Edition 8.1 Checklist: The SQF Food Safety Code for Primary Production - System Elements

Edition 8.1 Checklist: The SQF Food Safety Code for Primary Production - System Elements

Opening Meeting

Closing Meeting

Facility Description | Auditor Description of Facility

Auditor Recommendation

Clause: 2.1 | Item: Management Commitment

Clause: 2.1.1 | Item: Food Safety Policy (Mandatory)

Clause: 2.1.1.1 | Item: The owner/senior site manager shall prepare and implement a policy statement that outlines as a minimum the: i. The site's commitment to supply safe food;

ii. Methods used to comply with its customer and regulatory requirements and continually improve its food safety management system; and iii. The site's commitment to establish and review food safety objectives.

"Clause: 2.1.1.2 | Item: The policy statement shall be: i. Signed by senior site management; ii. Made available in language understood by all staff; and iii. Displayed in a prominent position and effectively communicated to all staff. "

Clause: 2.1.2 | Item: Management Responsibility (Mandatory)

Clause: 2.1.2.1 | Item: The reporting structure describing those who have responsibility for food safety shall be identified and communicated within the organization.

Clause: 2.1.2.2 | Item: The owner/senior site manager shall make provision to ensure fundamental food safety practices and all applicable requirements of the SQF System are adopted and maintained.

Clause: 2.1.2.3 | Item: The owner/senior site manager shall ensure adequate resources are available to support the development, implementation, maintenance and ongoing improvement of the SQF System.

Clause: 2.1.2.4 | Item: The owner/senior site manager shall designate an SQF practitioner for each site with responsibility and authority to:

i. Oversee the development, implementation, review and maintenance of the SQF System, include Good Agricultural/Aquacultural Practices outline in 2.4.2 and the food safety plan outlined in 2.4.3;

ii. Take appropriate action to ensure the integrity of the SQF System; and iii. Communicate to relevant personnel all information essential to ensure the effective implementation and maintenance of the SQF System.

Clause: 2.1.2.5 | Item: The SQF practitioner shall: i. Be employed by the site as a company employee on a full-time basis; ii. Have completed a HACCP-based training course;

iii. Be competent to implement and maintain Good Agricultural/Aquacultural Practices; and iv. Have an understanding of the SQF Code and the requirements to implement and maintain SQF System relevant to the site’s scope of certification.

Clause: 2.1.2.6 | Item: Senior site management shall ensure the training needs of the site are resourced, implemented and meet the requirements outlined in 2.9,

and that site personnel have met the required competencies to carry out those functions affecting the legality and safety of food products.

Clause: 2.1.2.7 | Item: The owner/senior site manager shall inform all staff, including temporary or seasonal workers, of their food safety and regulatory responsibilities, of their role in meeting the requirements of the SQF Code

, and of their responsibility to report food safety problems to personnel with authority to initiate action.

Clause: 2.1.2.8 | Item: Job tasks for those responsible for food safety shall be listed and communicated to personnel including provisions to cover for the absence of key personnel.

Clause: 2.1.2.9 | Item: The senior site management shall establish processes to improve the effectiveness of the SQF System to demonstrate continuous improvement.

Clause: 2.1.2.10 | Item: The owner/senior site manager shall ensure the integrity and continued operation of the food safety system in the event of organizational or personnel changes within the farm/company or associated locations.

Clause: 2.1.2.11 | Item: The owner/senior site manager shall designate defined blackout periods that prevent unannounced re-certification audits from occurring out of season or when the facility is not operating for legitimate business reasons.

The list of blackout dates and their justification shall be submitted to the certification body a minimum of one month before the sixty (60) day re-certification window for the agreed unannounced audit.

Clause: 2.1.3 | Item: Management Review (Mandatory)

Clause: 2.1.3.1 | Item: The owner/senior site manager shall be responsible for reviewing the SQF System and documenting the review procedure.

Reviews shall include the policy manual, internal and external audit findings, corrective actions and their investigations and resolution, customer complaints and their resolution and investigation.

Clause: 2.1.3.2 | Item: The SQF practitioner(s) shall update senior site management on a (minimum) monthly basis on matters impacting the implementation and maintenance of the SQF System.

The updates and management responses shall be documented. The SQF System in its entirety shall be reviewed at least annually.

Clause: 2.1.3.3 | Item: Food Safety Plans, Good Agricultural/Aquaculture Practices and other aspects of the SQF System shall be reviewed and updated as needed when any potential changes implemented have an impact on the site's ability to deliver safe food.

Clause: 2.1.3.4 | Item: Records of all management reviews and updates shall be maintained.

Clause: 2.1.4 | Item: Complaint Management (Mandatory)

Clause: 2.1.4.1 | Item: The methods and responsibility for handling and investigating the cause and resolution (corrective actions) of complaints from customers and authorities shall be documented and implemented.

Clause: 2.1.4.2 | Item: Trends of customer complaint data shall be investigated and analyzed by personnel knowledgeable about the incidents.

Clause: 2.1.4.3 | Item: Corrective action shall be implemented commensurate with the seriousness of the incident and as outlined in 2.5.5.

Clause: 2.1.4.4 | Item: Records of customer complaints and their investigations shall be maintained.

Clause: 2.1.5 | Item: Crisis Management Planning

Clause: 2.1.5.1 | Item: A crisis management plan that is based on the understanding of known potential dangers (e.g. flood, drought, fire, tsunami, or other severe weather or regional events such as warfare or civil unrest) that can impact the site's ability to deliver safe food, shall be documented by the owner/senior site management outlining the methods and responsibility the site shall implement to cope with such a business crisis.

Clause: 2.1.5.2 | Item: The crisis management plan shall be reviewed, tested and verified at least annually. Records of reviews of the crisis management plan shall be maintained.

Clause: 2.2 | Item: Document Control and Records

Clause: 2.2.1 | Item: Food Safety Management System (Mandatory)

Clause: 2.2.1.1 | Item: A food safety management system shall be documented, maintained in either electronic and/or hard copy form, and made available to relevant staff and include: i. The policy statement and organization chart; ii. The scope of the certification; iii. A list of the products covered under the scope of certification; and

iv. Include or reference the written procedures (Good Agricultural Practices, Good Aquacultural Practices and/or Good Production Practices) and other documentation necessary to support the development, implementation, maintenance and control of the SQF System.

Clause: 2.2.1.2 | Item: All changes made to Food Safety Plans, Good Agricultural/Aquacultural Practices and other aspects of the SQF System shall be validated or justified.

Clause: 2.2.2 | Item: Document Control (Mandatory)

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

Clause: 2.2.2.2 | Item: A register of current SQF System documents and amendments to documents shall be maintained.

Clause: 2.2.2.3 | Item: Documents shall be safely stored and readily accessible.

Clause: 2.2.3 | Item: Records (Mandatory)

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

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

Clause: 2.2.3.3 | Item: 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.

Clause: 2.3 | Item: Specification and Product Development

Clause: 2.3.1 | Item: Product Development and Realization

Clause: 2.3.1.1 | Item: The methods and responsibility for designing, developing and converting product concepts (e.g. new crops, animal species) to commercial realization shall be documented and implemented.

Clause: 2.3.1.2 | Item: New products shall be validated for shelf life, Maximum Residue Limits (MRLs) and customer requirements.

Clause: 2.3.1.3 | Item: Records for new products validation, shelf life and final approvals shall be maintained.

Clause: 2.3.2 | Item: Raw and Packaging Materials

Clause: 2.3.2.1 | Item: Specifications for food contact packaging and agricultural/aquaculture inputs shall be documented and kept current.

Clause: 2.3.2.2 | Item: All food contact packaging and agricultural/aquaculture inputs shall comply with the relevant legislation.

Clause: 2.3.3.3 | Item: Food contact packaging and agricultural/aquaculture input specification development and approval shall be documented.

Clause: 2.3.2.4 | Item: Food contact packaging and agricultural/aquaculture inputs shall be verified to ensure product safety is not compromised and the material is fit for its intended purpose. Verification shall include certificates of conformance; or certificate of analysis; or sampling and testing.

Clause: 2.3.2.5 | Item: Verification of packaging materials shall include: i. Certification that all packaging that comes into direct contact with food meets either regulatory acceptance or approval criteria. Documentation shall either be in the form of a declaration of continued guarantee of compliance, a certificate of conformance, or a certificate from the applicable regulatory agency; and

ii. In the absence of a certificate of conformance, certificate of analysis, or letter of guarantee, tests and analyses to confirm the absence of potential chemical migration from the packaging to the food contents shall be conducted and records maintained.

Clause: 2.3.2.6 | Item: Finished product labels shall be accurate, comply with the relevant legislation and be approved by qualified company personnel.

Clause: 2.3.2.7 | Item: A register of current packaging materials and agricultural input specifications and labels shall be maintained.

Clause: 2.3.3 | Item: Contract Service Providers

Clause: 2.3.3.1 | Item: Specifications/agreements for contract services that have an impact on finished product safety shall be documented, current, include a full description of the service to be provided and detail relevant training requirements of contract personnel (e.g. sprayers, portable toilets, temporary labor).

Clause: 2.3.3.2 | Item: A register of all contract service specifications shall be maintained and kept current.

Clause: 2.3.3 | Item: Contract Service Providers

Clause: 2.3.3.1 | Item: Specifications/agreements for contract services that have an impact on finished product safety shall be documented, current, include a full description of the service to be provided and detail relevant training requirements of contract personnel (e.g. sprayers, portable toilets, temporary labor).

Clause: 2.3.3.2 | Item: A register of all contract service specifications shall be maintained and kept current.

Clause: 2.3.4 | Item: Contract Farms/Producers

Clause: 2.3.4.1 | Item: The methods and responsibility for ensuring all agreements relating to food safety, customers product requirements and its realization and delivery are specified and agreed shall be documented and implemented.

Clause: 2.3.4.2 | Item: The site shall: i. Verify compliance with the SQF Food Safety Code and that all customer requirements are being met at all times; and ii. Ensure changes to contractual agreements are approved by both parties and communicated to relevant personnel.

Clause: 2.3.5 | Item: Finished Product Specifications

Clause: 2.3.5.1 | Item: Finished product specifications shall be documented, current, approved by the farm/producer and their customer where applicable, accessible to relevant staff and may include: i. Microbiological and agricultural chemical limits; ii. Maximum Residue Limits (MRL’s) for pesticides and/or veterinary drugs; and iii. Labeling and packaging requirements.

Clause: 2.3.5.2 | Item: A register of finished product specifications shall be maintained.

Clause: 2.4 | Item: Food Safety System

Clause: 2.4.1 | Item: Food Legislation (Mandatory)

Clause: 2.4.1.1 | Item: The owner/senior site manager shall ensure that, at the time of delivery to its customer, the food supplied shall comply with the legislation that applies to the food and its production in the country of use or sale, if known.

Clause: 2.4.1.2 | Item: The methods and responsibility for ensuring the organization is kept informed of changes to relevant legislation, scientific and technical developments, emerging food safety issues, and relevant industry codes of practice shall be documented and implemented.

Clause: 2.4.1.3 | Item: SQFI and the certification body shall be notified in writing within twenty-four (24) hours in the event of a regulatory warning. Notification to SQFI shall be by email to foodsafetycrisis@sqfi.com.

Clause: 2.4.2 | Item: Good Agricultural/Aquaculture Practices (Mandatory)

Clause: 2.4.2.1 | Item: The site shall ensure that Good Agricultural Practices described in Module 7, or other relevant applicable module of this Code, are applied, or exempted according to a written risk analysis outlining the justification for exemption or evidence of the effectiveness of alternative control measures to ensure that food safety is not compromised.

Clause: 2.4.3 | Item: Food Safety Plan (Madatory)

Clause: 2.4.3.1 | Item: A HACCP-based reference Food Safety plan, developed by a responsible authority shall be implemented by the organization in the absence of a specifically developed food safety plan for the organization. The organization shall: i. Maintain a current record indicating that is has reviewed the food safety plan and ensure its scope of risk assessment covers all products sold by the organization; and

ii. Document where changes in the food safety plan have impacted their Good Agricultural/Aquaculture Practices.

Clause: 2.4.3.2 | Item: Where an organization has developed its own food safety plan, either by choice or due to product(s) not included within the scope of a HACCP-Based model as per 2.4.3.1, it shall be implemented and maintained and outline the means by which the organization controls and assures food safety of the products or product groups included in the scope of the SQF certification and their associated processes.

More than one HACCP food safety plan may be required to cover all products included in the scope of certification.

Clause: 2.4.3.3 | Item: The food safety plan or plans shall be developed and maintained by a multidisciplinary team that includes the SQF Practitioner and those site personnel with technical, production, and engineering knowledge of the relevant products and associated processes. Where the relevant expertise is not available on site, advice may be obtained from other sources to assist the food safety team.

Clause: 2.4.3.4 | Item: The scope of each food safety plan shall be developed and documented including the start and end-point of the processes under consideration and all relevant inputs and outputs.

Clause: 2.4.3.5 | Item: Product descriptions shall be developed and documented for all products included in the scope of the food safety plans. This shall reference the finished product specifications plus any additional information relevant to product safety, such as pH, Aw, composition.

Clause: 2.4.3.6 | Item: The intended use of each product shall be determined and documented by the food safety team. This shall include target consumer groups, the potential for consumption by vulnerable groups of the population, requirements for further processing if applicable, and potential alternative use of the product.

Clause: 2.4.3.7 | Item: The food safety team shall develop and document a flow diagram covering the scope of each food safety plan. The flow diagram shall include every step in the process of primary production, all agricultural inputs, packaging material, and service inputs (e.g. water, steam, gasses as appropriate), process delays, and all process outputs including feed, waste and rework. Each flow diagram shall be confirmed by the food safety team during all stages and hours of operation.

Clause: 2.4.3.8 | Item: The food safety team shall identify and document all food safety hazards that can reasonably be expected to occur at each step in the processes, including agricultural/aquaculture inputs.

Clause: 2.4.3.9 | Item: The food safety team shall conduct a hazard analysis for every identified hazard, to identify which hazards are significant, i.e. their elimination or reduction to an acceptable level is necessary to ensure food safety. The methodology for determining hazard significance shall be documented and used consistently to assess all potential hazards.

Clause: 2.4.3.10 | Item: The food safety team shall determine and document the control measures that must be applied to all significant hazards. More than one control measure may be required to control an identified hazard, and more than one significant hazard may be controlled by a specific control measure.

Clause: 2.4.3.11 | Item: Based on the results of the hazard analysis (refer to 2.4.3.9), the food safety team shall identify the steps in the process where control must be applied to eliminate a significant hazard or reduce it to an acceptable level (a critical control point or CCP). In instances where a significant hazard has been identified at a step in the process, but no control measure exists, the food safety team shall modify the process to include an appropriate control measure.

Clause: 2.4.3.12 | Item: For each identified CCP, the food safety team shall identify and document the limits that separate safe from unsafe product. The food safety team shall validate the critical limits to ensure the designated level of control of the identified food safety hazard(s) and that all critical limits and control measures individually or in combination effectively provide the level of control required (refer to 2.5.2.1)

Clause: 2.4.3.13 | Item: The food safety team shall develop and document procedures to monitor CCPs to ensure they remain within the established limits (2.4.3.12). Monitoring procedures shall identify the personnel assigned to conduct testing, the sampling and test methods, and the test frequency.

Clause: 2.4.3.14 | Item: The food safety team shall develop and document deviation procedures that identify the disposition of affected product when monitoring indicates a loss of control at a CCP. The procedures shall also prescribe actions to correct the process step to prevent recurrence of the safety failure.

Clause: 2.4.3.15 | Item: The documented and approved food safety plan(s) shall be implemented in full. The effective implementation shall be monitored by the food safety team, and a full review of the documented and implemented plans shall be conducted at least annually, or when changes to the process, equipment, inputs or other changes affecting product safety occur.

Clause: 2.4.3.16 | Item: Implemented food safety plans shall be verified as part of SQF System verification (refer to 2.5).

Clause: 2.4.3.17 | Item: Where food safety regulations in the country of production and destination (if known) prescribe a food safety control methodology other than the Codex Alimentarius Commission HACCP guidelines, the food safety team shall implement food safety plans that meet both Codex and food regulatory requirements.

Clause: 2.4.4 | Item: Approved Supplier Program (Mandatory)

Clause: 2.4.4.1 | Item: Agricultural/aquaculture inputs, harvested product, pre-market ready livestock, market ready product and packaging materials that impact on finished product food safety shall be supplied by an approved supplier.

Clause: 2.4.4.2 | Item: The receipt of agricultural/aquaculture inputs, harvested product, pre-market ready livestock, market ready product and packaging materials received from non-approved suppliers shall be acceptable in an emergency situation provided they are inspected or analyzed before use.

Clause: 2.4.4.3 | Item: The responsibility and procedure for selecting, evaluating, approving and monitoring an approved supplier shall be documented and implemented.

Clause: 2.4.4.4 | Item: The site's food defense plan (refer to 2.7.1.1) shall include measures to secure incoming materials and ingredients and protect them from deliberate acts of sabotage or terrorist-like incidents.

Clause: 2.4.4.5 | Item: The site's food fraud vulnerability assessment (refer to 2.7.2.1) shall include the site's susceptibility to raw material or ingredient substitution, mislabeling, dilution and counterfeiting which may adversely impact food safety.

Clause: 2.4.4.6 | Item: The food fraud mitigation plan (refer to 2.7.2.2) shall include methods by which the identified vulnerabilities from ingredients and materials shall be controlled.

Clause: 2.4.4.7 | Item: Agricultural/aquaculture inputs, harvested product, pre-market ready livestock, market ready product and packaging materials received from other facilities under the same corporate ownership, shall be subject to the same specification requirements (refer to 2.3.2) and approved supplier requirements as all other material providers.

Clause: 2.4.4.8 | Item: The approved supplier program shall be based on the prior performance of a supplier and the risk level of received goods and shall contain as a minimum: i. Agreed specifications; ii. Reference to the rating of the level of risk applied to the approved supplier; iii. A summary of the food safety controls implemented by the approved supplier; iv. Methods for granting approved supplier status;

v. Methods and frequency of monitoring approved suppliers; vi. Details of the certificates of conformance if required, and vii. Methods and frequency of reviewing approved supplier performance and status.

Clause: 2.4.4.9 | Item: Supplier audits shall be based on risk and shall be conducted by individuals knowledgeable of applicable regulatory and food safety requirements risk and trained in auditing techniques.

Clause: 2.4.4.10 | Item: A register of approved supplier and records of inspections and audits of approved suppliers shall be maintained.

Clause: 2.4.5 | Item: Non-conforming Product or Equipment

Clause: 2.4.5.1 | Item: Non-conforming product, agricultural/aquaculture inputs, packaging or equipment shall be quarantined, handled, re-worked or disposed of in a manner that minimizes the risk of inadvertent use, improper use or risk to the integrity of finished product.

Clause: 2.4.5.2 | Item: Records of the handling and disposal of non-conforming product shall be maintained, minimally including grower/producer name, farm location, quantity and final disposition.

Clause: 2.5 | Item: SQF System Verification

Clause: 2.5.1 | Item: Validation and Effectiveness (Mandatory)

Clause: 2.5.1.1 | Item: The methods, responsibility and criteria for ensuring the effectiveness of Good Agricultural/Aquaculture Practices and production programs, and validating critical food safety limits to ensure they achieve their intended purpose shall be documented and implemented. The methods applied shall ensure that: i. Good Agricultural/Aquaculture Practices are confirmed to ensure they achieve the required result;

ii. Critical food safety limits are validated, and re-validated annually; iii. Changes to the processes or procedures are assessed to ensure controls are still effective.

Clause: 2.5.1.2 | Item: Records of all validation activities shall be maintained.

Clause: 2.5.2 | Item: Verification Activities (Mandatory)

Clause: 2.5.2.1 | Item: A verification schedule outlining the verification activities, their frequency of completion and the person responsible for each activity shall be prepared and implemented.

Clause: 2.5.2.2 | Item: The methods, responsibility and criteria for verifying monitoring of Good Agricultural/Aquaculture Practices, critical control points and other food safety controls, and the legality of certified products, shall be documented and implemented. The methods applied shall ensure that personnel with responsibility for verifying monitoring activities authorize each verified record.

Clause: 2.5.2.3 | Item: Records of the verification of monitoring activities shall be maintained.

Clause: 2.5.3 | Item: Corrective and Preventative Action (Mandatory)

Clause: 2.5.3.1 | Item: The responsibility and methods outlining how corrections and corrective actions are determined, implemented and verified, including the identification of the root cause and resolution of non-compliance of critical food safety limits, and deviations from food safety requirements, shall be documented and implemented.

Clause: 2.5.3.2 | Item: Records of all investigation and resolution of non-conformities including their corrections and corrective action shall be maintained.

Clause: 2.5.4 | Item: Product Sampling, Inspection and Analysis

Clause: 2.5.4.1 | Item: The sampling, inspecting and/or analyzing and release of finished product shall be documented and implemented. The procedures applied shall ensure: i. Inspections and analyses are completed at regular intervals as required and to agreed specification (e.g. MRL’s as per 2.3.5) and regulatory and labeling requirements;

ii. All analyses are conducted to nationally recognized methods or alternative methods which are validated as equivalent to the nationally recognized methods; iii. Release of products to customers is approved by authorized personnel.

Clause: 2.5.4.2 | Item: On-site personnel that conduct product testing shall participate in an applicable proficiency testing program at least annually to ensure accuracy of results.

Clause: 2.5.4.3 | Item: Where external laboratories are utilized to conduct input or product analysis, the laboratories shall be accredited to ISO 17025 or an equivalent national standard, and shall be included on the site's contract service specifications register (refer to 2.3.3.1)

Clause: 2.5.5 | Item: Internal Audits (Mandatory)

Clause: 2.5.5.1 | Item: The methods and responsibility for scheduling and conducting internal audits to verify the effectiveness of the SQF System shall be documented and implemented. Internal audits shall be conducted at least annually. The methods applied shall ensure: i. All applicable requirements of the SQF Food Safety Code are audited as per the SQF Audit Checklist or equivalent tool; ii. Correction and corrective action of deficiencies identified during the internal audits are undertaken;

iii. Audit results are communicated to relevant management personnel and staff responsible for implementing and verifying corrective actions; and iv. Records of internal audits and any corrections and corrective action taken as a result of internal audits shall be maintained.

Clause: 2.5.5.2 | Item: Staff conducting internal audits shall be trained and competent in internal audit procedures.

Clause: 2.5.5.3 | Item: Regular inspections of the facility and equipment shall be planned and carried out to verify Good Agricultural Practices and building/equipment maintenance is compliant to the SQF Food Safety Code. The supplier shall: i. Take correction or corrective and preventative action; and ii. Maintain records of inspections and any corrective action taken.

Clause: 2.5.5.4 | Item: Where practical staff conducting internal audits shall be independent of the function being audited.

Clause: 2.6 | Item: Product Identification, Trace, Withdrawal and Recall

Clause: 2.6.1 | Item: Product Identification (Mandatory)

Clause: 2.6.1.1 | Item: A product identification system shall be implemented to ensure: i. Agricultural/Aquaculture inputs, work in progress and finished product are clearly identified during all stages of receipt, operations, storage, shipping and transportation and dispatch; and ii. Finished product is labeled to the customer specification and/or regulatory requirements.

Clause: 2.6.1.2 | Item: Product identification records shall be maintained.

Clause: 2.6.2 | Item: Product Trace (Mandatory)

Clause: 2.6.2.1 | Item: The responsibility and methods used to trace product shall be documented and implemented to ensure: i. Finished product is traceable to the customer (one up) and provides traceability through the process to the agricultural input supplier and date of receipt of raw materials, food contact packaging and materials and other inputs (one back);

ii. Traceability is maintained where product is reworked; and iii. The effectiveness of the product trace system shall be reviewed at least annually as part of the product recall and withdrawal review (refer to 2.6.3.3).

Clause: 2.6.2.2 | Item: Records of agricultural/aquaculture inputs and packaging material receipt and use, and product shipping and transportation shall be maintained.

Clause: 2.6.3 | Item: Product Withdrawal and Recall (Mandatory)

Clause: 2.6.3.1 | Item: The responsibility and methods used to withdraw or recall product shall be documented and implemented. The procedure shall: i. Identify those responsible for initiating, managing and investigating a product withdrawal or recall; ii. Describe the procedures to be implemented by site management;

iii. Outline a communication plan to inform customers, consumers, authorities and other essential bodies in a timely manner appropriate to the nature of the incident; and iv. Ensure that SQFI and the certification body are listed as an essential body for notification of a recall or withdrawal.

Clause: 2.6.3.2 | Item: Investigation shall be undertaken to determine the cause of a withdrawal, mock recall or recall and details of investigations and any action taken shall be documented.

Clause: 2.6.3.3 | Item: The product withdrawal and recall system shall be reviewed, tested and verified as effective at least annually and include the traceability requirement of 2.6.2.1.

Clause: 2.6.3.4 | Item: SQFI and the certification body shall be notified in writing within twenty-four (24) hours upon identification of a food safety event that requires public notification. SQFI shall be notified at foodsafetycrisis@sqfi.com.

Clause: 2.7 | Item: Food Defense and Food Fraud

Clause: 2.7.1 | Item: Food Defense Plan (Mandatory)

Clause: 2.7.1.1. | Item: The methods, responsibility and criteria for preventing food adulteration caused by a deliberate act of sabotage or terrorist-like incident shall be documented, implemented and maintained.

Clause: 2.7.1.2. | Item: A food defense plan shall include: i. The name of the senior site management person responsible for food defense; ii. The methods implemented to ensure only authorized personnel have access to equipment, vehicles, operations and storage areas through designated access points; iii. The methods implemented to protect sensitive operational points from intentional adulteration;

iv. The measures taken to ensure the secure receipt and storage of Agricultural/aquaculture inputs, packaging, equipment and hazardous chemicals; v. The measures implemented to ensure agricultural/aquaculture inputs, packaging materials, work-in progress and finished products are held under secure storage and transportation conditions; and vi. The methods implemented to record and control access to the premises by employees, contractors, and visitors.

Clause: 2.7.1.3 | Item: The food defense plan shall be reviewed and challenged at least annually and appropriately documented.

Clause: 2.7.2 | Item: Food Fraud

Clause: 2.7.2.1 | Item: The methods, responsibility and criteria for identifying the site's vulnerability to food fraud shall be documented, implemented and maintained. The food fraud vulnerability assessment shall include the site's susceptibility to product substitution, mislabeling, dilution and counterfeiting or stolen goods which may adversely impact food safety.

Clause: 2.7.2.2 | Item: A food fraud mitigation plan shall be developed and implemented which specifies the methods by which the identified food fraud vulnerabilities shall be controlled.

Clause: 2.7.2.3 | Item: The food fraud vulnerability assessment and mitigation plan shall be reviewed and verified at least annually.

Clause: 2.7.2.4 | Item: Records of reviews of the food fraud vulnerability assessment and mitigation plan shall be maintained.

Clause: 2.8 | Item: Allergen Management

Clause: 2.8.1 | Item: Allergen Management for Primary Production (Mandatory)

Clause: 2.8.2.1 | Item: The responsibility and methods used to control allergens and to prevent sources of allergens from contaminating product shall be documented and implemented. The allergen management program shall include: i. A risk analysis of those Agricultural/aquaculture inputs and processing aids, including food grade lubricants, that contain food allergens; ii. An assessment of workplace-related food allergens from locker rooms, vending machines, lunch rooms, visitors;

iii. A list of allergens which is accessible by relevant staff; and iv. The hazards associated with allergens and their control incorporated into the food safety plan.

Clause: 2.8.2.2 | Item: Product labeling, in accordance with regulatory requirements, shall include allergens where risks from cross contamination have been documented.

Clause: 2.9 | Item: Training

Clause: 2.9.1 | Item: Training Requirements

Clause: 2.9.1.1 | Item: Appropriate training shall be provided for personnel carrying out the tasks essential to the effective implementation of the SQF System and the maintenance of food safety and regulatory requirements.

Clause: 2.9.2 | Item: Training Program (Mandatory)

Clause: 2.9.2.1 | Item: An employee training program shall be documented and implemented. It shall outline the necessary competencies for specific duties and the training methods to be applied for those staff carrying out tasks associated with: i. Developing and applying Good Agricultural Practices, Good Production Practices or Good Aquaculture Practices; and ii. Applying food regulatory requirements.

Clause: 2.9.3 | Item: Instructions

Clause: 2.9.3.1 | Item: Instructions shall be available in the languages relevant to the staff, explaining how all tasks critical to meeting regulatory compliance, the maintenance of food safety and process efficiency are to be performed.

Clause: 2.9.4 | Item: HACCP Training Requirements

Clause: 2.9.4.1 | Item: Where a HACCP-based model or Group/Multi-site program is not used then HACCP training shall be provided for staff involved in developing and maintaining food safety plans.

Clause: 2.9.5 | Item: Language

Clause: 2.9.5.1 | Item: Training materials and the delivery of training shall be provided in language understood by staff.

Clause: 2.9.6 | Item: Refresher Training

Clause: 2.9.6.1 | Item: The training program shall include provision for identifying and implementing the refresher training needs of the organization.

Clause: 2.9.7 | Item: Training Skills Register

Clause: 2.9.7.1 | Item: A training skills register describing who has been trained in relevant skills shall be maintained.