Developing an SQF Compliant Internal Audit Program

Internal Audits are vital in ensuring the health and effectiveness of an organization. They not only evaluate the efficacy of a company’s internal control. They also ensure compliance with laws and regulations, safeguard assets, and facilitate the achievement of organizational ...

Developing an SQF Compliant Internal Audit Program

Internal Audits are vital in ensuring the health and effectiveness of an organization. They not only evaluate the efficacy of a company’s internal control. They also ensure compliance with laws and regulations, safeguard assets, and facilitate the achievement of organizational goals.

Going beyond mere periodic assessments, internal audits serve as the cornerstone of an organization’s operational health and its continual pursuit of excellence. By examining and critiquing a company’s practices and controls, internal audits identify discrepancies and vulnerabilities, fostering value addition and optimization.

Central to Internal Audits is the assessment of the effectiveness of a company’s internal controls, which are systems and procedures designed to ensure compliance with relevant regulations and the SQF Code. An effective Internal Audit program assures proper controls or identifies areas of improvement.

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One often overlooked aspect of Internal Audits is their ability to instill a culture of continuous improvement. Effective Internal Audits not only pinpoint problems but also recommend solutions and best practices, promoting a learning and growth environment within the Organization and, therefore, an improvement of the SQF Food Safety Management System (FSMS)

Resource limitations often pose a substantial challenge in the realm of Internal Audits. Conducting in-depth Internal Audits demands personnel with expertise in auditing methods, the SQF Code, and the operation. These audits, which require a scheduled and through execution, are resource intensive in terms of time and manpower. For numerous organizations, particularly smaller ones, allocating required resources for an extensive internal audit program can be a financially and logistically daunting task. These constraints may result lack of adherence to the audit schedule or less comprehensive audits, potentially to an incomplete assessment of the organization’s SQF FSMS.

To effectively develop and implement an Internal Audit Program that complies with the SQF FSMS requirements, consider the following strategies:

1. Assign and Empower the SQF Practitioner

The SQF Practitioner is typically the subject matter expert on auditing methods and SQF Code requirements. This key position should take charge of the Internal Audit Program. This includes defining audit methods, scheduling audits, and training internal auditors.

2. Strategically Schedule Audits

Plan internal audits to cover all SQF Code Elements within a year. While the SQF Code doesn’t specify a schedule, I have experienced that spreading audits throughout the year can be beneficial. This approach allows for more detailed evaluation of the programs associated with the SQF FSMS. Integrating audits of Systems Elements (Module 2) monthly, along with Good Industry Practice Elements in the existing inspection process, has proven to be an effective strategy for me in the past.

2. Develop a Comprehensive Audit Checklist

Utilize the checklist provided by SQFI, enhancing it with additional information for clarity. Simplify the technical language of the SQF Code on the checklist to facilitate understanding and compliance assessment. Include columns specifying required documents for review and personnel to be interviewed or observed, streamlining the audit process.

4. Invest in Auditor Training

Prioritize training for the Lead Auditor and, if possible, the entire Internal Auditing Team. Training should focus on internal audit skills based on the ISO 190011 – Auditing Management Systems Standard. Empowered and knowledgeable auditors lead to a more effective audit process.

5. Focus on Objective Evaluation

Internal audits should be about gathering objective evidence, not fault-finding. This approach ensures a fact-based assessment of the SQF FSMS.

6. Document the Audit Process Thoroughly

Create detailed forms to capture all information during document reviews, interviews, and observations. This documentation forms the basis of the Internal Audit report and should include both conformances and non-conformances.

7. Implement and Analyze Corrective Actions

Perform a root cause analysis for each non-conformance identified and implement appropriate corrective actions.

8. Monitor and Verify Corrective Actions

The audit process extends beyond identifying corrective actions. Monitor the implementation of these actions and verify their effectiveness after 60-90 days to ensure they address the non-conformances adequately.

9. Solicit and Apply Feedback

Post-audit, gather feedback from internal auditors about the methods and documentation used. Use this feedback to refine and improve the internal audit process continually.

By following these steps, you can establish a robust and compliant Internal Audit Program that not only meets the 2.5.4 Element of the SQF Standard but also fosters continuous improvement within your organization.


Smaller organizations can optimize resources by training multi-skilled auditors, leveraging external audit expertise for training or joint audits, and using technology to streamline audit processes and documentation.
An effective audit checklist should cover all SQF Code Elements, specify required documents, and identify key personnel for interviews. It should simplify the SQF Code’s technical language to ensure clarity and ease of use during audits.
By not only identifying non-conformances but also recommending practical solutions and best practices, internal audits encourage learning and operational enhancements, fostering a proactive culture of continual development.
Best practices include scheduling follow-up audits to verify the implementation and effectiveness of corrective actions within 60-90 days, integrating feedback mechanisms, and adjusting audit strategies based on observed outcomes to ensure continuous improvement.

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Picture of Radojka Barycki

Radojka Barycki

Radojka Barycki is an Award-Winning Quality Assurance, Food Safety, Training and Consulting Professional with 24+ years’ experience with demonstrated success in the development, implementation, and improvement of Quality and Food Safety Management Systems (SQF, BRCGS, FSSC2200)
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