SQF from Scratch: 2.2.1 Food Safety Management System, 2.2.2 Document Control, 2.2.3 Records

2.2.1 Food Safety Management System, 2.2.2 Document Control, 2.2.3 Records

 

If someone says that they want to become SQF certified, what do they assume that means?

 

A whole bunch of paperwork!

 

These elements are the “where is all the stuff” portion of the code. It’s not the sexiest part, nor the most difficult to interpret, but SQF practitioners need to organize all of this information in a way that’s first useful to the company as well as auditable.

 

Let’s get into it!

 

The code:

 

2.2.1 Food Safety Management System

 

2.2.1.1 A food safety management system shall be documented and maintained in either electronic and/or hard copy form. It shall outline the methods the site will use to meet the requirements of the SQF Food Safety Code for Manufacturing, be made available to relevant staff and include:

 

i. A summary of the organization’s food safety policies and the methods it will apply to meet the requirements of this standard;

ii. The food safety policy statement and organization chart;

 

iii. The scope of certification;

 

iv. A list of the products covered under the scope of certification;

 

v. Food safety procedures, pre-requisite programs, food safety plans; and

 

vi. Other documentation necessary to support the development and the implementation, maintenance and control of the SQF system.

 

2.2.1.2 All changes made to food safety plans, Good Manufacturing Practices and other aspects of the SQF System shall be validated or justified.

 

2.2.2 Document Control

 

2.2.2.1 The methods and responsibility for maintaining document control and ensuring staff have access to current documents shall be documented and implemented.

 

2.2.2.2 A register of current SQF System documents and amendments to documents shall be maintained.

 

2.2.2.3 Documents shall be safety stored and readily accessible.

 

2.2.3 Records

 

2.2.3.1 The methods and responsibility for undertaking monitoring activities, verifying, maintaining and retaining records shall be documented and implemented.

 

2.2.3.2 All records shall be legible and suitably authorized by those undertaking monitoring activities that demonstrate inspections, analyses and other essential activities have been completed.

 

2.2.3.3 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.

 

What’s the point? How is this making our product safer?

 

If it doesn’t happen on paper, it didn’t happen. And if it didn’t happen, it shouldn’t be on the paperwork!

 

In a perfect world, we wouldn’t need SOP’s, certification packages, HACCP methodology, consultants, or online classes to help generate paperwork for our systems. We could just print out a copy of the code and keep it on site. Everyone’s plant, equipment, processes, and personnel would be identical, auditing would be simple, and we all would know exactly how to produce food with zero risk of safety or quality issues.

 

…okay, I’m back. But it was nice to be there for a moment.

 

In reality, to implement these systems companies need to figure out how to meet the intent and requirements of the code in a way that makes sense for the products, facilities, and people involved. Using the code as a guide to apply “best practices” to individual situations is where the real value of SQF lies. Not in the fancy certificate, but in the assurance that the company has systematically taken international best practices and figured out how they can be applied to their unique situation.

 

What am I being asked to do?

 

I’m going to look at the code section by section here, but keep in mind that they’re a little redundant and all interrelated, so we may jump around a bit.

 

2.2.1.1 A food safety management system shall be documented and maintained in either electronic and/or hard copy form. It shall outline the methods the site will use to meet the requirements of the SQF Food Safety Code for Manufacturing, be made available to relevant staff…

 

 

The” Food safety management system” is the name of the pile of SOP’s, training, production paperwork, and other records created to support the SQF system, food safety, and local regulatory requirements. It doesn’t need a name like “Fur Farm and Fork’s Food Safety System 2000”. It’s kind of like saying “Regulations in [country]”. It’s a broad blanket covering all the stuff that is done to meet the requirements of the code.

 

The system documents need to be available in a digital format, binder, file cabinet, or book to all staff. That can be a bit confusing given the large scope of documentation included, but in short, if someone wants to see the food safety plan or truck inspection procedures, they need to be easily found by employees other than the SQF practitioner.

 

i. A summary of the organization’s food safety policies and the methods it will apply to meet the requirements of this standard;

 

ii. The food safety policy statement and organization chart;

 

iii. The scope of certification;

 

iv. A list of the products covered under the scope of certification;

 

v. Food safety procedures, pre-requisite programs, food safety plans; and

 

vi. Other documentation necessary to support the development and the implementation, maintenance and control of the SQF system.

 

As I described above, the food safety management system includes everything that supports the code. That doesn’t mean that the procurement team has to keep their vendor documentation in the same place, but it does mean that the supplier approval register needs to be readily available (usually by referencing the location in the applicable SOP).

 

It’s a little silly that SQF calls out some of these code portions such as “food safety policy statement and organization chart”. That’s a redundancy because from the earlier sections of the code Management Responsibility and Food Safety Policy, we already knew that we had to have these things and they needed to be communicated throughout the facility. For the sake of focusing on what what’s novel in this section of the code, I’m going to lump together a bunch of these requirements and say that we should already have documented and included them in the system:

 

i. A summary of the organization’s food safety policies and the methods it will apply to meet the requirements of this standard;

 

ii. The food safety policy statement and organization chart;

 

v. Food safety procedures, pre-requisite programs, food safety plans; and

 

vi. Other documentation necessary to support the development and the implementation, maintenance and control of the SQF system.

 

2.2.1.2 All changes made to food safety plans, Good Manufacturing Practices and other aspects of the SQF System shall be validated or justified.

 

2.2.2.3 Documents shall be safety stored and readily accessible.

 

All of the above sections are already outlined in their own portions of the code. Each one says that records should be maintained, and changes should be documented along with justifications for the change as needed. All of this should already be covered, provided we fulfilled the requirements in that individual section of the code.

 

Let’s focus on those components that are unique.

 

iii. The scope of certification;

 

iv. A list of the products covered under the scope of certification;

 

The “scope of certification” isn’t defined in the main manufacturing code but in the “implementing and maintaining” section that talks about how the process. To summarize, the scope of certification are the portions of the business that will be “SQF Certified”. This includes the entire site and grounds (unless exemption is approved by the CB), and any products promoted as being covered by the certification. These products will define the “food sector categories” that the site is SQF certified in. Often this is included in a “scope” section of SOP documents or food safety plan.

 

If the site contains exemptions, then it may be more helpful to identify those products under the scope of certification in a list of some kind, such as the one required in bullet iv. This does not need to be a separate document. If there is already a list of products and product specifications, which also indicate whether the product is in scope or not, then the requirement is already met! Normally the food safety plan or finished product specification registerwill already include a list of products.

 

 

Do not duplicate things like product lists unless it benefits the business to do so. Follow the golden rule and avoid documentation redundancy.

 

2.2.1.2 All changes made to food safety plans, Good Manufacturing Practices and other aspects of the SQF System shall be validated or justified.

 

2.2.2.2 A register of current SQF System documents and amendments to documents shall be maintained.

 

Revisions to documentation represent changes to how things are done, and hopefully those changes didn’t come down to “we decided to stop washing the equipment all the time, it’s annoying.”

 

This is an area where everyone has a few different approaches, but a common one I see is including a revision history at the end of each controlled document like so:

 

I addressed this in a previous post on document control; this information is rarely if ever relevant to the document user, and with so much documentation, it’s maintenance intensive to keep something like this on every single file (even small ones like a sanitation instruction sheet).

 

I like to keep a central revision database where I can document changes I make on any document, as well as justification for those changes as needed.

 

When combined with saved older versions of the documents, this is a helpful, searchable tool and easily meets the intent of the code. Don’t forget to document any validation data as necessary.

 

2.2.2.1 The methods and responsibility for maintaining document control and ensuring staff have access to current documents shall be documented and implemented.

 

This language should be familiar to us by now. Every SQF element requires us to identify “the methods and responsibility” for meeting the intent of the code. Just like there should be an SOP for sanitation, there should be a policy and procedure for document control. Who controls the revisions and makes sure they’re distributed? How do we ensure old copies are purged from the building? It’s not a complicated SOP, but it is an important one to make sure the documentation is…well…controlled.

 

In a paper-only operation this is simple, identify a person (e.g. SQF practitioner) who is responsible for routing new controlled documents for approval, documenting the changes, replacing old versions in the register once approved, and getting rid of the old versions. Modify the details depending on what portions are paper or digital, and execute it as written.

 

For tips and tricks to make controlled documents simpler and less painful to update, check out “Document control – make it less of a chore and more of an asset”.

 

2.2.3.1 The methods and responsibility for undertaking monitoring activities, verifying, maintaining and retaining records shall be documented and implemented.

 

The methods and responsibility for reviewing records is again going to be covered under individual code clauses. For example, the food safety plan will clearly indicate who is responsible for monitoring CCP’s/Preventive Controls and where that will be documented. In your procedures, provide blanket coverage by using the terminology “SQF practitioner or designee” to indicate that the SQF practitioner will subsequently delegate review and signatures as needed.

 

2.2.3.2 All records shall be legible and suitably authorized by those undertaking monitoring activities that demonstrate inspections, analyses and other essential activities have been completed.

 

Every time someone records information on a record, require their initials or signature. That’s part of the heavy “documentation” part of SQF we’re always talking about. It’s no longer sufficient to say it happened, we need to know who did it and took responsibility for it. And yes, you’ll need to correct people with poor handwriting to make sure that we know it was 66 degrees, and not 60.

 

2.2.3.3 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.

 

It’s simple to have the document control SOP include record retention policies as well. Retention periods should include any regulatory requirements (e.g. those for financial records or food regulatory agencies), and also cover the entire shelf life of the products so that they can be referenced as part of customer complaint investigations (if it’s still on shelves 5 years later, the production records need to be available 5 years later).

 

How will this be audited?

 

Auditors are going to look for the policies and procedures that detail how documentation is updated and controlled in the facility. They want to see strong revision control (e.g. no copies of old stuff on the floor), signatures, and evidence of verification on important monitoring records. The practitioner should be able to find the history of documentation changes in a record, log, or on the documents themselves, and that the changes were justified and validated as necessary when they impacted food safety or compliance.

 

Much of this section of the code will be evaluated in the same manner as management responsibility and management review. Is the “food safety management system” or manual something the SQF practitioner makes to pass the audit, or is it a collection of materials used to implement the code effectively at the site? Take each section of the code seriously, create a policy/procedure and relevant documentation for monitoring, and have those materials ready for review.

 

If the system is real, and the SQF practitioner knows it well enough to pull up whatever the auditor wants to see (and it’s not missing!), there will be no issues with this section of the code.

 

2.2.1, 2.2.2, and 2.2.3 are there to support the rest of the code and the SQF philosophy of “do what you say and say what you do”. The entire point of the certification is that an auditor has come on site to verify that the organization has implemented the requirements of the code, but in order to do so companies need to be able to demonstrate that the food safety management system operates year-round, not just on the day of the audit.

 

It is a pile of paperwork. But hopefully it’s paperwork that represents tangible and effective work that was completed, not just copied bits of code.

 

Author Biography:

 

 

Austin Bouck is a food safety consultant and manufacturing supervisor in Oregon, USA. You can find more food safety resources and discussion on his website, Fur, Farm, and Fork, as well as contact information for consulting services.