*If you are not sure which Code applies to your company, we recommend confirming with your Certification Body.

Then there were some changes to Part A – Implementing and maintaining the code. A change was made to the scoring of audits, a major nonconformance was changed from 10 points to 5 points. Another change was to eliminate the requirement for the desk audit. A certification body may offer optional desk audits, but it is not an official part of the audit or audit records. Audit duration has been changed and is now based on the GFSI durations.

Finally, there are changes to the requirements section of the code. Overall, there has been some reorganization of requirements, some have been moved from one section to another. There has been an effort to remove duplication, so some requirements have been deleted from a section but may still be listed in another spot of the code. And most important, there have been additions to the requirements.

A few of the more major additions are the requirements for implementing a food safety culture, for internal laboratories doing food safety related testing to meet the relevant requirements of 17025 (but not a requirement for internal laboratories to be certified to ISO 17025), and for label reconciliation, that is evaluating and checking labels to make sure they are correct and match the product as they are used in production.

Details on changes to module 2:

The code now starts with Management Responsibility. In the past version it started with a section on the food safety policy, but the first requirement in management responsibility is to prepare and implement the food safety policy. The important new addition to the requirements for the policy is to outline the commitment of all site management to establish and maintain a food safety culture in the site. The policy must still include a commitment to supply safe food and establish and improve the food safety management system and to comply with regulatory and customer requirements.

Several items are no longer called out as requirements for the food safety policy:

• Methods used to comply with its customer and regulatory requirements and the site’s commitment to establish and review food safety objectives are not specifically required in the policy.

This is followed by the requirement to lead and support a food safety culture within the site.  It works in (with some rewording) a few of the requirements of management commitment from version 8.1 including making sure that staff are informed of their food safety and regulatory responsibilities, are aware of their role in meeting the requirements, and are informed of their responsibility to report food safety problems to personnel with authority to initiate action. Adequate resources are available to meet food safety objectives. Food safety culture performance must be included in the management review meetings.

New requirements in the food safety culture clause include the addition of performance measures in addition to objectives, Employees must be positively encouraged and required to notify management about actual or potential food safety issues; and empowered to act to resolve food safety issues within their scope of work.

One other notable new requirement in the Management Responsibility section is that in addition to the primary SQF practitioner, there must also be a substitute practitioner, and they must both meet the training and competence requirements and job position requirements.

Document Control

A few new things are included in the list of what the food safety management system must include. These additions are: Food safety regulations that apply to the manufacturing site and the country of sale, raw material, ingredient, packaging, and finished product specifications, and process controls that impact product safety.

There is also a requirement for review of the system specified here: Food safety plans, Good Manufacturing Practices, and all relevant aspects of the SQF System shall be reviewed, updated, and communicated as needed when any changes implemented have an impact on the site’s ability to deliver safe food.

Under document control, it no longer mentions a register of documents and amendments.

Retention of records now includes, in addition to meeting customer and regulatory requirements, retention periods must also be at least the minimum of the product shelf-life or established by the site if no shelf-life exists.

Specifications, Formulations, Realization, and Supplier Approval

This section now includes supplier approval, which had its own clause in SQF 8.1. Requirements are similar to SQF 8.1.

• Develop and create formulations – must be by authorized person to meet intended use for food safety. Notify management or authorized person of any changes.
• Service providers now under 2.3.0.3. Notify site if changes are made to ingredients that affect food safety.
• 3.4.3 Addresses verification of raw materials – shall include certificates of conformance, certificates of analysis, or sampling, and testing. The verification frequency shall be identified by the site.
• Co manufacturers includes high risk, low risk, third party distributors
• Moved approved supplier
• Moved labs into module 2
• Moved nonconforming equipment into PRP from module 2
• Positive release – if doing procedure in place
• 6 more emphasis on label control and labelling requirements
• 6 Crisis management and testing of withdrawal systems moved together
• 7 grouped food defense and fraud
• Allergen management – no gluten labeling
• 9 streamlined

Product release shall include a procedure to confirm that product labels comply with the food legislation that applies in the country of manufacture and the country(ies) of use or sale if known (refer to 2.4.1.1).If product is packaged and distributed in bulk or unlabeled, product information shall be made available to inform customers and/or consumers of the requirements for its safe use.

In the event that the site uses positive release based on product pathogen or chemical testing, a procedure shall be in place to ensure that product is not released until acceptable results have been received.In the event that off-site or contract warehouses are used, these requirements shall be effectively communicated and verified as being followed.

Environmental monitoring

Outline the locations in which samples are to be taken and the rotation of locations as needed; and

Environmental testing results shall be monitored, tracked, and trended, and preventative actions (refer to 2.5.3.1) shall be implemented where unsatisfactory results or trends are observed.

Internal Audits

Changes implemented from internal audits that have an impact on the site’s ability to deliver safe food shall require a review of applicable aspects of the SQF System

Traceability

Procedures shall be implemented to ensure that label use is reconciled, and any inconsistencies investigated and resolved.

Product changeover and label reconciliation records shall be maintained.