Developing an Effective Document Control Program for SQF Compliance

Effective management of documentation is crucial in ensuring food safety and quality. Controlling documents helps maintain compliance, consistent operations, product tracking, and efficient audits. For food businesses, essential documents include specifications, procedures, records of monitoring, logs of training, and audit ...

Document Control Program for SQF Compliance

Effective management of documentation is crucial in ensuring food safety and quality. Controlling documents helps maintain compliance, consistent operations, product tracking, and efficient audits. For food businesses, essential documents include specifications, procedures, records of monitoring, logs of training, and audit reports, among others.

The SQF Food Safety Management System (FSMS) requires a mandatory Document Control (2.2.2) and Records Program (2.2.3)

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How to Implement a Document Control System?

To implement a successful document control system, consider these strategies:

1. Create a Document Register

Keep a comprehensive list of all controlled documents, noting details like name, code, revision status, date, author, approvals, distribution, and the date of the next review.

2. Establish a Document Hierarchy

Categorize documents into levels such as policies, procedures, instructions, forms, and records, and clarify their interrelationships.

3. Define Roles and Responsibilities

Assign clear roles and responsibilities to those involved in the creation, review, approval, and distribution of documents.

    1. Identify Document Authors: The program owners should be the ones who write their own programs and related documentation.

    1. Define Reviewers: Have relevant process owners or specialized personnel review documents for accuracy and completeness.

    1. Establish Approvers: Typically, higher-ups like department heads or plant managers authorize documents before they are released or revised.

    1. Assign Distribution Roles: Ensure controlled distribution of documents to the right people by designated personnel.

In smaller firms, these roles might be combined or shared among various staff, while larger companies might have specialized teams for document control. Regardless, clear assignment of responsibilities ensures accountability and systematic governance.

4. Standardize Document Identification

Use a uniform numbering and titling system to easily identify document type, applicability, and version.

5. Specify Review Cycles:

Regularly review documents to keep them current, with critical documents reviewed annually and others every two to three years.

6. Control Document Versions

Release new versions of documents upon changes, noting the version number, date, author, and summary of changes. Archive old versions.

7. Limit Access and Distribute Controlled Copies

Restrict editing rights to prevent unauthorized changes and circulate read-only versions.

8. Manage Document Obsolescence

Remove outdated documents from active use but keep them in archives marked ‘Obsolete’ for legal reasons. One of the major pitfalls I have seen while working in the industry and as a consultant is the use of obsolete documents by front-line employees. It is important to emphasize to everyone at the facility the criticality of using the most updated version of documents. If you find a trend in this non-conforming practice, you must find the root cause analysis and implement a corrective action that would ensure the issue doesn’t reoccur. 

9. Train Employees

Educate staff involved in document control about policies, formats, hierarchies, version control, approvals, distribution, and archiving.

10. Audit Compliance

Regularly audit to ensure document accuracy, timely reviews, and adherence to the control system. To learn more, read our article on how to prepare for SQF audit.

In my experience as a food safety professional and consultant that helps companies to develop and implement SQF Food Safety Management Systems, the leverage of SQF software tools that allow efficient authoring, versioning, workflows, distribution, access, and archiving provide the basis for a strong Document Control and Management Program.

Record-keeping procedures should include methods and responsibilities for storage and destruction of records. A question often asked during my training sessions is for how long should records be kept. The answer is to follow regulatory requirements. For example, Food Safety Plan related records should be kept for a minimum of 2 years. Organic records should be kept at minimum for 5 years. You might also have customers that require records be kept for specific amounts of time. So, ensure that these requirements are included as well in your program. In addition to the length of storage, you should include provisions for securing the storage of records related to the SQF FSMS in a secure and dry place to ensure that they are not misplaced or damaged. 

In conclusion, investing in a robust Document Control and Records Keeping Program is crucial for food companies to enhance their food safety culture and achieve quality goals, ensuring organizational governance and regulatory compliance. For navigating the challenging environment and become SQF compliant, engaging an SQF consultant can provide the expertise and support needed to streamline processes and meet stringent standards.

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