Document Review Requirements for SQF 2000 (Safe Quality Food Standard)

[vpandora]

I am the document control coordinator for a food packaging manufacturing company that is ISO 9001:2008 certified and SQF Level 2 certified. I understand that ISO 9001 requires that documents under the QMS be "reviewed and updated as necessary", which leaves it up to the company to decide what is "necessary". There is no requirement that states you must review all documents annually.

However, SQF is a little trickier... it simply states:

"4.2.1 Document Control
4.2.1.1 The methods and responsiblity for ensuring personnel have access to current documents and maintaining document control shall be documented and implemented.
4.2.1.2 A register of current SQF 2000 System documents and amendments to documents shall be maintained. documents shall be safely stored and readily accessible."

Our ISO / SQF Practitioner argues that while ISO does not require document review annually, SQF does. I cannot find anything that explicitly supports that. What I think she is citing as proof is found under Management Review:

"4.1.4.1 Senior Management shall be responsible for reviewing the SQF 2000 System and documenting the review procedure. Reviews shall include:
i. The policies outlined in the Policy Statement;
ii. Internal and external audit findings;
iii. corrective actions and their investigations and resolution; and
iv. customer complaints and their resolution and investigation.
4.1.4.2 The SQF 2000 System in its entirety shall be reviewed at least annually"

Does the SQF 2000 System mean all documents too? When ISO 9001 says that management shall review the quality management system, it doesn't mean all the documents too, right?

What is your opinion of the actual requirement for document review under SQF?

[AndyN]

It's clear to me they are extending the idea of a review of the system to a review of the documentation - two somewhat different things. They may also be 'tainted' by their knowledge of other regulated industries where such a documentation review is also required. There's nothing explicit, no annual documentation review is needed, only a review of the management system.

[Sidney Vianna]

In Reply to Parent Post by vpandora

What is your opinion of the actual requirement for document review under SQF?

Are you aware of the Guidance for Developing, Documenting and Implementing an SQF 2000 System document? The guidance on section 4.1.4 reads

Senior Management shall assure that the entire SQF System is reviewed annually. This review shall include the policies outlined in company’s Policy Statement, findings in the regularly scheduled internal audits and external audits and customer complaints.
The Supplier must prepare a procedure documenting how the reviews of SQF System will be completed. The reviews must be conducted by a representative from the senior management team with the objective of ensuring the continued integrity of the food safety and quality management system. The annual review shall measure the effectiveness of the Pre-requisite Programs, the Food Safety Plan, other food safety controls and the Food Quality Plan. All reviews and major changes to the SQF 2000 System are to be documented by the SQF Practitioner. Documentation shall include reasons for any changes. Major changes to a process, a process control or any change that could impact on the ability of the system to deliver a safe quality food may trigger a review of the Food Safety Plan and/or the Food Quality Plan in addition to the annual review. Any major change to Food Safety or Quality plans shall be validated and verified by the SQF Practitioner (Practitioner) before implementation.

Note: When completing an annual review of the SQF System, documents which should be considered include any document that might highlight deficiencies in the system, such as, customer complaint records, corrective action reports, internal and external audit reports and deviations from process control reports, etc.

[vpandora]

Thank you AndyN, Sidney...

I had not looked at the guidance for this particular issue, and completely forgot it existed. That does appear to support the idea that the only document (not including records) required to be reviewed annually is the policy statement.