Episode 7: CAPA Programs in GFSI

In facilities operating under an SQF program, the SQF Practitioner (or substitute practitioner) must be made aware of all nonconformances related to the SQF system. Additionally, when a root cause analysis is performed, the SQF Practitioner must approve of the investigation in writing. Trending of nonconformances should be presented to site leadership during the required Management Review meetings.

Facilities that operate under a BRCGS program are expected to document nonconformances involving both food safety and product quality; therefore, deviations involving product specifications should be included in the site’s CAPA program. A CAPA Team is expected to contribute to CAPA decision making activities, with results of these activities reviewed by Senior Management.

In facilities operating under an FSSC 22000 program, the implementation of operational prerequisite programs, or oPRPs, is required and should include corrective actions as key metrics. The core concept of communication must be clearly applied to corrective actions and include activities such as documented training for personnel involved in corrective actions. Corrective actions and investigations must be presented to Top Management in order to meet the improvement requirements of FSSC 22000.

Facilities that operate under a PrimusGFS program must have a Notice of Unusual Occurrences and Corrective Actions (NUOCA) log as part of the communications of corrective actions. The concept of unusual occurrences is used in place of nonconformances due to the inherent variations of weather and living systems within a farm or indoor agricultural facility. PrimusGFS does use the concept of nonconformance where it relates to employees, and a disciplinary system is required for such instances.

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