We all remember the day when we got to school and there stood the warm but nervous face of a Substitute teacher! Oh the joy and the panic felt by all. The questions swirling from student to teacher… Will they know what they are doing? Will the kids behave? Will they let us get away with something? What will they try to get away with today? I figured this is what some of us might be feeling trying to understand the new SQF Substitute Practitioner requirement in edition 9. Wondering how will this be different from a back-up? Will my substitute be prepared if I need to take a day off? Is the substitute required to be in attendance through the entire audit? Will the kids, I mean coworkers listen to them if I give the substitute more responsibility? Well you’re not alone and we need to develop a plan to meet these updated requirements for any SQF audits being conducted on or after May 24, 2021.
SQF states that the Substitute must meet all the same requirements and qualifications as the primary SQF Practitioner, outlined in 220.127.116.11 and 18.104.22.168 of the code.
- Designated by Senior site management.
- Responsibility and authority to oversee the development, implementation, review, and maintenance of the SQF system.
- Take appropriate action to ensure the integrity of the SQF system.
- Communicate to relevant personnel information essential to ensure the effective implementation and maintenance of the SQF System.
- Be employed by the site.
- Hold a position of responsibility related to the management of the site’s SQF System.
- Have completed a HACCP training course.
- Be competent to implement and maintain HACCP based food safety plans.
- Have an understanding of the SQF Food Safety Code and the requirements to implement and maintain an SQF System relevant to the site’s scope of certification.
In some companies it may be fairly easy to identify the SQF Substitute Practitioner, as there are multiple technical professionals who are already supporting at this level or could be promoted to take on additional responsibilities. Although not everyone is this lucky or resourced the same, such as small facilities that may lack of depth and breadth of the current team structure. These companies already have a team that wears multiple hats.
So what if there is nobody qualified currently to fill the Substitute role? Does SQF really expect there to be two SQF Practitioners?
These are not easy questions to answer, as each company operates differently and it may take time to bring someone to the same level of knowledge and skillset as the Primary SQF Practitioner or additional resources may need to be considered. SQF auditors will be looking for confirmation on who the Primary and Substitute Practitioners are and how the roles meet the clauses of the new code. So knowing that regardless of the size of the company, complexity of personnel structure, and overall pathway to achieve compliance, we need to start finding answers to these questions and creating a plan.
Preparing for Your Transition from SQF 8.1 to 9.0 Edition
If you’re a site that is currently certified or looking to achieve certification this year, we encourage you to watch on-demand this insightful webinar.
During this webinar we’ll discuss the changes transitioning from 8.1 to 9.0 as well as provide helpful tips on how to quickly and effectively address the key changes and ensure compliance to the new standard.
- Ask the Important Questions
Re-evaluate who the current SQF “Backup” person selected was and take this opportunity to perhaps rethink the strategy and not just automatically assign them as the “Substitute”.
- Was it the right person?
- Do they have the expertise to fill the new role?
- Where are the gaps?
- Is it time to start developing a new person who could be a better fit now and for the future?
- Do you have a new person in your existing organization?
- Have a Plan
Once selected, set them up for success with a formal on-boarding plan. Whether it is a new hire or a current employee filling these shoes, it is important to create a plan to share knowledge, engage them in document writing, inspections and cross training. Additionally, this will prove to the Auditor that thought went into achieving this new requirement.
- Share the Lead
Once the Substitute has obtained the necessary technical knowledge, have them take Responsibility for certain programs. We learn when we are doing…just like sensory play in preschool.
- Be Audit Ready
It will be important that the Substitute is as audit ready as the Primary Practitioner. They should be in charge of internal audits, interviewing employees for preparation, and an active partner in the success of the audit readiness – before, during and after.
The importance of this role should not be lost on us and we should learn to embrace it as an opportunity to share our knowledge, grow the team, and continuously improve.
If we only had this type of foresight as a kid to see a Substitute as an opportunity to learn something new from. Remember having an SQF Substitutes provides the business confidence that there is more than one person capable of driving the ship or teaching the class and that they are just as qualified!