Changes to the SQF Code, Edition 7.2. Proposed Action Plan from TAC Responses
Issue
1) Establishing the scope of certification
The SQF audit is site and product specific
allowing facilities to exempt out areas for
certification. It has been suggested that SQF
require that facilities have the entire site of the
facility in the scope of certification and prevent
the site from exempting out areas from the
scope of certification. Recent edition to 7.1
requires the auditor to walk around the entire
facility regardless of the scope however, this
discussion warrants further review to include
discussion about those facilities that currently
have exempted areas, facilities that have
vertically integrated processes (i.e. nut roaster,
nut processor) or facilities that have buildings
such as distribution buildings within the same
management but off the facility property.
2) Product list on the SQF Certificate
Currently, the SQF certificate identifies product that
is certified. This has been causing many requests
from Certification Bodies to add products to fit their
customer’s requirements. Should SQF identify on the
certificate product that is not included in the scope
of certification?
Summary of Responses

Some suggested scenarios for discussion

USDA Dual jurisdiction plants (FDA and USDA products produced under one
roof)

Joint ventures under one roof

Manufacturer with two or more production buildings within a complex

Several manufacturers under one roof

Several manufacturers in adjoining buildings

Manufacturing site within another manufacturing site

As long as “out of scope” operations are not negatively impacting “in scope” operations from
a food safety/quality perspective than I don’t see what needs to change in the code at this
time.

Just because manufacturing is on the same property, does not mean it is under the same
scope.

Following this rule under a Food Safety principle would also disallow a plant from exempting
one line at their facility versus another.

I suggest to clearly define area for certification and the requirements in order to get it
certified.

SQF should require that facilities have the entire site of the facility in the scope of
certification.

Is the emphasis for facility and grounds rather than growing areas?

Other GFSI recognized programs (eg BRC) allow for exemption of products/areas out of the
scope of certification but places rules around them. This may put SQFI at a competitive
disadvantage.
 I think this would be very difficult to keep up with – and it seems counter intuitive to list
what is not covered versus what is covered.
Proposed Actions (Bill’s Ideas)

Continue to allow for exemptions however,
provide rules and requirements for when
exemptions shall be allowed.

The audit report should contain the process
and locations

The certificate should be changed to list the
EXACT products that are produced in the
facility (i.e. Wendy’s Seasoning Blend).

Recommended solution is incorporated in
the above suggestion.
 I think adding non-certified products could be a moving target for SQFI
 Companies with lots of brands are constantly changing their product mix.
 I wouldn´t add the product list, but I will set something in order to assure that if there´s an
area certified, just the products done there are considered.
 SQF is certifying a facility & processes/system on the property…not products. So I would
provide a reference list of what products are produced in the facility/system
 I believe it is important this be allowed in order to provide flexibility to the suppliers to
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Changes to the SQF Code, Edition 7.2. Proposed Action Plan from TAC Responses
exclude products and allow for clear communication to customers on the certificate so that
they fully understand that though the excluded product is manufactured at the certified site,
the product is not covered.
3) Seasonal Product
Currently, there is no variability for season product
for the recertification or surveillance audit. The SQF
will need to include criteria as to how the audit
should be managed for seasonal products.

Provisions should also state that the audit needs to take place during operational
periods and a limit on how far out in time you can go.

Is the process or a specific product seasonal? I mean does it change in a way that all SQF
system changes? If not this doesn´t make sense.
Yes, SQF should include criteria on how the audit should be managed for seasonal
production.
Seasonality should be taken into account for surveillance in order to ensure production is
observed.


4) Switching CBs
The current requirement is that sites that are
under a surveillance audit are not allowed to
switch to a different CB until the surveillance
audit is completed. The intent is to have
consistency in the perspective of the facility’s
non-conformances and corrective actions. The
issue is that that sites that want to opt out of
their audit look to SQF to exempt them from
this requirement and when not granted would
choose to lose certification rather than
continue with the existing CB. Should SQF
revert to the requirements under edition 6, and
remove all requirements as to when the site
can switch CBs?
 Recommend adding a new section for
season suppliers to include:
1) Resetting the recertification audit date
2) When to audit if more than one season
product
3) When to conduct a surveillance audit.
 I understand this is an issue when facilities are ‘shopping for a better score’ or when  Change the surveillance audit form not
a surveillance audit is trying to be avoided but I don’t know that you can prohibit a
issuing a score to having a new score and
supplier from switching – isn’t it a bit like trying to prohibit free trade?
rating based off the results of the
surveillance audit. The surveillance audit will
 Would it be possible to allow them switch CBs while under a surveillance audit but
not change the recertification date.
require the new CB to verify that all non-conformances and corrective actions were
addressed from the previous CB?
 Allow for suppliers to switch under specific
conditions:
 Perhaps we can allow them to switch CB’s but the surveillance requirement remains
1 – For due cause
intact. That way, if they have an issue with the CB or auditor, they can switch and
the surveillance audit requirement remains intact.
2 - After there is documented evidence
 If they want to change, at least SQF should define the new CB assigned to the site,
provided by the site that they have
and the surveillance audit and status should continue with the new CB.
followed the CBs internal process to
 Stay the course and do not allow sites that are under a surveillance audit to switch
address the due cause
CB”s. This not only drives consistency of non-conformances and corrective actions.
3 - Site provide a copy of their last 1-2
It also discourages “CB shopping”.
(min.) SQF audit reports to the new CB
 Switching CBs should be allowed, but only:
1 – For due cause
2 - After there is documented evidence provided by the site that they have
followed the CBs internal process to address the due cause
3 - Site provide a copy of their last 1-2 (min.) SQF audit reports to the new CB
5) Understanding the SQF Practitioner
per site
If we are going ahead with the ‘Advanced
Practitioner’, we need to reference in the
Code. Also, what do we do with the small sites
and sub-sites? It is important to sort out this
 I believe that each site regardless of size needs to have a trained SQF practitioner
on site.
 I agree. In the absence of a practitioner at a small site or sub-site, than a
responsible employee shall be designated by the corporate practitioner with
sufficient oversight of the operations
 I like the new provision and allowing for continuous improvement and learning



Retain this requirements
Guidance for the supplier and the auditor is
provided in the Guidance document for
Module 2
SQF Advanced Practitioner will not be added
to 7.2 of the code.
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Changes to the SQF Code, Edition 7.2. Proposed Action Plan from TAC Responses
issue for clarification for the sites.
under the standard
 If this is not going to be a requirement (advanced practitioner) then shouldn´t been
referenced.
 Yes, pls include the advanced practitioner in the code.
 Are the small sites and sub-sites part of a multisite?
 Advanced Practitioner credential or training course should be documented as a
definition in the SQF Code only. If it’s written into 2.1.2.5 it is very likely that it will
be misinterpreted by auditors, practitioner or consultants who will start insisting
that the SQF Practitioner at the site must have this credential.
 I strongly support the requirement of SQF Practitioner per site (including sub-sites). The SQF
Code makes it easy for any qualified individual within the facility to become the SQF
practitioner.
6) Viewing results of non-conforming
product
Based off the findings from Sunland, it was
discovered that product was shipped out that did not
meet microbiological specification. This prompted us
to include auditor guidance under section 2.4.6-Non-conforming product- that provides direction for
the auditor to request reviewing documentation as
to how product that did not meet specification was
handled.
Moving forward how should SQF address this in the
SQF Code that requires the finished product or raw
materials that do not meet specifications be
recorded and actioned.
7) Adjusting the code requirement for
compressed air
In recent discussions with Parker Balston, filtration
products, they have suggested alternative language
to clarify the intent of the compressed air quality
element. There has been a lot of confusion with this
element and this may need to get revisited.
 I agree absolutely – out of spec materials need to have follow up investigation
documented, product disposition recorded and corrective actions and preventive
measures, if needed.
 One way would be to have the supplier perform a mock-recall on the product
during the audit.
 At level 2, they should review documentation for non-conforming to the FS plan.
This should already be part of the HACCP review
 FDA is going to be looking at environmental testing and product pathogen results.
 Yes, SQF should require that finished product and/or raw materials that do not
meet specifications be recorded and actioned.
 This requirement is addressed in 2.4.6.2:
Non-conforming Product or Equipment:
Quarantine records, and records of
handling, corrective action, or disposal of
non conforming product or equipment shall
be maintained.
 Checking and asking for records for nonconforming records is also described in
guidance for this section.
 SQF will continue to emphasize in auditor
training and professional update training.
 Nonconforming product is currently addressed in 2.4.6, managed so as to minimize
potential for inadvertent/improper use as was the case with Sunland Co
 I agree this is very confusing. Compressed air contamination can occur in numerous ways
and if undetected, it can contaminate final product.
 Waiting for proposed changes from Parker
Balston.
 Most compressed air systems have oil traps and filters to protect the product. It would help
to have additional guidance as to what the expectation is for suppliers

It is wise for SQF to revisit the compressed air quality language and make it clear
 I agree on the language, very confusing
 I would like to see proposed language for this. I feel that this is best addressed in the
guidance document.
8) Viewing regulatory reports and
warning letters

I believe this belongs in the “Business” section of the code – Part A but not in the code itself

It would make it easier if incorporated into the actual code. I would suggest placing it in 2.4.1
 Add requirements to:
 2.4.1.3- SQFI and the CB shall be
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Changes to the SQF Code, Edition 7.2. Proposed Action Plan from TAC Responses
With the many regulatory inspections and warning
letters SQF has incorporated in the requirements
under Part A, section 5.3 that requires the supplier to
inform the CB and SQF of any food safety event that
requires public notification (such as Class I, Class II
and Regulatory Warning letters). However, does this
require SQF to have this added into the code and if
so, where would this be required.
Food Legislation (Regulation) (M)

Only in the countries with this regulatory requirements.

Yes, notification of recalls and warning letters should be in the code….not sure where.

This item is already addressed in 2 places in the SQF Code (Part A, 5.3 and Part B, 2.1.5.1). I
do not see a need to address it further in the Code. Perhaps it should be addressed in the
guidance document under Part B, 2.1.5.1.


9) Multi-site requirements
The multi-site requirement may be changing with
the publication of the Storage and Distribution
guidance document and SQF will need to reconsider
how this would apply to the code.
10) Use of the Quality Shield
There are large corporations that would like to have
one Quality Shield used for all facilities. SQF should
consider changing the Quality Shield requirement to
allow for multiple facility use of the same logo and
number.
11) Adding modules
Develop a module for brokers. Develop a module for
warehousing and retailers

This will be very big and tough to get our arms around. I am anxious to see where GFSI goes
with this.

Careful consideration should be paid to multisite requirements to ensure the entire food
system is contained in the certification.

What is in the Storage and Distribution guidance that would be of concern?

Lets see what GFSI comes up with

I was told a few years ago by a GFSI Board member that GFSI discourages the use of any
labeling that indicates a product may be ‘safer’ than another.

This makes sense but I’d have concerns about the shield being inappropriately applied to a
facility that is not SQF certified.

This could be good, but does this mean that if one facility does poorly on an audit and status
is removed, that the Quality Shield usage would need to be removed from all?

Yes, one Quality Shield should be available for all facilities within a large company.

No comment. This makes sense

I believe flexibility could be applied for this and a corporate master number be assigned. I
propose the corporate number be assigned through the database and tied to the certification
number for the sites so that in a public query of the database the sites are identified

FONA International would be happy to participate on development of these models if you
need working group members.

The broker and warehouse modules are going to be very important for these entities to
comply with FSMA. Especially for brokers under the Preventative Controls for Supplier
Verification.

Yes, pls add modules for brokers, warehousing & retailers.

I support this
notified within 24 hours in instances
in which a supplier receives a
regulatory warning letter.
2.6.1.3.iv: SQFI and the CB shall be
listed as an essential body and be
notified in instances in which there is
a food safety incident of public
nature.
Work with CBs to provide examples
and further clarification for
regulatory warning letters
 GFSI will be revising this requirement. SQF
should wait for this guidance and make the
necessary modifications.
 Recommend making changes to Appendix
3., schedule 1:
Corporate Shields can be issued for
organizations wishing to display the SQF
Quality Shield at the corporate site. SQF will
issue one shield number to be used at the
corporate site. The other, SQF certified sites,
will be required to use their assigned Quality
Shield with their unique number.
 Will be adding the Broker module based off
of TAC feedback.
 Retail module will wait for GFSI guidance.
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Changes to the SQF Code, Edition 7.2. Proposed Action Plan from TAC Responses
12) Unannounced audits
Expressed during the closing session for GFSI, the use
of unannounced audits will be coming to GFSI in the
future. This is something that should be discussed as
how unannounced audits should be used within SQF.
13) Other areas for discussion

I believe this will be challenging for CBs to manage and especially difficult for small
manufacturers.

Fully support

This is needed and something that I support. I like the idea discussed as one audit in three
with reasonable advance warning to make sure the facility is operating, not undergoing
another audit with a customer or other exemptions that need to be spelled out.

Need to define goals and consequences

YES! YES! YES! Unannounced audits should be used within SQF. This is essential to renew
confidence in GFSI and SQF

Today the industry has gotten too good at “prettying itself up”. Unannounced audits would
eliminate this phenomenon. All SQF certified sites should be audit ready 7x24.

Growers – this is a challenge due to harvest timing especially if grower has one variety of
production.

Unannounced audits are currently an option under BRC,
Two respondents (Holly, Joan) mentioned ‘management commitment’:

Management Commitment and Food Safety Culture seem to be one in the same in my mind
and I know the Guidance Document Working Group sent a message back to the GFSI Board
that a working group should be formed to determine how to measure Food Safety Culture.

I believe that the efforts toward a global food handler curriculum and good training practices
will be one of the ways to measure management commitment and the culture within a
facility

Management Commitment – SQF must continue its focus and increased requirements re:
management commitment.
 Captured in separate document
 Management commitment is discussed in
detail in the SQF Guidance for module 2.
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