The Safe Quality Food Institute (SQFI) released SQF Code Edition 10 last March. The SQF 10 is still awaiting benchmarking through the Global Food Safety Initiative (GFSI). Audits are scheduled to start in January of 2027 pending the GFSI review. SQF 10 represents a natural evolution of the program to align with other international standards for quality and food safety. To successfully transition to Edition 10, sites should take a structured and proactive approach. We have asked SQF certified auditor Dr. Narasimhanama to point out the main changes in SQF 10 and how to prepare for an audit. You will find below auditing guidance and insights on how to meet the new SQF 10 requirements.
1. Focus on Food Safety Culture
What is in the Ed. 10 of the Safe Quality Food (SQF) Code?
Sites are required to develop and document a positive food safety culture plan that includes objective measurable elements, such as, employee feedback, continuous improvement (CI) initiatives, management commitment.
- Effective communication strategies to ensure all personnel are informed and engaged in food safety practices.
- Comprehensive training programs for all personnel including site management.
- Mechanism to collect and address feedback from all personnel regarding food safety practices; and
- Regular measurement and evaluation of food safety-related activities.
How will auditors verify the requirement?
- A documented food safety culture plan with specific metrics for measuring employee feedback, Continuous Initiatives (CI), employee food safety habits, food safety training effectiveness, employee engagement in food safety.
- Review of food safety related training plan and training records that include all employees.
- Interviewing management regarding CI initiatives and their action plans, employee feedback, employee engagement in food safety.
- Interviewing employees to verify management commitment to food safety, effectiveness of training, empowerment of food safety, effectiveness of communication related to food safety.
2. Requirement for Change Management Procedures
What new GFSI element must be implemented as part of SQF 10?
- A separate clause requiring sites to develop a risk-based documented procedure for managing changes to equipment, processes, personnel, suppliers, or materials.
- Impact analysis of changes to food safety.
How will auditors verify the requirement?
Availability of a documented procedure addressing how changes to process, product, equipment, personnel, suppliers, materials will impact food safety.
- Evidence of impact analysis of the changes on food safety through review of records.
- Interviewing management to verify how changes are routed in the food safety management system.
- Review of records for the changes that would have occurred at the site in the past year.
3. Enhanced Requirements of document and record management
What is in the Ed. 10 of the Code?
- Consolidated requirements for document control, records, and verification.
- Clarity regarding completion of annual food safety management records, such as, management review (refer to 2.1.2); internal audits (refer to 2.5.4); food defense threat assessment and prevention plan review (refer to 2.7.1); food defense test (refer to 2.7.1); food fraud vulnerability assessment and mitigation plan review (refer to 2.7.2); traceability test (refer to 2.6.2); crisis management test (refer to 2.6.4); recall test (refer to 2.6.3); and food safety plan review, including process flow (refer to 2.4.3).
- Clarity regarding completion of records demonstrating the implementation of food safety management system, such as, monthly management updates (refer to 2.1.2); product development approvals (refer to 2.3.1); supplier approvals (refer to 2.3.4); root cause analysis and the corrective action process (refer to 2.5.3); validation and verification records ( 2.5.1 and 2.5.2); process changes (refer to 2.3.5); complaints, investigations, and resolutions (refer to 2.1.3); and contractual agreements (refer to 2.3.3).
How will auditors verify the requirement?
- Review of a written procedure for document control, and objective evidence for its effective implementation.
- Review of a written procedure for maintaining records, and objective evidence for its effective implementation.
- Review of annual food safety management system records, such as, monthly management updates (refer to 2.1.2); product development approvals (refer to 2.3.1); supplier approvals (refer to 2.3.4); root cause analysis and the corrective action process (refer to 2.5.3); validation and verification records ( 2.5.1 and 2.5.2); process changes (refer to 2.3.5); complaints, investigations, and resolutions (refer to 2.1.3); and contractual agreements (refer to 2.3.3).
- Review of records demonstrating the implementation of food safety management system, such as, monthly management updates (refer to 2.1.2); product development approvals (refer to 2.3.1); supplier approvals (refer to 2.3.4); root cause analysis and the corrective action process (refer to 2.5.3); validation and verification records ( 2.5.1 and 2.5.2); process changes (refer to 2.3.5); complaints, investigations, and resolutions (refer to 2.1.3); and contractual agreements (refer to 2.3.3).
4. Risk-Based Environmental Monitoring
What is in the SQF 10 Code?
- Mandatory requirement for a risk-based approach to environmental monitoring program including a formal assessment to determine monitoring scope, frequency, and pathogens.
- Requirement for review of the program annually or when trends or other changes affect food safety.
How will auditors verify the requirement?
- Review of a written plan for environmental monitoring program to verify if it is based on risk assessment, and whether the scope is defined and how the site determined the frequency of testing and the basis of selecting the target organism.
- Review of records to verify the effectiveness of implementing the documented program.
- Review of records to verify how the site addresses the deviations and the effectiveness of corrective actions implemented.
- Interview with the person in-charge of the program to collect additional evidence.
5. Training
What is in the Ed. 10 of the Code?
a. Mandatory training for those responsible for,
- Developing and maintaining food defense, food fraud, and food safety plans.
- Monitoring critical control points.
- Implementing the corrective action process, including root cause analysis.
- Conducting audits and inspections (internal, GMP, and supplier); and
- Any other tasks identified as critical to meeting the effective implementation and maintenance of the SQF Code.
and an assessment of the training
b. Consolidated training requirements for personnel and contractors on the following: Allergen management; food fraud mitigation; food defense; environmental monitoring; recall; traceability; crisis management; supplier and co-manufacturer audits; sampling and testing of all raw materials including packaging, work-in-progress, and finished products; personal hygiene; and equipment and site cleaning, sanitizing, and maintenance.
How will auditors verify the requirement?
- Review of training records related to the training mentioned above.
- Interview of relevant personnel
6. Corrective and Preventive Action
What is in the Ed. 10 of the Code?
- Emphasis on the use of correction to address the identified issue; method(s) of analysis used to investigate and identify the root cause; process for determining and implementing the corrective and preventative actions needed to address the root cause; verification of effectiveness of the implemented actions to prevent reoccurrence; and communication of results to relevant site management and personnel.
How will auditors verify the requirement?
- Review of CAPA records to verify the methods used to identify the root cause (example, fishbone diagram).
- Review of CAPA records to verify the effectiveness of corrective actions (repeat issues, for example).
- Review of CAPA records to verify preventive actions taken, if applicable
- Interview with employees responsible for the CAPA program regarding their understanding of the methodologies used.
Authored by Ramakrishnan Narasimhanama, PhD, Certified SQF Auditor and Trainer.
Sirocco Consulting Inc. provides SQF 10 certification services, detailed and dynamic SQF 10 Templates as well as SQF training courses through licensed SQF training centers. Contact us to obtain a quote or to schedule a gap assessment. We serve Canada and the United States. We fly to your location and provide support remotely.
