SQF Code FAQs
What does the supplier have to provide for the mock recall records, as is required in element 220.127.116.11 iii of the SQF Code?
The auditor is expected to check the records the supplier has compiled during the annual test of the recall program.
Evidence may include:
- A recall committee is established and all members understand their roles and responsibility;
- The methods and responsibilities for notifying customers, SQFI, the certification body, regulators and other essential bodies are identified;
- The recall/withdrawal system has been tested annually;
- The recall/withdrawal system meets regulatory and customer requirements;
- Communication has been tested during an actual or test recall;
- Investigations into the root cause of actual recalls/withdrawals have been conducted;
- Corrective actions have been taken on identified deficiencies in the recall/withdrawal (refer 2.5.5)
What are the parameters and what methods are required for air purity testing on compressed air to address element 11.5.7?
Purity is defined in the SQF Code (Appendix 2: Glossary) and means the absence of contaminants that could cause a food safety hazard. Pure air means the air is free of risk of cross-contamination to the products. Essentially, the air must not contribute any contamination to the product.
Food processing facilities need to operate from a fundamental assumption that compressed air can be a source of chemical and microbiological contamination. The site must verify and validate that the compressed air used in the facility is appropriate for use and not a source of contamination. Where compressed air comes in contact with exposed product, direct product contact surfaces and interior surface packaging, the air compressor should use food grade oil.
Preventive maintenance programs need to ensure that an appropriate filtration program is in place at the point of use and the filters are cleaned/changed at a frequency appropriate to the product and process or following any maintenance to air supply source or equipment. Maintenance must be done in a hygienic manner. Air should be filtered at the point of use for most operations (recommended filter size at point of use is 0.1 micron, or as determined as appropriate by a risk analysis). Nozzles and air hoses are to be in good condition, properly repaired and maintained in a hygienic state (e.g., cleaned and sanitized). Hoses and nozzles are to be kept off the ground.
Testing is to be conducted to validate the air-filtration control system for the compressed air is effective based on the risk to the product, but at a minimum of once a year. Testing can be done in-house or by a contracted party. Test requirements and number of samples will be based on the risk to the product and process. Microbiological testing can include testing for aerobic plate count and/or indicator organisms as appropriate to the operation. Testing for moisture should be considered if moisture is a potential risk to the product (e.g., dry operations). Aseptic sample collection should be used. There are a wide variety of measures available including the use of air sampling equipment, use of sterile sponges, membrane filtration and others.
Is the supplier required to notify their certification body of USDA issued Noncompliance Records (NRs)?
No. As outlined in Part A, 5.3 of the SQF Code, the certification body is to be notified only for recall events requiring public notification, such as Class l or Class ll recall or the receipt of a regulatory warning letter.
Who is the supplier required to contact and list as a contact in the event of a recall?
As outlined in Part A, 5.3 of the SQF Code, upon identification of a food safety event that requires public notification (such as Class I or Class II recall, or the receipt of a regulatory warning letter), SQF certified supplier shall notify the certification body and the SQFI in writing at email@example.com within twenty-four (24) hours of the event. As stated in the SQF Code elements 18.104.22.168 and 22.214.171.124iv, SQFI and the Certification Body shall be listed as an essential body.
What are the requirements to be an SQF practitioner? Are individuals required to register or certify as a practitioner?
The education and knowledge requirements of an SQF practitioner are outlined in SQF Code, edition 7.2 in element 126.96.36.199. They are as follows:
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 training course;
- Be competent to implement and maintain HACCP based food safety plans; and
- Have an understanding of the SQF Code their level of certification and the requirements to implement and maintain SQF System relevant to the supplier scope of certification.
As noted, there are no specific requirements for training (other than HACCP) or testing. The practitioner must demonstrate knowledge of the current version of the SQF Code. Some choose to do this by either successfully completing an Implementing SQF Systems training course, or by successfully completing an Implementing SQF Systems examination. Additionally, the practitioner may adequately demonstrate knowledge of the Code by having an effectively-implemented SQF System or appropriately address questions posed by the auditor at the time of the certification audit.
Additionally, note that there is no requirement to register or “certify” as a practitioner. A person in the role of a practitioner must meet the requirements of 188.8.131.52 and 184.108.40.206 of the SQF Code. Therefore there is no need to “re-register” or “recertify,” nor is there a need to retake either the Implementing SQF Systems course or the Implementing SQF System examination if already successfully completed.
Is a supplier required to undergo a full document audit when moving from level 2 to level 3?
A document (or desk) audit is only required for the supplier’s initial certification audit, irrespective of level. A separate document audit is not required if the supplier chooses to progresses from level 1 to level 2, or from level 2 to level 3. Similarly, a separate desk audit is not required when the supplier changes product or process scope. Suppliers moving to a different level (e.g. from level 2 to level 3 or from level 3 to level 2) must wait until their next re-certification audit date.
When a supplier changes scope, including level, and in fact at all recertification audits and surveillance audits, changes to documentation shall be reviewed as part of the facility audit.
Section 2.5.6 of the SQF Code requires outside laboratories to be accredited to ISO 17025 or equivalent. What is equivalent and how is that determined?
ISO 17025 is the international standard for laboratory accreditation. It is a GFSI requirement that external analysis of inputs is performed by laboratories that are accredited to this international standard. However, some countries do not recognize ISO 17025, and have national laboratory accreditation standards in place.
Equivalence therefore applies to national standards that are used in-country, instead of ISO 17025.
What are the qualifications of an SQF auditor?
The criteria to register as an SQF auditor can be found via the SQF Professional tab of the SQF website.
In summary, an individual seeking to register as an SQF auditor will need to provide evidence of the following:
- Complete a registered Management System Lead Auditor training course (i.e. RABQSA, IRCA approved) of 40 hours duration.
- Complete SQF scheme owner training (e.g., Auditing SQF Systems) of 3 days duration. Note: Applicant may choose take the SQF Lead Auditor training course (of 5 days duration) to meet the requirements of 1 and 2 above.
- Successful completion of a HACCP training course with certificate issued. HACCP training must be a 2 day course with a final assessment and a certificate.
- Have at least 160 hours of food safety and/or quality auditing in the food industry (20 audit days).
- Have at least 5 years work experience in food safety, HACCP program management and/or quality systems management within the food industry.
- For each high risk Food Sector Category (FSC) requested for registration, the applicant shall demonstrate 2 years work experience in food safety and/or quality management within food industry within requested FSC, or 160 audit hours within requested FSC, or a combination of work experience and audit experience for each FSC requested.
- Must be either be employed by or contracted to a SQF licensed certification body (if contracted, then the applicant must be sponsored by at least one SQF licensed certification body).
To apply to register as an SQF auditor, the candidate will need to submit evidence to support the requirements outlined above via an online application. The online application can be accessed via the “SQF Professional” tab of the SQF website, or by clicking here.
For more information on the application process, including templates for audit logs and work experience, please visit the Become an SQF Professional page of the SQF website.
When can a supplier change to a different certification body during the whole SQF certification process?
The requirements for changing to a new certification body can be found under Part A, section 5.2 of the SQF Code, edition 7.2.
If an SQF supplier is certified under one certification body (CB) and would like to use a different CB, the supplier can change CBs after one certification cycle and cannot be under a surveillance audit schedule. The supplier must have closure of all outstanding non-conformities and the certification cannot be suspended or under threat of suspension or withdrawal. Suppliers that require a surveillance audit are permitted to change certification bodies only after the surveillance audit is conducted or by written approval from the SQFI senior technical director.
When a supplier changes certification bodies, the certificate of registration issued by the previous certification body remains valid until the expected expiration date. The certification number and re-certification date are transferred with the supplier to the new certification body.
It will be the responsibility of the certification body to review of the supplier’s certification to:
- Confirm the certificate of registration is current, valid and relates to the SQF Systems so certified.
- Confirm the supplier’s food sector category falls within the new certifier’s scope of accreditation.
- Confirm any complaints received are actioned;
- Review the supplier’s audit history (where the supplier can demonstrate such history to the satisfaction of the new certifier by way of copies of audit reports completed by any former certifier) and the impact of any outstanding non-conformities.
- Confirm the stage of the current certification cycle.
What happened to the pre-requisite programs (PRPs) that were in section 6 of the SQF 2000 Code? What PRPs need to be verified according to 220.127.116.11?
The pre-requisite programs that were addressed under section 6 of the SQF 2000 Code did not go away. They have been integrated with other food safety fundamentals to avoid duplication. All PRPs must be documented, implemented and verified as per 18.104.22.168. Keep in mind that all food safety fundamentals (i.e., PRPs), critical limits and other food safety controls need to be verified as per 22.214.171.124.
Why have the elements for the allergen management program, the approved supplier program, and the site’s training program been moved into module 2?
Allergen management, approved suppliers and training are considered to be important parts of the supplier’s SQF System and identified as System Elements, which are all located in module 2 of the SQF Code. Allergen management (2.8.2) is not a stand-alone program, but is part of the site’s food safety plan as well as many of the food safety fundamentals. The site’s approved supplier program (2.4.5) is now incorporated into module 2 within the “Incoming goods and services” section and the training program (2.9) is now considered an essential System Element. As with all SQF System Elements, these programs must be effectively documented and implemented if applicable, and verified to ensure effective implementation.
Why are PRPs not required to be validated? Instead, they are required to be verified as described in 126.96.36.199. Can you provide clarification as to whether PRP’s require formal validation?
The term “validation” specifically applies to control limits and requires scientific analysis to demonstrate that control limits are effective. Based on advice from our stakeholders, we reworded the requirement for pre-requisite programs to state that the PRPs be “confirmed to ensure they achieve the required result rather” than “validated.” The intent is to clarify the intent of the Code so that the effectiveness of the PRP is being met.
Section 188.8.131.52 in the SQF Code specifically identifies paper towels be provided at hand wash stations. Would hot air hand dryers or “air blades” be suitable alternatives?
The SQF Code specifically states paper towels because paper towels physically remove microorganisms from hands. Additionally, air hand dryers are not always an effective means of drying hands and in some instances can be a source of contamination. If a site desires to use air-hand dryers, the effectiveness must be verified. This means that the equipment used to dry the hands must be able to dry the hands without further contamination. For example, many times the air dryers do not completely dry the hands leading employees to dry their hands using other, unsanitary means (e.g., pants, unclean towel, etc.). Additionally, the hand dryers themselves may be unclean, including the air or other parts on the machine, or there may not be enough hand driers to adequately service all plant personnel.
Suppliers using air blades need to conduct a risk analysis to identify the risk and how the risk will be controlled through this alternative method. The auditor will require the supplier to demonstrate that the air hand dryer effectively dries the hands without further contamination and does not contaminate the product or environment.
What is a contract manufacturer?
A SQF certified supplier can contract co-manufacturers co-packers to produce product that comes under their SQF registration and certification, provided they comply with this Code requirement. The supplier must have a means of showing that these contract manufacturers follow the supplier’s product safety and if level 3, quality parameters and meet customer specifications. A contract manufacture may not be directly certified, but must be monitored by the SQF certified supplier to ensure that products included in the supplier’s SQF certification are manufactured according to SQF criteria. The supplier could mandate that all co-packers must have an SQF or GFSI certification as a means of reducing risk, but must provide assurance co-packers and co-manufacturers are meeting customer requirements/specifications.
To satisfy meeting the requirements under 2.3.4, it is expected that all contract manufacturers meet the requirements under the approved supplier program (2.4.5) which include as a minimum the key elements under 184.108.40.206. In their policy manual, it would be expected to see a procedure on how contract manufacturers are identified and establish a verification schedule to assure co-packers and co-mans are meeting the specification requirements agreed upon between the supplier and their customer. If an SQF certified supplier has a strong and acceptable approved supplier program the majority of the requirements for contract manufacturers are likely to be acceptable. It is the responsibility of the SQF supplier to have this well documented and prove that they have controls in place that assure the products supplied are meeting specification, such as through verification schedules, sampling plans or third party audits. The supplier must be able to assure that changes to customer specifications are not only fully documented internally and verification that product produced reflects the required change.
Where can the canning requirements of the SQF 2000 Code, 6th edition be found in the SQF Code, edition 7.2?
Section 7 of the SQF 2000 Code was discussed at length by the Code review committee. The position the committee took was that many concepts addressed in the canning/thermal processing section of the 6th edition were redundant and adequately covered by modules 2 and 11 of edition 7.2. The auditor will still assess the supplier using the concepts of section 7 of the SQF 2000 Code against the elements of the 7th edition Code and apply them to the canning/thermal processing industry.
SQF will work with applicable industry groups to develop sector-specific guidance to specifically offer interpretations of modules 2 and 11 of the Code.
Module 15 is not currently available. Can a catering or retail operation be SQF certified? What modules are to be used?
Module 15 is currently under development or is in draft form and under review by the SQFI Technical Advisory Committee. This module will not be available for use until it is approved and published in a later version of the SQF Code. Until that time, facilities in food sector category 23, 24 can implement modules 2 and 11.