SQF Code Edition 9 - Safe Quality Food

Management must foster a positive food safety and quality culture throughout the organization.

• Senior management food safety policy statement
• Management review minutes
• Food safety and quality culture plan
• Dedicated SQF practitioner or compliance officer appointment letter
• Resource allocation records (budget, headcount)

• Culture plan not measurable
• Reviews skipped quarterly
• Resource gaps unaddressed
• Policy not signed by senior leader

The SQF system must be reviewed by senior management at planned intervals to ensure continuing suitability.

• Senior management food safety policy statement
• Management review minutes
• Food safety and quality culture plan
• Dedicated SQF practitioner or compliance officer appointment letter
• Resource allocation records (budget, headcount)

• Culture plan not measurable
• Reviews skipped quarterly
• Resource gaps unaddressed
• Policy not signed by senior leader

Methods must be in place to ensure awareness of and compliance with current food safety legislation.

• Applicable food legislation register
• Prerequisite programmes (PRPs) documentation
• HACCP plan with CCPs identified
• Hazard analysis and risk assessment workpapers

• Legislation register outdated
• PRPs unverified
• CCPs not validated
• Hazard scoring inconsistent

Good Manufacturing Practices that form the foundation of the food safety plan must be documented and implemented.

• Applicable food legislation register
• Prerequisite programmes (PRPs) documentation
• HACCP plan with CCPs identified
• Hazard analysis and risk assessment workpapers

• Legislation register outdated
• PRPs unverified
• CCPs not validated
• Hazard scoring inconsistent

A food safety plan based on HACCP principles must be developed, implemented, and maintained.

• Applicable food legislation register
• Prerequisite programmes (PRPs) documentation
• HACCP plan with CCPs identified
• Hazard analysis and risk assessment workpapers

• Legislation register outdated
• PRPs unverified
• CCPs not validated
• Hazard scoring inconsistent

A thorough hazard analysis must identify biological, chemical, physical, and radiological hazards.

• Applicable food legislation register
• Prerequisite programmes (PRPs) documentation
• HACCP plan with CCPs identified
• Hazard analysis and risk assessment workpapers

• Legislation register outdated
• PRPs unverified
• CCPs not validated
• Hazard scoring inconsistent

Scientific or technical evidence must validate that control measures are capable of controlling identified hazards.

• Validation studies for CCPs
• Internal verification audit reports
• Corrective and preventive action register
• Product sampling, inspection, and analysis records

• Validations not refreshed
• Verification frequency low
• CAPA closure slow
• Sampling plans unrepresentative

Verification schedules must outline verification methods, responsibilities, frequency, and corrective actions.

• Validation studies for CCPs
• Internal verification audit reports
• Corrective and preventive action register
• Product sampling, inspection, and analysis records

• Validations not refreshed
• Verification frequency low
• CAPA closure slow
• Sampling plans unrepresentative

Procedures for investigating root causes and implementing corrective and preventive actions must be documented.

• Validation studies for CCPs
• Internal verification audit reports
• Corrective and preventive action register
• Product sampling, inspection, and analysis records

• Validations not refreshed
• Verification frequency low
• CAPA closure slow
• Sampling plans unrepresentative

Product sampling and testing must be conducted to verify product safety and quality compliance.

• Validation studies for CCPs
• Internal verification audit reports
• Corrective and preventive action register
• Product sampling, inspection, and analysis records

• Validations not refreshed
• Verification frequency low
• CAPA closure slow
• Sampling plans unrepresentative

A product identification and traceability system must enable trace-back and trace-forward of all products.

• Lot identification and traceability records
• Mock recall exercise reports
• Food defence (TACCP) plan
• Food fraud (VACCP) vulnerability assessment
• Allergen management plan and validation

• Mock recalls miss 100 percent reconciliation
• Defence plan not tested
• Fraud assessment narrow
• Allergen cross contact validation weak

Procedures must be documented for effective product withdrawal and recall with customer notification.

• Lot identification and traceability records
• Mock recall exercise reports
• Food defence (TACCP) plan
• Food fraud (VACCP) vulnerability assessment
• Allergen management plan and validation

• Mock recalls miss 100 percent reconciliation
• Defence plan not tested
• Fraud assessment narrow
• Allergen cross contact validation weak

A food defence plan must assess threats from deliberate sabotage or tampering and implement preventive measures.

• Lot identification and traceability records
• Mock recall exercise reports
• Food defence (TACCP) plan
• Food fraud (VACCP) vulnerability assessment
• Allergen management plan and validation

• Mock recalls miss 100 percent reconciliation
• Defence plan not tested
• Fraud assessment narrow
• Allergen cross contact validation weak

A vulnerability assessment must identify and mitigate food fraud risks throughout the supply chain.

• Lot identification and traceability records
• Mock recall exercise reports
• Food defence (TACCP) plan
• Food fraud (VACCP) vulnerability assessment
• Allergen management plan and validation

• Mock recalls miss 100 percent reconciliation
• Defence plan not tested
• Fraud assessment narrow
• Allergen cross contact validation weak

An allergen management plan must control allergenic cross-contact and ensure accurate labelling.

• Lot identification and traceability records
• Mock recall exercise reports
• Food defence (TACCP) plan
• Food fraud (VACCP) vulnerability assessment
• Allergen management plan and validation

• Mock recalls miss 100 percent reconciliation
• Defence plan not tested
• Fraud assessment narrow
• Allergen cross contact validation weak

All staff must receive food safety training appropriate to their role and responsibilities.

• Training needs analysis
• Training records by role and competency
• Document control register and revision log
• Refresher training schedule

• Training not role specific
• Records gaps
• Documents uncontrolled copies
• Refresher cadence missed

A training program must ensure employees are competent to carry out food safety functions.

• Training needs analysis
• Training records by role and competency
• Document control register and revision log
• Refresher training schedule

• Training not role specific
• Records gaps
• Documents uncontrolled copies
• Refresher cadence missed

Per SQF Code: SQFI certification + 3rd-party audit + corrective actions + CB (Certification Body) cooperation.

• SQF evidence for SQFCODE-5

• HACCP + traceability partial

Per SQF Code Edition 9 Module 2: Food Safety System Elements + Management Responsibility + Document Control + Specifications + Quality and Food Safety Manual + Internal Audits + Training.

• SQF evidence for SQFCODE-1

• HACCP + traceability partial

Per SQF Code: Food Safety Plan including HACCP per Codex + PRPs + Allergen Management + Food Defense + Food Fraud + Validation + Verification.

• SQF evidence for SQFCODE-3

• HACCP + traceability partial

Site location, layout, and construction support food safety by separating raw and finished product, controlling environmental contamination, and enabling cleaning.

• Site map showing raw, processing, and finished areas
• Construction material specifications (food contact and non contact)
• Pest and contamination assessment
• Drainage and waste flow drawings

• Raw and finished product crossing paths
• Floors and walls in poor repair
• Drainage flowing from dirty to clean areas

Personnel practices including hygiene, protective clothing, and welfare facilities prevent contamination of food during handling.

• Personal hygiene policy
• Hand washing facility design and monitoring
• PPE provision and laundering procedure
• Welfare facility inspection records

• Hand washing stations missing soap or paper towels
• PPE laundered at home
• Welfare facilities not adequate for site headcount

A documented cleaning and sanitation program defines schedules, methods, chemicals, and verification activities to maintain hygienic processing conditions.

• Master sanitation schedule by area and equipment
• Approved chemical list with safety data sheets
• Cleaning verification records (visual, ATP, micro)
• Trained sanitation staff records

• Master sanitation schedule incomplete for hard to reach equipment
• ATP results not trended or actioned
• Chemical strength not verified at point of use

A pest prevention program is documented and implemented, including monitoring devices, contract pest control services, and trend analysis.

• Pest control contract with licensed provider
• Site map showing device locations
• Monthly service reports and recommendations
• Trend analysis with corrective actions

• Pest activity recorded but not acted upon
• Devices not maintained or replaced after activity
• No trend analysis between service visits

A documented allergen management program identifies allergens present, controls cross contact, and ensures accurate allergen labeling.

• Site allergen matrix by line and product
• Cross contact cleaning validation
• Label verification at changeover and packaging
• Allergen training records

• Allergen matrix not updated when new SKU introduced
• Cross contact cleaning not validated, only verified
• Label reconciliation missed at changeover

Sites engaged in storage and distribution apply food safety controls covering receipt, storage conditions, stock rotation, and dispatch to maintain product integrity.

• Receipt inspection records (temperature, condition, lot)
• Temperature monitoring of storage areas
• Stock rotation (FEFO or FIFO) evidence
• Dispatch checks and trailer inspections

• Temperature logs with gaps during off shifts
• Stock rotation not enforced for slow moving SKUs
• Trailer inspection skipped under time pressure

Senior site management documents a food safety and quality policy, communicates it to staff, and demonstrates commitment to the SQF system through visible leadership and resource provision.

• Signed food safety and quality policy posted at site
• Management review meeting minutes
• Organizational chart showing food safety roles
• Budget evidence for food safety improvements

• Policy not signed by current senior management
• Policy not translated for non English speaking staff
• Management review held less than annually

Site management designates a qualified SQF practitioner to oversee development, implementation, and maintenance of the SQF system, with documented authority and competence.

• SQF practitioner job description
• HACCP training certificate (recognized course)
• SQF training certificate
• Backup SQF practitioner designation

• Practitioner not full time on site
• No backup designated for absences
• Training certificates expired

All documents in the SQF system are controlled, including issue, revision, distribution, and obsolete document management to ensure only current versions are in use.

• Master document list with revision dates
• Document approval and review workflow
• Distribution list per controlled document
• Archive of obsolete documents marked as such

• Multiple versions of same procedure in circulation
• No date or version on printed forms
• Obsolete documents still posted in production area

Records demonstrating compliance with the SQF system are legible, retained for the required period, and protected from loss or damage.

• Record retention schedule per record type
• Sample monitoring records (temperature, sanitation, CCP)
• Electronic record system access controls
• Backup procedure for digital records

• Retention period less than required (typically 2 years)
• Records stored in damp areas leading to illegibility
• No backup of electronic records

Specifications are documented and current for raw materials, ingredients, packaging, contract services, and finished products, and new products undergo formal development and approval.

• Master specification list for all raw materials and finished products
• Customer specifications on file
• Product development approval records
• Allergen declaration on each finished product specification

• Specifications missing for some raw materials
• Customer specifications not updated when contract changes
• Allergens not declared in specifications

Contract service providers and manufacturers are approved, monitored, and meet specifications to ensure outsourced activities do not compromise food safety.

• Approved supplier list with criteria
• Contracts including food safety obligations
• Supplier performance review records
• GFSI certificates for critical suppliers

• New suppliers used before approval
• Contracts silent on food safety responsibilities
• Performance reviews not documented annually

A documented food safety plan is developed and implemented using HACCP principles, including hazard analysis, CCP identification, critical limits, monitoring, corrective action, verification, and record keeping.

• HACCP team list with qualifications
• Process flow diagrams verified on site
• Hazard analysis with rationale for CCPs and PRPs
• Critical limit validation evidence (scientific or regulatory)

• Flow diagrams not verified annually on the floor
• Critical limits not validated, only set by industry convention
• HACCP team lacks required disciplines

Verification activities are documented to confirm the food safety system is implemented and effective, including verification schedules, responsible persons, and corrective actions.

• Verification schedule across CCPs and PRPs
• Internal audit plan and reports
• Calibration records for monitoring equipment
• Trend analysis of verification results

• Internal audit conducted by personnel not independent of audited area
• Verification activities documented but not analyzed for trends
• Calibration certificates expired

Procedures are in place to identify, correct, and prevent recurrence of non conforming product, processes, or system failures, including root cause analysis.

• Corrective action log with status and due dates
• Root cause analysis examples (5 Why, fishbone)
• Verification of effectiveness for closed CAPAs
• Trend analysis of corrective actions

• Corrective actions correct symptoms but not root cause
• No verification that the corrective action worked
• Same issue recurring without preventive action

A food defense plan is developed and implemented to protect food from intentional adulteration, including vulnerability assessment and mitigation strategies.

• Food defense vulnerability assessment
• Mitigation strategies for identified vulnerabilities
• Food defense plan annual review
• Personnel awareness training records

• Vulnerability assessment focused only on external threats
• Mitigation strategies generic, not tied to assessment
• No annual review of plan

A food fraud vulnerability assessment and mitigation plan is in place to address economically motivated adulteration of raw materials, ingredients, packaging, and finished products.

• Food fraud vulnerability assessment per ingredient
• Mitigation plan with verification activities
• Supplier verification testing for high risk ingredients
• Annual review of assessment

• Assessment covers some but not all ingredients
• Mitigation plan generic, not risk based
• No testing for known adulterants in high risk ingredients

Critical limits, food safety controls, and process steps are validated to ensure they are effective in controlling identified hazards.

• Validation study reports for critical processes (thermal, pH, water activity)
• Scientific literature or regulatory references
• Re validation schedule and triggers
• Equipment qualification records

• Critical limits adopted from industry without site specific validation
• No re validation after equipment change
• Validation reports lack scientific rationale

Procedures define product and environmental sampling, inspection, and analysis to verify the food safety and quality system, including frequency and methods.

• Sampling and testing plan by product and pathogen
• Lab accreditation certificate (ISO 17025) for external labs
• Internal lab method validation
• Trending and review of results

• Environmental monitoring program lacks rationale for sampling sites
• Lab results received but not trended
• Internal lab methods not validated

Documented recall and withdrawal procedures are in place and tested at least annually to remove non conforming product from the supply chain.

• Recall procedure with roles and contact list
• Mock recall results within past 12 months
• Traceability test forward and backward (one step up, one step down)
• Customer and regulator contact list

• Mock recall not achieving 100% reconciliation in defined time
• Traceability one direction only
• Contact list outdated

All raw materials, ingredients, work in process, finished products, and rework are identified throughout receipt, storage, production, and dispatch.

• Lot coding procedure
• Sample labels (received, in process, finished, hold, release)
• Rework identification procedure
• Inventory management system records

• Rework not lot coded
• Hold status not visibly different from released
• Lot coding inconsistent across product lines

A traceability system records the movement of raw materials, packaging, work in process, and finished products through receipt, processing, and distribution.

• Lot to raw material traceability records
• Mass balance reconciliation per lot
• Traceability test results
• Distribution records by lot

• Mass balance not reconciled, with shrinkage unexplained
• Trace test not completed in defined time (typically 4 hours)
• Distribution records held by third party with no access

Personnel performing tasks affecting food safety and quality are trained and competent, with a documented training program covering induction and ongoing training.

• Training matrix by role
• Induction training records for new staff
• Competency assessment evidence (observation, test)
• Annual refresher training records

• Training matrix outdated as roles change
• Training delivered but no competency check
• Temporary or contract staff not trained

Per SQF Code Module 11 (Food Sector Categories): premises + facilities + personnel + cleaning + sanitation + waste + pest control + temperature.

• SQF evidence for SQFCODE-2

• HACCP + traceability partial

Per SQF Code: Traceability + Mock Recall + Crisis Management + Customer Complaints + Records.

• SQF evidence for SQFCODE-4

• HACCP + traceability partial