The release of SQF Code Edition 9 will align the code with the latest GFSI benchmarking criteria when audits begin in May 2021.
Taking pride of place at the recent SQF Global Conference, the freshly debuted Edition 9 unites the global SQF community of more than 10,000 sites in 40 countries to serve as an integral part of the world’s food supply chain.
The changes in its release arrive at a time of unprecedented challenge for the industry worldwide and are designed to propel SQF further into being an accessible and implementable solution that works for the global food safety community.
Having attended multiple sessions throughout the conference, what follows below is a high-level introduction of what food manufacturers can expect in the changing compliance landscape of 2021 and beyond.
From a very high level, changes to the code can largely be categorized between structural and technical changes.
Changes to the code can be categorized between structural and technical changes
Change or adjustment to any standard can often cause concern or worry to a food manufacturer that may be unfamiliar with what is required and conscious that they may not be adequately prepared.
This blog presents a detailed summary of the core changes and key areas of concern that you may need to know of what is occurring to the standard and what food businesses are obligated to do to ensure their compliance remains unaffected between the transition of Code Edition 8.1 to Edition 9.
Before continuing, it must be pointed out that what this blog is not is a comprehensive framework or roadmap for compliance to the standard, but rather it is designed to introduce the topic to those who may be unaware and help them in their path to familiarization.
Starting from an extremely high level, the aesthetic of the code itself has changed with a new look cover, font, and spacing immediately evident.
On the surface, while such changes might seem pedantic or trivial, they are indicative of larger changes within the code itself where the architecture and structure of the codes has been improved, and it could be considered that a new aesthetic supposes the code is now designed to be more accessible to stakeholders.
A new look and aesthetic appeal of the code are indicative of larger changes
Arguably, one of the most prominent criticisms of the code from detractors in the past has been with regards to unnecessary duplication and the problems associated with it.
For example, in previous iterations handwashing was mentioned in several areas of the code which it could be argued might create confusion for businesses who were starting their SQF-journey and might find it difficult to determine where to begin.
To address these critiques, Edition 9 prioritizes consolidation to make it easier to locate requirements and indeed to make them more understandable for would-be sites new to SQF as well.
At the risk of oversimplifying the changes, and on a very simple and pragmatic level, the Primary Production and Manufacturing Codes have been divided into sections to streamline and improve synergies across the road
Primary Production and Manufacturing Codes have been divided into sections to streamline and improve synergies across the code
The Primary Production code has now been divided into three different codes: Primary Livestock (Animal) Production, Primary Plant Production, and Aquaculture.
Each of these industry scopes will now be represented by its own dedicated code and system elements.
While I will focus on the specifics of these later in this piece it is important to note that the parameters of these scopes have also increased in parts and it is not a case that they are simply a copy-and-paste of the previous iterations.
For example, Pre-packing of produce (module 10 in SQF 8.1) has been removed and is now with Primary Plant products.
The subdivision of the Primary Production code also increases their parameters and it is not they are a simply a ‘copy-and-paste’ of the previous iterations.
The Manufacturing Code has also seen changes with Processing of Animal Products, Pet Food, and Animal Feed also being removed into separate codes as well.
The purpose of these adjustments is to streamline the code and create synergies that bring elements together for more effective adherence, such as slaughtering, which is now included with processing.
One change to the Quality Code is that it is now applicable to any GFSI standard whereas before it was just applicable to SQF.
The Quality Code is now applicable to any GFSI standard whereas before it was just applicable to SQF
Finally, there have been no changes made to Food Retail, Foodservice, or the Fundamentals Program; although it is currently envisioned that these will be updated to Edition 9 in 2021.
One of the most immediate and obvious changes is the adjustment of how scoring is determined in Part A of the code.
A major non-conformance is now scored at 5 points instead of 10, which indicates a possibility for more nonconformances to be raised which should allow for better reflection of the current site performance and hopefully lead to more effective learning opportunities for development.
Additionally, this scoring change will provide a holistic view of a facility while still identifying systemic issues.
How scoring is calculated has been changed to provide a holistic view of a facility while still identifying systemic issues.
The requirement for a stage one desk audit for initial certifications has also been removed while the option for remote activities has been included.
In simple terms, what this means is that Part A now accommodates the facilitation of a ‘hybrid audit’ which can be incorporated into the audit process.
As pre-audit activities can now be performed remotely (something Safefood 360° can assist with) the audit duration table in the section has also been removed.
Specific time frames are also now in place which are based on the GFSI duration guide.
There is also clear clarification provided for sites on what activities to do when the site fails an audit or is suspended.
An ‘IF/THEN’ table in Part A should help sites get back on track when required
In such instances, the SQF has provided an IF/THEN table in Part A which is designed to help the site get the site back on track in as efficient a way as possible.
Overall, the changes are designed to be more ‘site-friendly’, something which is reflected in how Part A is now written from a site’s perspective.
System Element Changes
One of the key changes in system elements is the requirement for Food Safety Culture has been updated (126.96.36.199).
This is something that should bring a closer alignment between the SQF and BRCGS Food Safety Issue 8 and follows an emphasis on Food Safety Culture from the FDA in its New Era Blueprint.
A requirement for Food Safety Culture should bring closer alignment between the SQF and BRCGS
That said, what is required here is not necessarily anything new as it has been compulsory in other elements in past versions, e.g., adequate resources being available to ensure objectives can be met is in the requirement for senior management commitment.
Similarly, what is expected and required from the senior manager commitment section seems to be comparable to the expectations in the food safety culture requirement and quality policies should be updated to include food safety culture.
Internal labs that conduct food safety testing must ensure that sampling and testing methods are in accordance with the applicable requirements of ISO/IEC 17025 and there is an annual proficiency testing conducted for staff who perform the analysis work.
This caveat is only required for those conducting food safety testing and not quality testing such as Brix, and the internal lab doesn’t need to be accredited to ISO/IEC 17025.
Individual System Element Changes
2.1 Management Commitment
The requirements in 2.1 Management Commitment have been consolidated with duplications removed.
Food Safety Culture, as discussed above, has been added into this section and it is now required that a site has a substitute or backup SQF practitioner.
Sites are required to have a substitute or backup SQF practitioner
Sites must now be organized in order to meet food safety objectives and staff should be evaluated to ensure they have the right competency and support from management.
Finally, Crisis management, which was previously in this section, has now moved to 2.6.3 Recalls and Withdrawals.
2.2 Document Control and Records
There were no major changes to 2.2 Document Control and Records, except the addition of a requirement for retention periods of documents to consider the shelf life of the product.
This was added to meet GFSI benchmarking criteria.
2.3 Specifications, Formulations, Realization, and Supplier Approval
This section has been renamed from Specification and Product Development to a more encompassing Specifications, Formulations, and Supplier Approval.
Product formulation needs to include development by authorized persons and is required to be reviewed when changes are made in materials, ingredients, or equipment.
Process flow has been added to 188.8.131.52 and all specifications have been summarized under 2.3.2 and include service suppliers.
Suppliers must now notify the site of changes in product composition that could have an impact on product formulation and food safety, for example where a potential allergen such as soy has been added.
Suppliers must notify the site of changes in product composition that could have an impact on product formulation and food safety
It has also been added that finished product labels must be accurate, comply with the relevant legislation, and be approved by the qualified company personnel.
184.108.40.206 is now split with validation of specifications being retained in 220.127.116.11 and verification is now in 18.104.22.168 as part of Approved Supplier Requirements which has moved to 2.3.4.
If your business utilizes Co-Manufacturers the requirement now includes high and low risk, as well as third-party distributors with specific mention for the first time as it had not been defined before.
2.4 Food Safety System
Product sampling, formerly in section 2.5.4, is now in 2.4.4 in Food Safety Systems, while testing and analysis now include reference to internal as well as external laboratories (internal lab formerly 11.8.1).
Proficiency testing is now included in 22.214.171.124 (formerly 126.96.36.199) and Non-conforming equipment has moved to 188.8.131.52.
Product release should now include a procedure to confirm that product labels comply with the applicable food legislation with a positive product release procedure required in 184.108.40.206.
2.5 SQF System Verification
A record for root cause analysis is now required under 220.127.116.11 but beyond this, there have not been many changes of note to this section.
That said, the SQF has announced that they intend to provide clarification on the requirement, as well as detailing where deviations from food safety requirements may occur.
These clarifications have not been issued at the time of writing.
2.6 Product Traceability and Crisis Management
2.6 has been renamed to include ‘Crisis Management’ which can now be found under 2.6.4 (previously 2.1.5), a decision that allows for a better flow of requirements.
Crisis Management allows for a better flow of requirements
There is also a new emphasis on labeling requirements and checks during operations to ensure that the correct product is in the correct package and with the correct label.
Product changeovers will need to be inspected and approved by an authorized person, while procedures will be implemented to ensure that label use is reconciled, and any inconsistencies are investigated and resolved.
Requirements for testing the recall system are now to include products from different shifts and for materials across a range of products and customers.
2.7 Food Defense and Food Fraud
This section is a good example of how the new edition groups similar requirements as it has been consolidated to include all food defense and food fraud.
In version 8.1 food defense was mentioned in the approved supplier program but is now fully contained under 2.7.
2.8 Allergen Management
Allergen Management has seen a walk back of requirements from Edition 8.1 with regards to the labeling of gluten.
Additional requirements regarding the approval, use, verification, and reconciliations of labels has been added as labeling issues in regard to allergens has been a cause of many recalls.
To reduce the number of sub-clauses in 2.9, training was consolidated into two sections – 2.9.1 Training Requirements and 2.9.2 Training Program.
The content hasn’t changed too much with just a few additional requirements being added in the cases of relevant staff for the tasks of sampling and testing methods, as well as environmental monitoring.
All relevant staff are required to have adequate training for allergen management, food defense, and food fraud.
Module 11 Changes
There have been numerous changes to Module 11, so it is important to address them separately to ensure they receive the appropriate attention.
11.1 Site Location and Premises
11.1 was renamed to Site Location and Premises and now covers 11.1.2 Building Materials; 11.1.3 Lighting and Light Fittings; 11.1.4 Inspection/QC Area; 11.1.5 Dust, Insect, and Vermin Proofing; 11.1.6 Ventilation; 11.1.7 Equipment and Utensils; and 11.1.8 Grounds and Roadways.
While this might seem an extensive sweep of change upon initial glance, the purposes for them being consolidated follows in line with the previous ones mentioned and was to streamline the requirements by having similar reaching requirements grouped together.
One other change in 11.1.6 is the requirement for ventilation in enclosed processing and food handling areas, and where appropriate a positive air pressure system should also be put in place.
Finally, 18.104.22.168 includes non-conforming equipment, which was previously located in 2.4.5, while equipment storage rooms has been moved to 11.6 Storage.
11.2 Site Operation
11.2 was renamed to Site Operations and it now includes 11.2.1 Repairs and Maintenance; 11.2.2 Maintenance Staff and Contractors; 11.2.3 Calibration; 11.2.4 Pest Prevention; and 11.2.5 Cleaning and Sanitation.
11.2.2 Maintenance Staff and Contractors has also been separated out from what was 11.2 Premises and Equipment Maintenance.
Lastly, Pest Prevention was restructured and clarified and there was a terminology change with regard to handwashing basins now being referred to handwashing stations.
11.3 Personnel Hygiene and Welfare
More restructuring and consolidating mean this section contains only one code requirement in 22.214.171.124 where references to signage for handwashing have been combined.
11.3.3 has been ‘rebranded’ from Clothing to Clothing and Personal Effects and it now includes laundering, protective clothing, and jewelry while 11.3.5 Staff Amenities include change rooms, toilets, and break rooms.
11.4 Personnel Processing Practices
This section remains the same but requirements for staff personnel working in or visiting food handling areas has been differentiated.
Process flow which was previously in 11.7.1 is now captured under 126.96.36.199.
11.5 Water, Ice, and Air Supply
A business is now required to have contingency plans in place for its water supply in such instances where the potable water is deemed to have been contaminated (188.8.131.52).
Ice supply should be sourced from an approved supplier and included in the food safety risk assessment
There also now exists a new clause in 184.108.40.206 with regards to ice supply, indicating that ice should be sourced from an approved supplier, included in the site’s food safety risk assessment, and be supplied in containers that are appropriate for use.
11.6 Receipt, Storage and Transport
11.6 has been renamed to Receipt, Storage, and Transport due to an update in relation to the receipt of materials.
220.127.116.11 includes a new clause to meet GFSI GMP 4.1 which is to ensure all materials are received and stored properly to prevent cross-contamination risks.
A new requirement exists for loading docks which should be designed to protect the product from any kind of contamination during loading and unloading.
In 18.104.22.168 there is a new requirement for loading and unloading docks, which requires them to be designed to protect the product from any kind of contamination during loading and unloading.
11.7 Separation of Functions
There is a new requirement for Ambient air in high-risk areas to be tested, at least annually, to confirm that it does not pose a risk to food safety (22.214.171.124).
Ambient air should be tested annually [at least] to confirm it does not pose a risk to food safety.
A new clause (126.96.36.199) has been added stating that “Gaskets, Rubber Impellers, and other equipment made of materials that can wear or deteriorate overtime shall be inspected on a regular frequency.”
Receipt of raw materials moved to 11.6.1.
11.8 Waste Disposal
With On-site laboratories being addressed in 2.4.4., this section is now fully dedicated to Waste Disposal.
188.8.131.52 has moved from 184.108.40.206 in Edition 8 as “Waste and overflow water from tubs, tanks and other equipment shall be discharged direct to the floor drainage system and meet local regulatory requirements.”
A new clause has been added to meet GFSI GMP 12.1 regarding the effective removal and storage (if required) of wastewater.
Primary Production Changes
As mentioned earlier the Primary Production code has now been divided into three different codes: Primary Livestock Production, Primary Plant Production and Aquaculture.
The Primary Plant Production means that grower and packers who previously would have been required to be certified to 2 codes, Primary Production and Manufacturing, now only need to be certified to one.
A new food sector category ‘Indoor Growing and Harvesting of Fresh Produce and Sprouted Seed Crops’ has been added and grain handling is now under the sector ‘Food Produce, Grain and Nut Pack House Operations’.
A new module, Module 18 – GAP for Indoor Farming of Plant Products has also been added and Packaging Module 10 has moved into Primary Plant Production.
These changes will align with GFSI and should help improve the scoping and effectiveness of audits in vertically integrated sites and multi-site certifications.
There has also been an update to the language in the code which should help remove ambiguity and provide enhanced clarity on the areas where the code is applicable.
Language in the code has been amended to remove ambiguity and provide clarity
For example, when products are grown in indoor situations they are clearly not grown in fields, so the terminology has changed to ‘growing areas’ to reflect the unique situation.
The term Good Operating Practices is also used as GMP isn’t suited to this sector.
To be in compliance with GFSI, the Primary Plant Products code now also includes licensing & a review process for plant/hybrids (for example hemp being supplied into the food industry), and a HACCP-based alternative will now be applied to Packhouses and applicable to indoor agriculture.
The Primary Plant Products code establishes a review process for plants and hybrids
This allows for corporate, brand owners or independent groups to provide food safety plans.
The word “significant” has also been added to CAPA, so if an incident occurs on a site a business can define in advance the appropriate action that needs to be taken.
A condition for Environmental monitoring has also been added for indoor agriculture and packhouses with a requirement for water quality for the Concentrated Animal Feeding Operation (CAFO) for leafy greens, as well as commodity-specific SOP’s for harvesting.
Finally, to align further with the latest GFSI criteria, new requirements for chemical label compliance, visitor cross-contamination, and waste system design have all been added.
As mentioned already, Pet Food has been separated out.
The most prominent change is that allergens are no longer mandatory with the requirements having been rescinded.
The ‘Allergens’ header has changed to ‘Identify Preserved Foods’ as this better identifies the hazards to pets (i.e., such as cases where a label claims to be grain free).
Some changes can be also seen in the domain of Animal Feed where HACCP-based programs or a risk management system can be used as a means of preventative controls.
Due to feed being separated out, a number of requirements were removed such as ice, a CIP reference, and sensory evaluation, while clarity has been provided on 3.6.2 Cold Storage and Thawing which is applicable to ingredients not feed.
Like most of the codes, the Food Packaging code has undergone consolidation by streamlining and decreasing the overall number of elements while preserving the integrity of the code.
Language has been updated to better reflect food sector packaging and pest prevention elements have been simplified.
There is now a requirement reading quarantined product (220.127.116.11) and finished product returned from a customer shall be quarantined until authorized for release for use or re-shipment.
Environmental monitoring has also been modified to be less prescriptive and to ensure it applies to all types of packaging rather than to paper-packaging.
Lastly, additional clarity has been given on the use of other materials such as recycled material in 18.104.22.168 with all raw materials, including those made with recycled, plant-based or additional additives, shall be suitable for the intended use, food contact compliance where applicable, and shall comply with the relevant legislation in the country of manufacture and country of destination, if known.
Storage & Distribution:
Storage & Distribution has followed the food manufacturing code with customized language for distribution centers.
Food safety plans can now be HACCP-based or based on preventative controls rather than their previous base which was tied to the Codex Principles.
This was amended to be compliant with a GFSI update which allowed some flexibility for US distribution centers to follow regulations.
Finally, a new requirement has been added (22.214.171.124) which requires procedures to be in place to identify the methods and responsibilities used to ensure that processes applied to materials prior to distribution (e.g., thawing, slacking, labeling) do not pose a risk to product safety or loss of traceability.
What does all this mean and how can I prepare?
Although the changes are numerous and may seem daunting, it is important to keep in mind that they are not radical and do not require a complete rethink in terms of how a business should approach the code.
Most of the changes made are actually to the benefit of the business and should help those already currently in compliance to reduce their burden of obligation and eliminate inefficiencies in their processes.
If you are already compliant with other GFSI standards as well, the inconvenience of any of this should be even less.
That said, complying with any change in the code can often be onerous and time-consuming in terms of the resources that are already being dedicated to the standard or can be spared to adjust for the change.
As such, it is always best to ensure you are as familiar with the code in advance of the changes as far out as possible and so that you can start taking the appropriate and effective action.
Of course, for existing users of our platform, SQF Code Edition 9 will be updated into the platform in due course ahead of the compliance date and the migration should be a relatively seamless switch for most.
If you would like more information about how Safefood 360° helps food businesses globally meet their compliance requirements with not just SQF but also other GFSI standards, global and retailer technical standards, please just leave a comment below or click the demo request button to start a conversation on how we can assist you with your own requirements.
Disclaimer: This blog is not legal advice and should be considered educational in nature. You may implement this advice at your own risk.