
Under the proposed changes to SQF Code Edition 10, if a minor non-conformance is not fully addressed before your next audit, it could be escalated to a major.
You may ask: why are they doing that? Because if a previously flagged minor issue hasn’t been properly corrected and verified, it probably indicates a deeper problem—one that could impact your certification status.
In this post, we’ll explore how this update affects your Corrective and Preventive Action (CAPA) Program and how you can stay on top by tightening your response and resolution processes.
Background Information: Understanding the SQF Code Edition 10 Updates: What It Means for Your Business
The original (repeat) non-conformance remains classified as a minor. But failure to resolve it effectively becomes an additional non-conformance against your Corrective and Preventive Action (CAPA) Program, signaling that your system for managing issues isn’t working as it should. And this one is rated as Major.
This is not a new expectation—addressing all non-conformances effectively has always been a requirement. What’s changing is how auditors apply that expectation: they are now more likely to escalate unresolved minors to majors when CAPA is not demonstrated to be effective. The enforcement approach is tightening up.
The minor non-conformance is not why it matters. After all, by definition, a minor doesn’t pose an immediate food safety risk. It might eventually if things deteriorate. But this is not the case in this instance.
The real issue is the major non-conformance indicates a significant program breakdown that needs urgent attention.
This change reinforces a clear message: no issue is too small to fix. Each audit finding must be fully resolved and documented in a timely manner. With SQF Edition 10 audits on the horizon, now is the time to ensure your CAPA program is working as it should, and issues are being effectively addressed.
Track Corrective Actions Like You Track Critical Control Points (CCPs): Treat corrective actions with the same urgency and structure: log them, assign owners, verify the fix, and close them out. If needed, build a simple spreadsheet to track open items and review them weekly. (Mention CA Log?)
Set Internal Deadlines, Not Audit Deadlines: Don’t wait until just before your next SQF audit. Set internal closure deadlines 30–60 days post-audit to allow time for verification and follow-up.
Check Your Corrective Action Log: Ask: - Are corrective actions being verified for effectiveness? - Are we fixing every instance of the issues we find? - Are problems recurring? - Are we truly finding and fixing root causes?
Use “Minors” as Training Opportunities: Small issues can teach big lessons. Turn minor non-conformances into real-time training to reinforce how attention to detail strengthens your food safety system.
Involve Department Leads: CAPA should be a shared responsibility. Bring in maintenance, sanitation, and production leads—not just QA. Cross-functional involvement boosts accountability and better root cause analysis.
Document Everything: Auditors want to see not just the action, but evidence that it was effective. Keep clear, dated records of what was done and when. (back to the Corrective Action Log!)
Stay proactive. By consistently tying non-conformances back to your CAPA program and closing the loop, even on minor issues, you reduce risk, avoid major non-conformances, and keep your SQF certification secure. It’s also a good way to practice and strengthen your CAPA process, building everyday habits that make your system more resilient and audit-ready.
The purpose of this update is evident: to ensure food safety improvements are real, lasting, and verifiable. It’s about establishing a corrective action process that enables you and your team to manage risk effectively, every day, not just on audit day.
Our QIMA team hosted a roundtable discussion featuring guest panelists from SQFI and Navigate Food Safety Solutions, where we explored how upcoming changes could impact facilities. Watch the full recording here.
QIMA offers SQF certification and audits for brands across the food industry.
Contact us to learn more about SQF certification or book an audit today.
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