Highlights of What and How to Meet SQF 9.0 Requirements

SQFI has recently published SQF code version 9.0. The expected compliance date for SQF code 9.0 would be in May 2021.

You may download the SQF 9.0 code and summary from the SQFI site. See https://www.sqfi.com/resource-center/sqf-code-edition-9-downloads/.

We are highlighting 5 major updates to the code. Let’s start with the biggest highlight of the SQF 9.0 code -the concept of ūüí° food safety culture.

Changes #1: Food Safety Culture

The code:

2.1.1.2 Senior site management shall lead and support a food safety culture within the site that ensures at a minimum:

  1. The establishment, documentation, and communication to all relevant staff of food safety objectives and performance measures;
  2. Adequate resources are available to meet food safety objectives;
  3. iii. Food safety practices and all applicable requirements of the SQF System are adopted and maintained;
  4. Employees are informed and held accountable for their food safety and regulatory responsibilities;
  5. Employees are positively encouraged and required to notify management about actual or potential food safety issues; and
  6. Employees are empowered to act to resolve food safety issues within their scope of work.

Definition of Food Safety Culture from GFSI:

Definition of food safety culture according to GFSI is the shared values, beliefs and norms that affect mindset and behavior toward food safety in, across and throughout an organization.

Elements of food safety culture are those elements of the food safety management system which the senior management of a company may use to drive the food safety culture within the company. These include, but are not limited to:

  • Communication about food safety policies and responsibilities
  • Training
  • Employee feedback on food safety related issues
  • Performance measurement.

The Importance

We heard of how employees are the culprit for bad food safety behaviour that leads to food recall and outbreak. By instilling a positive food safety culture, it helps shun the bad behaviours and encourage good food safety practices.

How to Demonstrate

Go beyond Letter of Commitment.

Top site management takes the responsibility to lead the site in achieving food safety goals. They encourage open communication to ensure any food safety concerns are properly addressed in a timely manner. It starts from the top management.

Our opinion:

Food safety culture is shown through the site personnel’s response to food safety questions and not just through records. After all, paper can only show so much!

Changes #2: Alternate SQF Practitioner

The code:

2.1.1.4 Senior site management shall designate a primary and substitute SQF practitioner for each site with responsibility and authority to:

  1. Oversee the development, implementation, review, and maintenance of the SQF System;
  2. Take appropriate action to ensure the integrity of the SQF System; and
  3. Communicate to relevant personnel all information essential to ensure the effective implementation and maintenance of the SQF System.

2.1.1.5 The primary and substitute SQF practitioner shall:

  1. Be employed by the site;
  2. Hold a position of responsibility related to the management of the site’s SQF System;
  3. Have completed a HACCP training course
  4. Be competent to implement and maintain HACCP based food safety plans; and
  5. Have an understanding of the SQF Food Safety Code: Food Manufacturing and the requirements to implement and maintain an SQF System relevant to the site’s scope of certification.

The Importance

It is essential to ensure there is a suitable backup for the SQF Practitioner, in case he/she is sick or on vacation, to upkeep the food safety program on-site.

How to Demonstrate

There are 3 components to meeting the backup SQF Practitioner’s requirements: designate a backup SQF practitioner, training and competence. At a minimum, the backup SQF Practitioner must complete a formal HACCP course and hold responsibility for managing the SQF system. The person must be knowledgeable and able to maintain SQF systems, similar to the primary SQF Practitioner. The way to think about this is the backup person must have similar competencies as the primary SQF Practitioner in terms of upkeeping the SQF system for the site.

Changes #3: Corrective actions are now corrective and preventative actions

The Sample Code:

2.1.3.3 Corrective and preventative action shall be implemented based on the seriousness of the incident and the root cause analysis as outlined in 2.5.3. Records of customer complaints, their investigation, and resolution shall be maintained.

The Importance

You will see the terms “corrective actions and preventative actions” throughout the code. We think it is essential because when we take action on any non-conformances, we tend to correct what is wrong but missed out on preventing the non-conformances.

How to Demonstrate

Document both corrective actions and preventative actions on the Deviation or Non-Conformance Report.

Changes #4: Major deviation scoring point changes from -10 to -5

The code:

Based on the evidence collected by the SQF food safety auditor, each applicable clause of the SQF certification food safety audit is automatically scored in the audit report.

The score is based on the following factors:

0 – aspect meets the criteria

1 – aspect does not meet the criteria due to minor variations (minor non-conformance)

5 – aspect does not meet the criteria (major non-conformance)

50 – aspect does not meet the criteria (critical non-conformance)

A single rating is calculated for your site audit as (100 ‚Äď N) where N is the sum of the individual rating criteria allocated.

The Impact

We are not sure about the impact of whether or not your site SQF score will go up or down. Less score reduction for major non-conformances means more room for issuance of more majors or minor non-conformances as deem necessary. You may also end up with a better score.

How to Demonstrate

Identify gaps before an actual audit through an internal audit. Check out our  Internal Audit article for more tips.

Changes #5: Label Reconciliation

The code:

2.6.1.2 Product start-up, product changeover, and packaging changeover (including label changes)  procedures shall be documented and implemented to ensure that the correct product is in the correct package and with the correct label and that the changeover is inspected and approved by an authorized person.

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.

The Importance

When we conduct traceability exercise, we often perform materials reconciliations. Often, product label reconciliation is missed. It is important to know that product labels are not being misused or labelled on the wrong products. One of the best ways to do this is to have a product label reconciliation procedure.

How to Demonstrate

Set up a procedure, similar to Material Traceability, for labels. Ensure all labels received, used, wasted or used as samples are recorded. On a regular basis, perform product label reconciliation to ensure product labels are not misused or misplaced.

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