. Our clients know that this is one of the most important benefits of a pre-audit.

See also: 7 ways audits create value for your organization

Preparation for the official audit

Having identified the non-conformities, now is time to focus the resources on fixing them. But, bear in mind that, depending on the outcome of a pre-audit, your business may decide to postpone the evaluation to prepare better or, on the contrary, obtain the confidence necessary to face the assessment in the best possible way. A pre-audit will give you the roadmap ahead.

No future financial losses

Suppose that you undergo the audit, and some non-conformities arise. You need to address them as quickly as possible not only because it is a requisite for the certification, but because you may need to fulfill a contract already in place with any buyer. If we are talking about a major non-conformity, the investigation and subsequent implementation could take you some time, possibly losing the buyer’s contract. The pre-audit could have identified the risk areas long before something like this happened.

Low-stress level

You probably didn’t expect this one benefit, but a pre-audit is likely to lower your stress level during the evaluation process. How? In CICS Americas, we suggest that the same auditor be the same for the pre-audit and the audit itself. Why? By establishing a rapport from the beginning, you and the auditor will work hand in hand with the certification in mind. This relationship of trust will let you feel relaxed towards the ultimate goal.

A pre-audit adds value to your system and the certification process. Although this first step is entirely optional, your business should not pass the opportunity to undergo an evaluation that will open your eyes as to the corrective actions you have to make to succeed. Of course, choosing the right third party to do it is vital to make the most out of the benefits of a pre-audit.

References: Eurofins
ISO Update

The definition

Corrective action is taken by a business to fix a failure in its system to ensure that it won’t happen again, addressing a non-conformity raised during an audit.

To take corrective action, you must be clear about the who, what, when, where, and why. Doing this will let you know all the specifications about the problem so that you can solve it most quickly and effectively.

It may be utopian to think about correcting a failure forever, but what you must be looking for is to minimize the probability of it happening again. These are some aspects you must consider when taking corrective actions:

Correction

Before implementing the full corrective actions, you must take an immediate one that solves the problem temporarily. It’s important to know that this is not the corrective action you are looking for to fix the system.

Informing customers, quarantining an item, or reviewing a procedure are great examples.

Depending on the nature of the non-conformance, you must determine its magnitude to identify batches with the same potential issue. You need to know if it’s an isolated incident or a problem in the system.

Identifying the  root cause

The next step is to make a profound analysis to identify the root cause of the problem. By reviewing all of the symptoms, you’ll be able to get to the bottom of the issue. Think of it as a medical diagnosis. “Why is the system suffering? What measurable evidences have you collected?” You will get to it by answering these questions.

Getting rid of the root cause is the only way to prevent a problem from happening again. Some popular techniques include the 5 Whys, the Pareto analysis, y the fishbone diagram.

Each one has its challenges. For example, the 5 Whys generate a tendency for a team to address the symptoms instead of going further, looking for the real root cause. On the other hand, the fishbone diagram is considered a more holistic approach.

See also: The benefits of a pre-audit during a certification process

Corrective action

When you have identified the root cause, you and your team must develop the tasks, processes, and designs to implement changes and resolve the problem.

All departments must know what is going to happen to maximize effectiveness. This level of coordination will let everyone understand how they will be affected by the actions. Of course, you must document everything for implementation. You must determine who is responsible, when are they going to act, and the specifics of it. These details will let you review the process in the future.

You can’t get to this stage until you identify the root cause. It’s very typical for companies to take corrective actions that don’t address the root cause.

The duration of a corrective action will depend on the complexity of the problem and the necessary steps to implement it.

Demonstration that the system works

Finally, when you present your corrective actions, the auditor will determine if they are satisfactory. The verification of the effectiveness will allow you to prevent future non-conformities and ensure that the system is working as intended. You also need to have a method to demonstrate that its functioning and issues are gone. An internal audit could be helpful to prove it.

Corrective actions are an essential part of any certification audit, so you and your team must be prepared to make these changes to achieve the ultimate goal.

Reference: Asia Quality Foods

But what is an “extraordinary event”? As previously mentioned, we refer to a situation beyond the control of the organization, commonly described as “Force Majeure” or “act of God”. Riots, geopolitical tensions, crimes, natural or human-made disasters, and, of course, pandemics, to mention some examples.

The lockdown forced many industries to change the way they operated, and SQF Certified Sites were not the exception. Dealing with highly restrictive travel policies and alterations in the site’s production are a few of the many challenges that organizations are currently facing. 

Consequently, the site’s SQF Recertification schedules were altered, and SQFI had to act diligently to support the SQF community and establish an appropriate course of action to adapt to the evolving situation.  

The SQFI Certificate Extension Policy

In line with the Global Food Safety Initiative (GFSI) Policy, Certifying Bodies (CBs) shall follow the SQFI Certificate Extension Policy. A one-time six-month extension to a site’s SQF Recertification date is granted when the site is going through extenuating circumstances that prevent the audit from taking place following its regular schedule.

So what’s next for the sites that will soon require SQF audits but cannot conduct them as they usually do? First, communication between the site and its CB is key to identifying challenges and defining a possible course of action. 

After this, a site may request the extension to their former CB, which will need to assess the site’s risks of continuing certification through a process called “risk assessment”. 

A CB performs the risk assessment by gathering the necessary information from the certified site and decides an appropriate course of action. Due to the moment we’re living, some sites have not been able to have their SQF Recertification audit. For them to comply, the SQFI has granted a one-time six-month extension. To approve it, they need to do a risk assessment to understand the risk to extend the certificate. 

See also: 7 ways audits create value for your organization

How’s the SQFI dealing with risk assessments during the COVID-19 pandemic?

Although on-site audits continue to be the preferred option, the Certification Body (CB) can perform a risk assessment to determine the risk to food safety and the SQF system continuity if the site remains inaccessible.

It’s important to know that this evaluation doesn’t determine the risk of the site’s exposure to COVID-19, but rather whether it could affect the safety of the products or integrity of the SQF system. Each CB must perform a risk assessment process for each site, requesting an extension, which can take approximately 1-3 hours. 

To request an extension to the SQFI, the CB shall analyze the site’s risks by collecting relevant information from their audit’s history and feedback from their previous auditor. After this process, the CB will determine the level of risk. If it’s “low”, then the CB performs the assessment without having to interview and conduct a remote evaluation. If, on the other hand, the risk is “high”, then a remote assessment (interviews with the personnel) should be conducted.

At CICS Americas, we support our clients and are here to help them through these rough times. 

Our risk assessment during the COVID-19 pandemic is entirely free of charge.

Risk classification

·       Low risk. Request a 6-month extension to the recertification audit using the on-line form.

·       High risk. Request additional information and conduct remote activities to determine if the CB can lower the risk to permit an extension. If not, the certificate will expire.

Questions that the risk assessment may include:

• When will the site be able to function normally again?

• Is the site able to manufacture products or perform the service defined within its current certification scope?

• Has the certified site conducted an impact assessment of the COVID-19 pandemic?

• What kind of impact is experienced or expected in the supply chain and site operations?

• To what extent has operations of the SQF management system been affected?

• Have there been any changes in the system, recalls, withdrawals, regulatory actions, or complaints since the last recertification audit?

• Are all internal audit activities complete as required by the SQF Code?

If the CBs risk assessment identifies that remote activities are needed to mitigate risk, they should follow with it. Remote activities are only necessary when the site is high risk. These may include a detailed analysis of the site management reviews, internal audit records, records of CCP monitoring, changes to the SQF system, follow-up on corrective actions raised at the last recertification, amongst others.

The evaluation, of course, is part of the audit itself. If the CB determines that the client is low risk, there’s no need to have a remote interview with the auditor. 

Source: SQF Institute