Audit Report # Created by Jessica Macon on Oct 4, :38:53 PM. Last Comment

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1 Audit Report # Created by Jessica Macon on Oct 4, :38:53 PM Last Comment Number Document Links 2012 Westside Produce Level 2 Initial Audit # [rev. 1] (Approved) Company Information Company ID Company Name Westside Produce Address 1 P.O. Box 7 Address th Street City Firebaugh State/Province California Postal Code Country UNITED STATES Certification Body Information CB Name SCS Global Services Country UNITED STATES Phone Website SCS Global Services Audit Information Audit Reference Audit Type Certification Facility Audit Level 2 Audit Status Completed Lead Auditor Heena Patel Date Audit Started Aug 14, :10:00 PM Aug 14, :10:00 PM UTC Audit Rating G - Good Secondary Auditor(s) SQFI Audit Score 91 Date Audit Finished Aug 15, :10:00 PM Aug 15, :10:00 PM UTC s

2 Opening Meeting People Present at the Opening Meeting (Please list names and roles in the following format Name: Role separated by comas) Garrette Patricio: Vice President/SQF Practitioner, Steve Patricio: President Closing Meeting People Present at the Closing Meeting (Please list names and roles in the following format Name: Role separated by comas) Garrette Patricio: Vice President/SQF Practitioner, Steve Patricio: President Facility Description Auditor Description of Facility (Please provide facility description include # of employees, size, production schedule, general layout, and any additional pertinent details The operation is seasonal. There are about 18 to 20 workers employed by the company during the season. The melons (honeydew and cantaloupes) are field packed and received at the facility. Products are inspected for quality on a random basis by opening boxes. Products are cooled via forced air cooling system in the cooler to remove field heat and stored in the cooler prior to distribution. Auditor Recommendation Auditor Recommendation

3 Management Policy (2) (M) Senior management shall prepare and implement a policy statement that outlines as a minimum: the organization's commitment to supply safe food; the methods used to comply with its customer and regulatory requirements and continually improve its food safety management system; and the organization's commitment to establish and review food safety objectives. Senior management has prepared and implemented a policy statement that outlines as a minimum a) organization's commitment to supply safe food, b) the methods used to comply with its customer and regulatory requirements and continually improve its food safety management system, c) and the organization's commitment to establish and review food safety objectives Management Policy (2, 3) (M) The policy statement shall be: signed by senior management; made available in language understood by all staff; and displayed in a prominent position and effectively communicated to all staff The policy statement is signed by the President and made available in Spanish and English. The policy statement was displayed in a prominent position and effectively communicated to staff. The Cooler Manager was interviewed and he was able to describe the content of the statement. The policy statement in English and Spanish is displayed on the employee bulletin board in the employee break room. In addition, training records showed that all new hires and workers had read the policy statement Management Responsibility (1, 2) (M) The organizational reporting structure describing those who have responsibility for food safety shall be defined and communicated within the organization. The organizational reporting structure is documented. The reporting structure describes each position that has responsibility for food safety. The document provides a snapshot of how positions interact and share responsibility for food safety. Garrett Patricio, the Vice President/SQF Practitioner reports to Stephen Patricio, the President of the company. Brandy Nunez, the Cooler Manager and Quality Advisor and VP of Sales and Marketing report to SQF Practitioner. All cooler employees report to Cooler Manager and Quality Advisor. All administrative and sales personnel report to VP of Sales and Marketing Management Responsibility (1, 2) (M) The senior management shall make provision to ensure fundamental food safety practices are adopted and maintained.

4 The senior management has ensured that food safety practices have been adopted. Based on the observation, an environment exists in which employees are encouraged to report food safety problems if they exist Management Responsibility (2) (M) The senior management shall ensure adequate resources are available to achieve food safety objectives and support the development, implementation, maintenance and ongoing improvement of the SQF System. The senior management has provided sufficient resources to achieve the food safety objectives and to support the on-going maintenance and improvement of the SQF System. The President and the SQF Practitioner were interviewed and according to them, the process has been the same for many years, but adequate resources are provided to maintain the program Management Responsibility (2) (M) The senior management shall designate an SQF practitioner for each site with responsibility and authority to oversee the development, implementation, review and maintenance of the SQF System, including food safety fundamentals outlined in 2.4.2, and the food safety plan outlined in 2.4.3, to take appropriate action to ensure the integrity of the SQF System, communicate to relevant personnel all information essential to ensure the effective implementation and maintenance The SQF Practitioner is designated by the organization. The SQF Practitioner has the responsibility and authority to support the development, implementation, maintenance, and ongoing improvement of the SQF system. The organizational chart was verified by the senior management and a brief description of job responsibility was documented, which provided a snapshot of how positions interact and share responsibility for food safety Management Responsibility (2) (M) The SQF practitioner shall be employed by the supplier as a company employee on a full-time basis, hold a position of responsibility in relation to the management of the supplier's SQF System, have completed a HACCP-based training course and be competent to implement and maintain HACCP-based food safety plans, have an understanding of the SQF Code level 2 and the requirements to implement and maintain SQF Systems relevant to the supplier scope of certification.

5 The SQF Practitioner is employed by the supplier as a company employee on a full-time basis, holds a position of responsibility in relation to the management of the supplier's SQF System and has completed a HACCP-based training course. The SQF Practitioner was interviewed and he was competent to implement and maintain HACCP-based food safety plan, and had an understanding of the SQF code level 2 and the requirements to implement and maintain SQF Systems relevant to the scope of certification Management Responsibility (2) (M) The responsibility for establishing and implementing the training needs of the organization's personnel to ensure they have the required competencies to carry out those functions affecting products, legality, and safety shall be defined and documented. A training program is documented. Responsibility for establishing and implementing the training needs of the organization has been defined and documented. SQF system training is provided by the SQF Practitioner. The SQF Practitioner has attended a 2 day training class on implementing SQF Systems. He has also taken a one day HACCP training course in Good Agricultural Practices, provided by SCS. He is planning to attend a 2 day course on HACCP in September In addition, training is also provided by the Cooler Manager and Consultant on GMPs Management Responsibility (2) (M) All staff shall be informed of their responsibility to report food safety problems to personnel with authority to initiate action. All staff has been provided training by the Consultant or SQF Practitioner. Training records were maintained and reviewed. Receiving and shipping personnel were interviewed and they were aware of their responsibilities and explained the product handling procedures. Staff report food safety problems to SQF Practitioner or Cooler Manager if there are any issues Management Responsibility (2) (M) Job descriptions for those responsible for food safety shall be documented and include provision to cover for the absence of key personnel. Job descriptions for those responsible for food safety were documented and included provision to cover for the absence of key personnel. Workers were interviewed on a random basis and were aware of their responsibilities Management Responsibility (2, 3) (M) The senior management shall establish processes to improve the effectiveness of the SQF System to demonstrate continuous improvement.

6 Continuous improvement processes were documented and implemented. Emphasis has been provided in the employee training program Food Safety Management System (2) (M) A food safety manual shall be documented and maintained in either electronic and/or hard copy form. It shall outline the methods the organization will use to meet the requirements of this Standard, be made available to staff and include a summary of the organization's food safety policies and the methods it will apply to meet the requirements of this standard, policy statement and organization chart, the scope of the certification, include a list of the products covered under the scope of certification. The food safety manual is kept locked in the file cabinets. Employees were interviewed on a random basis and they were aware of the food safety manual. There was evidence that the food safety manual has been maintained and implemented. All documented procedures applicable to the SQF, Level 2 program are accessed from the common server and these procedures are protected by username and password. The manual included organizational chart and other procedures and documentation necessary to support the development, implementation, and maintenance of the SQF system Food Safety Management System (2, 3) (M) A food safety manual shall be documented, maintained, made available to relevant staff and include or reference the written procedures, pre-requisite programs, food safety plans and other documentation necessary to support the development and the implementation, maintenance and control of the SQF System. The food safety manual does support the implementation, maintenance, and control of the SQF system. It also includes the pre-requisite programs, food safety plans, and other procedures and documentation necessary to support the development, implementation, and maintenance of the SQF system. The food safety manual was current and documented procedures were up to date. The content of documented procedures was verified Management Review (2, 3) (M) The senior management shall be responsible for reviewing the SQF System and documenting the review procedure. Reviews shall include the policy manual, internal and external audit findings, corrective actions and their investigations and resolution, customer complaints and their resolution and investigation.

7 The reviewing procedure is implemented and the entire SQF System is reviewed annually with senior management. Reviews include the policy manual, internal and external audit findings, corrective actions and their investigations and resolution, customer complaints and their resolution and investigation. Meeting discussion records were available for review Management Review (1, 2, 3) (M) The SQF System in its entirety shall be reviewed at least annually. The entire SQF System is reviewed annually by SQF Practitioner, who is senior management. Review was conducted on 05/12/12 and records were maintained Management Review (2) (M) Food safety fundamentals and food safety plans shall be reviewed when any changes implemented have an impact on the supplier's ability to deliver safe food. Food safety fundamentals and food safety plans are required to be reviewed when any changes are implemented. Based on the review of the documented procedures, there had not been any major changes in the process. The program requires that any major change to food safety plan shall be validated and verified by the SQF Practitioner before implementation. Note: The facility has been handling melons for many years Management Review (2) (M) The SQF practitioner shall be responsible for validating changes to food safety fundamentals and food safety plans that have an impact on the supplier's ability to deliver safe food. The SQF Practitioner is responsible for validating changes to food safety fundamentals and food safety plan. All reviews and major changes to the SQF System are required to be documented by the SQF Practitioner. Documentation will include reasons for any changes. Note: The program has been developed in year 2012 and there had not been any major changes Management Review (2, 3) (M) Records of all reviews and reasons for amending documents, validations and changes to the SQF System shall be maintained.

8 Records of all reviews and reasons for amending documents, validations and changes to the SQF System is required to be maintained. A change was made on one document and new version # was created and reason for amending the document was documented Complaint Management (2, 3) The methods and responsibility for handling and investigating the cause and resolution of complaints from customers and authorities shall be documented and implemented. A documented procedure on complaint management was documented and available for review. The Director of Administration receives the complaints and all complaints are documented in the Customer Complaint Form. The customer complaints are received via phone and s. The SQF Practitioner is responsible for investigating customer complaints and initiating follow up actions. The Director of Administration is responsible for communicating back to the customer on how the complaints were resolved. A Customer Complaint Log is required to be completed to track all complaints received. The investigation is initiated based on the nature of the complaint. All complaints reviewed were quality related Complaint Management (2, 3) Trends of customer complaint data shall be investigated and analyzed by personnel knowledgeable about the incidents. Customer complaint data is investigated and reviewed by the SQF Practitioner. The data is trended. Complaints are received via s and phone calls Complaint Management (2, 3) Corrective action shall be implemented commensurate with the seriousness of the incident and as outlined under Based on the interview of the management and review of records, there had not been any serious incident at the facility. The management was aware of all the requirements documented in the procedure Complaint Management (2)

9 Records of customer complaints and their investigations shall be maintained. Records of customer complaints and corrective actions taken by the supplier were maintained Business Continuity Planning (2) A business continuity plan based on the understanding of known food safety threats to a business shall be prepared by senior management outlining the methods and responsibility the organization will implement to cope with a business crisis that may impact on the ability of the supplier to deliver safe food. A business continuity plan is documented and it addresses the known threats relevant to the facility. The plan was prepared by the senior management and included methods and responsibilities the organization will implement to cope with a business crisis that may impact the ability of the supplier to deliver safe food. For example, business interruptions identified are power failure, fire, earthquake, ammonia leak, and equipment failure Business Continuity Planning (2, 3) The business continuity plan shall include as a minimum a senior manager responsible for decision making, oversight and initiating actions arising from a crisis management incident; the nomination and training of a crisis management team; controls implemented to ensure a response to a crisis does not compromise product safety; measures to isolate and identify product affected by a response to a crisis; the preparation and maintenance of a current crisis alert contact list; the responsibility for internal communications and communicating with authorities, external organizations and media. The business continuity plan shall include as a minimum sources of legal and expert advice. The business continuity plan includes a minimum a senior manager responsible for decision making; oversight and initiating actions arising from a crisis management incident; the nomination and training of a crisis management team; controls implemented to ensure a response to a crisis does not compromise product safety; measures to isolate and identify product affected by a response to a crisis; the preparation and maintenance of a current crisis alert contact list; the responsibility for internal communications and communicating with authorities, external organizations, and media. It includes sources of legal and expert advice. The Crisis Team members are the President, SQF Practitioner, SQF Consultant, Cooler Manager and Quality Advisor and VP of Sales and Marketing Business Continuity Planning (2, 3) The business continuity plan shall be reviewed, tested and verified at least annually. Minor

10 Business continuity plan has not been tested and verified. Records were not available for review Business Continuity Planning (2, 3) Records of reviews and verification of the business continuity plan shall be maintained. The plan is required to be reviewed annually Document Control (2, 3) (M) The methods and responsibility for maintaining document control and ensuring staff have access to current documents shall be documented and implemented. The SQF Practitioner is responsible for maintaining the document control and ensuring that staff has access to current documents. The SQF Practitioner keeps a record of all documents used, when they were issued, and updated. The documented procedures are controlled by version numbers. Note: All documented procedures have document number, title, issue date, version number, developed by, approved by, and revised by information. Records were reviewed and pencil and white-out were not used Document Control (2, 3) (M) A register of current SQF System documents and amendments to documents shall be maintained. A register of current SQF System documents and amendments were available for review Document Control (2, 3) (M) Documents shall be safely stored and readily accessible. Documents were safely stored and readily accessible.

11 Records (2, 3) (M) The methods and responsibility for undertaking monitoring activities, verifying, maintaining and retaining records shall be documented and implemented. Methods and responsibilities are defined for monitoring activities, retaining of records, and maintenance of records. The SQF Practitioner is responsible for monitoring activities, verifying, maintaining, and retaining records. Each Dept. Manager or Supervisor is responsible for maintaining daily records and the records are collected by the SQF Practitioner for final review. The records are reviewed by the SQF Practitioner on a scheduled basis. A verification schedule is documented, which includes a list of records to review, frequency of review, responsibility of immediate supervisor, reviewer (SQF Practitioner), and reviewer's frequency to review records. The records are reviewed and signed and dated by the SQF Practitioner as part of the verification activities Records (2, 3) (M) All records shall be legible and suitably authorized by those undertaking monitoring activities that demonstrate inspections, analyses and other essential activities have been completed. Records were reviewed and they were legible and signed by the SQF Practitioner Records (2, 3) (M) Records shall be readily accessible, retrievable, securely stored to prevent damage and deterioration and shall be retained in accordance with periods specified by a customer or regulations. Records were readily accessible and securely stored to prevent damage and deterioration. Records were reviewed. The procedure requires minimum of 2 year record storage Specification and Product Development (2, 3) The methods and responsibility for designing, developing and converting product concepts to commercial realization shall be documented and implemented.

12 The product is a whole produce Specification and Product Development (2, 3) Product formulation, manufacturing processes and the fulfillment of product requirements shall be validated by facility trials, shelf life trials and product testing. Methods and responsibility are documented to ensure that melons meet specifications. The President and SQF Practitioner are responsible. Note: The products are melons; therefore, only shelf life and product testing applies. However, there had not been any new products handled at the facility. The facility strictly handles melons and products are field-packed in corrugated cardboard boxes Specification and Product Development (2, 3) Shelf life trials where necessary shall be conducted to establish and validate a product's handling, storage requirements, including the establishment of "use by" or "best before" dates, microbiological criteria, consumer preparation, storage and handling requirements. "Use by" and "best before" dates are not used Specification and Product Development (2) A food safety plan shall be validated and verified for each new product and its associated process through conversion to commercial production and distribution, or where a change to ingredients, process, or packaging occurs that may impact food safety. There has not been introduction of any new products. The facility has been handling melons for many years Specification and Product Development (2, 3) Records of all product design, process development, shelf life trials and approvals shall be maintained.

13 Record was in place on evaluation on the product, based on the new seed variety introduced at the field in The melons were evaluated for color, aroma, flavor, and texture. The products were evaluated over a period of time (07/13/12, 07/18/12, 07/25/12, 08/01/12, and 08/08/12) Raw and Packaging Materials (2) Specifications for all raw and packaging materials, including, but not limited to ingredients, additives, hazardous chemicals and processing aids that impact on finished product safety shall be documented and kept current. Specifications on melons and corrugated cardboard boxes were on file. Material safety datasheets and labels for all chemicals used on site were in MSDS binder. Note: Packaging material, corrugated cardboard box is considered low risk. Letter of guarantee was on file as well. Melons are tested once per season for pesticides (organochorides, organophosphates, organonitrogens, carbamates, as well as reduced risk pesticides). Microbiological test is not conducted Raw and Packaging Materials (2, 3) All raw and packaging materials and ingredients shall comply with the relevant legislation. Melons are handled at the shed, where cgmps (21 CFR) are implemented. Packaging material is low risk and therefore letter of guarantee is maintained. For melons, the management is aware of the recent outbreaks associated with cantaloupes. Senior management is a member of the California Melon board and the board had supported research conducted at UC Davis by Dr. Suslow Raw and Packaging Materials (2, 3) The methods and responsibility for developing and approving detailed raw material, ingredient, and packaging specifications shall be documented. The President and SQF Practitioner are responsible for developing and approving packaging materials. Melons are handled at the facility. The specifications were documented. For example, quality inspection includes color, size, brix, pressure, firmness, decay, etc Raw and Packaging Materials (2)

14 Raw and packaging materials and ingredients shall be validated to ensure product safety is not compromised and the material is fit for its intended purpose. Validation of raw materials and ingredients shall include certificate of conformance; or certificate of analysis; or sampling and testing. Microbiological tests are not conducted on the melons. Packaging material is not tested, since it has been assessed as a low risk. Melons and raw materials are inspected upon receiving at the facility. Verification was conducted and melons came from approved growers and packaging materials from an approved supplier. The methods for selecting, evaluating, approving, and monitoring of approved suppliers were documented. The facility looks for a good supply history and sourcing from quality assured growers. A 3rd party packaging material inspection report was on file Raw and Packaging Materials (2, 3) Validation of packaging materials shall include certification that all packaging that comes into direct contact with food meets either regulatory acceptance or approval criteria. Documentation shall either be in the form of a declaration of continued guarantee of compliance, a certificate of conformance, or a certificate from the applicable regulatory agency. absence of a certificate of conformance, certificate of analysis, or letter of guarantee, tests and analyses to confirm the absence of potential chemical migration from the packaging to the food contents shall be conducted and records maintained. A letter of guarantee was on file on packaging material Raw and Packaging Materials (2, 3) Product labels shall be accurate, comply with the relevant legislation and be approved by qualified company personnel. A printed white sticker label with information, such as company name, location, lot code, etc. is placed on each box Raw and Packaging Materials (2, 3) A register of raw and packaging material specifications and labels shall be maintained and kept current. A register of melons, chemicals, and packaging materials were maintained. A sticker label is printed on a daily basis. All corrugated cardboard boxes are pre-printed by the supplier.

15 Contract Service Providers (2) Specifications for contract services that have an impact on finished product safety shall be documented, current, include a full description of the service to be provided and detail relevant training requirements of contract personnel. For example, the pest control company, waste management company, and refrigeration service company are contract service providers. The pest control operator is required to go through pest management and GMP training. Current PCO license was on file Contract Service Providers (2, 3) A register of all contract service specifications shall be maintained. A list of contract service providers was available, maintained, and current Contract Manufacturers (2, 3) The methods and responsibility for ensuring all agreements relating to customers product requirements and its realization and delivery are specified and agreed shall be documented and implemented. The facility does not use any contract manufacturers Contract Manufacturers (2, 3) The supplier shall verify all customer requirements are being met at all times, ensure changes to contractual agreements are approved by both parties and communicated to relevant personnel. The facility does not use any contract manufacturers.

16 Contract Manufacturers (2, 3) Records of all contract reviews and changes to contractual agreements and their approvals shall be maintained. The facility does not use any contract manufacturers Finished Product (1, 2) Finished product specifications shall be documented, current, approved by the supplier and their customer, accessible to relevant staff and may include microbiological and chemical limits, labeling and packaging requirements. Finished product specifications were documented, current, and approved by the supplier and customer. Products are inspected for quality by inspectors known as "bird dogs" and the person is sent by most buyers to the facility for inspection. The receivers at the facility also conduct inspections of each lot upon arrival from fields. The qualifications of the staff were verified and they were qualified and competent to verify the specifications. Records on quality inspections were maintained. Records were reviewed. Note: Microbiological tests are not conducted on products Finished Product (2, 3) A register of finished product specifications shall be maintained. A register of finished product specifications was maintained Food Legislation (2) (M) The organization shall ensure that, at the time of delivery to its customer, the food supplied shall comply with the legislation that applies to the food and its production in the country of its origin and destination. This includes compliance with legislative requirements applicable to maximum residue limits, food safety, packaging, product description, nutritional, allergen and additive labeling, and to relevant established industry codes of practice. The management demonstrated that they were aware of and compliant with the food regulation that applies to the products that are handled within the facility. Country of origin and facility name and address were printed on the corrugated boxes.

17 Food Legislation (2, 3) (M) The methods and responsibility for ensuring the organization is kept informed of changes to relevant legislation, scientific and technical developments and relevant industry codes of practice shall be documented and implemented. The President and SQF Practitioner keep abreast with relevant legislations and scientific or technical development. The facility is affiliated with Western Growers and Produce Marketing Association. The management is also involved in research studies conducted by UC Davis on melons due to cantaloupe implicated with microbiological outbreaks Food Safety Fundamentals (2) (M) The property, buildings and equipment shall be located, constructed, designed and maintained to facilitate the hygienic production, manufacture, handling, storage and/or delivery of safe food. The premises, buildings, and equipment are located, constructed, and designed to facilitate the proper manufacturing, handling, storage and delivery of safe food. Food safety fundamentals are documented to ensure fundamental food safety practices are adopted and maintained. A site plan showing location of the premises and surroundings was on file. Site registration was current indicating that the premise is approved for the purpose. The premises were structurally sound and operated in a hygienic manner Food Safety Fundamentals (1, 2) (M) The supplier shall ensure the food safety fundamentals described in the relevant subsequent modules of this Code (i.e. modules 3 15) are applied or excluded according to a detailed risk analysis outlining the justification for exclusion or evidence of the effectiveness of alternative control measures to ensure that food safety is not compromised. The food safety fundamentals were documented and these included 1) personnel practices, 2) personnel processing practices, 3) training of personnel, 4) calibration of equipment, 5) pest control program, 6) premises and equipment, 7) cleaning and sanitation, 8) monitoring of water microbiology and quality, 9) supplier approval, 10) transport and delivery, 11) waste management and disposal, and 12) allergen control (vending machines) Food Safety Fundamentals (2, 3) (M)

18 Those pre-requisite programs applicable to the scope of certification that outline the means by which food safety is controlled and assured shall be documented and implemented. Pre-requisite programs were documented and implemented. The programs are verified and validated by the SQF Practitioner Food Safety Fundamentals (2, 3) (M) The effectiveness of the pre-requisite programs shall be verified as described in SQF Practitioner is responsible for verifying monitoring activities for a) pre-requisite programs, b) control points, c) other food safety programs, d) sampling, inspection and analysis of raw materials, finished products, and d) scheduling and conducting internal audits. Records were in place showing that the methods and control measures provide the level of control needed. Potential methods for verification of the effectiveness of specific pre-requisite programs are listed below: 1. Personnel Practices: Employees are observed and interviewed during the internal audits to ensure that they are following personal hygiene. 2. Personnel Processing Practices: Employees are observed during the internal audit to ensure that they are following the program requirements. 3. Training of Personnel: Employees are interviewed to ensure that job training has been effective and that key points are understood. 4. Calibration of Equipment: Weighing scales, refractometers are calibrated according to the schedule. 5. Management of Pests and Vermin: Trend analysis is conducted on the pest activity to determine that the program is effective. 6. Premises Maintenance: Areas are inspected to ensure that building fabrics and fixtures are maintained. 7. Cleaning and Inspection: Pre-operational inspection is conducted to verify the cleaning and sanitation practices. Swabs are taken to verify the efficacy of sanitation program. 8. Water Microbiology and Quality: Water testing is performed to ensure that it meets potability standards. 9. Control of Physical Contaminants: Foreign material inspections are conducted. 10. Transport and Delivery: Trucks are inspected prior to loading. 11. Waste Management and Disposal: Outside grounds are monitored as part of self inspection Food Safety Plan (2, 3) (M) A food safety plan shall be developed, effectively implemented, and maintained and outline the means by which the organization controls and assures food safety. The food safety plan shall be prepared in accordance with the steps identified in the Codex Alimentarius Commission or NACMCF HACCP guidelines; cover a product or product group and the associated processes; describe the methodology and results of a hazard analysis conducted to identify food safety hazards associated with all inputs and process steps including rework; prescribe those measures taken to apply the controls implemented that are critical to assuring, monitoring and maintaining food safety; include process controls at control points in production to monitor product safety, identify when a process is deviating from set parameters and make corrections to keep a process under control; include documented Standard Operating Procedures (SOPs) and Work Instructions (WI) applicable to the organization's scope of certification. Primary producers may utilize a HACCP-based reference food safety plan developed by a responsible authority.

19 The food safety plan was current, verified, and validated by the SQF Practitioner. Food safety plan is implemented and maintained by the facility. The food safety plan had been prepared based on a thorough analysis of the process, identifying each step in the process and completing a "hazard analysis" of hazards at each step in the receiving, packing, storage, and transport of the products. The facility has demonstrated the 6 steps of HACCP as described in the CODEX HACCP Guidelines. There are no CCPs identified in the production process. There is one food safety plan. A multi-disciplinary HACCP team is in place. The HACCP team consists of the President, SQF Practitioner, VP of Sales and Marketing, Director of Information Technology, and other Supervisors and Managers. HACCP Plan: Product: Melons Food Category: Produce Packaging Used: Corrugated cardboard box Method of Storage and Distribution: Less than 40F Intended Use: Raw or cooked for General Public Composition: Whole produce Method of Preservation: No additives or preservatives Shelf life: 14 to 21 days under refrigeration Incoming Goods and Services (2) Raw materials, ingredients, packaging materials and services that impact on finished product safety shall be supplied by an approved supplier. Raw materials and packaging materials are supplied from approved suppliers. All incoming materials are inspected. Evaluation records were on file on each supplier Incoming Goods and Services (2, 3) The receipt of raw materials, ingredients, and packaging materials received from non-approved supplier shall be acceptable in an emergency situation provided they are inspected or analyzed before use. The melons are grown locally by the growers. According to the management, there will be no need to buy products from non-approved suppliers Incoming Goods and Services (2, 3) The responsibility for selecting, evaluating, approving and monitoring an approved supplier shall be documented and implemented. Approved supplier program is documented. All melons are harvested and packed from locally grown fields. The growers are selected, evaluated, and approved based on a good supply history and having GAP audits conducted on the fields. The inspections/audits are conducted every season. Also, a grower compliance form is completed which has food safety questions on employee training, water source, soil history evaluation, field sanitation, spray history and applications, pest and vermin control program, etc. Packaging material supplier's recent 3rd party audit report was maintained on file.

20 Incoming Goods and Services (2) The approved supplier program shall be based on the prior performance of a supplier and the risk level of the raw materials ingredients, packaging materials, and services supplied, and shall contain as a minimum agreed specifications, reference to the rating of the level of risk applied to a raw material's ingredients, packaging materials and services and the approved supplier, a summary of the food safety controls implemented by the approved supplier, methods for granting approved supplier status, methods and frequency of monitoring approved suppliers, details of the certificates of conformance if required, methods and frequency of reviewing approved supplier performance and status. The program does contain methods and frequency for monitoring and approving the suppliers. The approved supplier program is based on the prior performance of a supplier and the risk level of raw materials, packaging materials, and services supplied. The President and the SQF Practitioner manage the approved supplier program Incoming Goods and Services (2, 3) A register of approved supplier and records of inspections and audits of approved suppliers shall be maintained. All fields are audited for GAP on an annual basis by a third party auditing company. Records on audits were available for review. A list of approved suppliers and contract service providers was maintained Non-conforming Product or Equipment (2, 3) The responsibility and methods outlining how non-conforming product, raw material, ingredient, work-in-progress, packaging or equipment detected during receipt, storage, processing, handling or delivery is handled shall be documented and implemented. The methods applied shall ensure: Non-conforming product is quarantined, identified, handled and disposed of in a manner that minimizes the risk of inadvertent use, improper use or risk to the integrity of finished product; and Non-conforming equipment is effectively repaired or disposed of in a manner that minimizes the risk of inadvertent use, improper use or risk to the integrity of finished product; All relevant staff is aware of the organization's quarantine and release requirements applicable to equipment or product placed under quarantine status. For producers, the procedure must document the grower, field name, quantity and final disposition of the unacceptable materials when applicable. Methods and responsibility are documented, outlining how non-conforming products and packaging received during receiving, handling, and delivery are handled. Non-conforming products are identified physically with a tag or tape and stored segregated. Based on the interview of the SQF Practitioner, the products are field packed and inspected at the field level. Also, there had not been any incidents, and products had not been placed on hold or disposed of. Also, an inspector is on site to check the brix and quality of the products to ensure it is meeting the customer's specifications, prior to release. The SQF Practitioner and Cooler Manager are responsible for handling non-conforming products.

21 Non-conforming Product or Equipment (2, 3) Quarantine records, and records of the handling, corrective action, or disposal of non-conforming product or equipment shall be maintained. Products are field packed and according to the Cooler Manager, products are rarely disposed of from the facility. However, form is in place to document disposal of non-conforming products Product Rework (2, 3) The responsibility and methods outlining how the product is reworked (or recouped) shall be documented and implemented. The methods applied shall ensure: Reworking operations are supervised by qualified personnel; Reworked product is clearly identified and traceable; Each batch of reworked product is inspected or analyzed as required before release; Inspections and analyses shall conform to the requirements outlined in element 2.5.6; and Release of reworked product shall conform to the requirements outlined in element Products are not reworked Product Rework (2, 3) Records of all reworking operations shall be maintained. Products are not reworked Product Release (2, 3) (M) The responsibility and methods for releasing products shall be documented and implemented. The methods applied shall ensure the product is released by authorized personnel, once all inspections and analyses are successfully completed and documented to verify legislative and other established food safety controls have been met. The responsibility and methods are documented. The SQF Practitioner and Cooler Manager oversee the program. The representative who was sent by a customer to verify brix and quality of the products informs the Cooler Manager to release the products, after the results meet the customer specifications. All products released from the hold status are required to have records on a) product name and identification, b) total amount of products kept on hold, c) reason for hold, d) and product disposition.

22 Product Release (2, 3) (M) Records of all product release shall be maintained. Records of all product release are maintained Stock Rotation (2, 3) The responsibility and methods for ensuring effective stock rotation principles are applied shall be documented and implemented. Responsibility and methods are documented. The primary person to manage stock rotation is the Cooler Manager. Due to short shelf-life, products are released as quickly as possible to maintain the quality integrity. Inventory is conducted on a daily basis Responsibility Frequency and Methods (1, 2, 3) Validation and verification activities shall be the responsibility of the SQF practitioner. The frequency and methods used to validate and verify food safety fundamentals and other food safety controls identified in the food safety plan was documented and implemented. The SQF Practitioner is responsible for establishing frequency schedule and methods to verify and validate the programs. SQF Practitioner is responsible for verifying and validating a) pre-requisite programs (review and sign off), b) monitoring activities for pre-requisite programs, c) product inspections conducted, and d) internal audits. Verification and validation are conducted by review of records, interview of employees, and conducting visual observation Responsibility Frequency and Methods (2) The frequency and methods used to validate and verify food safety fundamentals, critical limits, and other food safety controls identified in food safety plans shall be documented and implemented and meet their intended purpose. A verification and validation schedule is documented outlining the activities, their frequency of completion, and the person responsible each activity. All pre-requisite programs were validated by the SQF Practitioner as required by the validation schedule in July, 2012.

23 Responsibility Frequency and Methods (1, 2, 3) Records of all verification activities shall be maintained. Verification records were available for review and authorized by the SQF Practitioner. For example, records were on sanitation, cooler temperature, water and environmental swabs results, pest control program, calibration, inspection of trucks, and other pre-requisite programs Validation and Effectiveness (2) (M) The methods, responsibility and criteria for ensuring the effectiveness of pre-requisite programs, and validating critical food safety limits to ensure they achieve their intended purpose shall be documented and implemented. The methods applied shall ensure that pre-requisite programs are confirmed to ensure they achieve the required result, that critical limits are selected to achieve the designated level of control of the identified food safety hazard(s), all critical limits and control measures individually or in combination effectively provide the level of control required, all critical limits and control measures individually or in combination effectively provide the level of control required, changes to the processes or procedures are assessed to ensure controls are still effective, ensure that critical food safety limits are re-validated at least annually. Internal audits are conducted to verify the effectiveness of the pre-requisite programs. Note: the facility does not have any CCPs Validation and Effectiveness (2, 3) (M) Records of all validation activities shall be maintained. Internal audit and pesticide tests on the melons were on file Verification Schedule (1, 2, 3) A verification schedule outlining the verification activities, their frequency of completion and the person responsible for each activity shall be prepared and implemented. A verification schedule was prepared.

24 Verification of Monitoring Activities (2) (M) The methods, responsibility and criteria for verifying the effectiveness of monitoring pre-requisite programs critical control points and other food safety controls identified shall be documented and implemented. The methods applied shall ensure that personnel with responsibility for verifying monitoring activities authorize each record verified. The SQF Practitioner reviews the records and makes observations on the floor to verify the effectiveness of pre-requisite programs. Example of monitoring records are sanitation, cooler temperature, water and environmental swabs results, pest control program, calibration, inspection of trucks, and other pre-requisite programs Verification of Monitoring Activities (2, 3) (M) Records of the verification of monitoring activities shall be maintained. Records of verification activities were maintained Corrective and Preventative Action (2) (M) The responsibility and methods outlining how corrections and corrective actions are investigated, resolved, managed and controlled, including the identification of the root cause and resolution of non-compliance of critical food safety limits, and deviations from food safety requirements, shall be documented and implemented. The SQF Practitioner is responsible for maintaining records of corrective and corrective actions. Corrective actions are investigated, resolved, managed, and controlled. Resolution of non-compliances and deviations are documented. Note: There are no CCPs. Corrective and preventive log was reviewed and it tracked the date of the issue, description of non-conformity, corrective action to be taken, date to be completed, assigned to, completion date, and verified by. Records were reviewed Corrective and Preventative Action (2, 3) (M) Records of all investigation and resolution of corrections and corrective action shall be maintained.

25 Records of all investigation and resolution of corrections and corrective actions were maintained Product Sampling, Inspection and Analysis (2) The methods, responsibility and criteria for sampling, inspecting and/or analyzing raw materials, finished product and work in progress shall be documented and implemented. The methods applied shall ensure: Inspections and analyses are completed at regular intervals as required and to agreed specification and legal requirements; Inspections are conducted to ensure raw materials, work in process and finished products comply with the relevant specification, regulatory requirements and are true to label; and All analyses are conducted to nationally recognized methods or alternative methods which are validated as equivalent to the nationally recognized methods. Where external laboratories are utilized to conduct input or product analysis, the laboratories shall be accredited to ISO or an equivalent national standard. Microbiological test is not conducted on the products. Pesticide testing is conducted on the products once per season (organochorides, organophosphates, organonitrogens, carbamates, and reduced risk pesticides) Product Sampling, Inspection and Analysis (2) Records of all inspections and analyses shall be maintained. Records of pesticide results were available for review Internal Audits (2) (M) The methods and responsibility for scheduling and conducting internal audits to verify the effectiveness of the SQF System including facility and equipment inspections, pre-requisite programs, food safety plans and legislative controls shall be documented and implemented. The methods applied shall ensure an internal audit schedule is prepared detailing the scope and frequency of internal audits, ensure correction and corrective action of deficiencies identified during the internal audits are undertaken, audit results are communicated to relevant management personnel and staff responsible for implementing and verifying corrective actions; and Audit results are communicated to relevant management personnel and staff responsible for implementing and verifying corrective actions The internal audits are carried out by the SQF Practitioner to verify the effectiveness of the SQF System and monthly GMP inspections are conducted by other personnel as well. The inspection includes facility inspections, pre-requisite programs, food safety plan, and legislative controls. SQF systems audit is conducted on an annual basis. The SQF Practitioner keeps track of all the findings and verifies the corrective actions taken. Correction and corrective actions are documented and results are communicated via s and in management meetings. The SQF Practitioner keeps track of all the findings and verifies the corrective actions taken. The internal audit on the SQF System was conducted on 05/12/12.