Conducting Annual Management Reviews

Aligned with SQF Code Edition 9 – System Element 2.1.4

Requirement Overview

Under SQF Code Edition 9, System Element 2.1.4 requires:

“Top management shall review the SQF System at planned intervals, at least annually, to ensure its continuing suitability, adequacy, and effectiveness.”

This requirement ensures that food safety systems remain up-to-date, resourced, and responsive to operational and regulatory needs.

Disclaimer: This content is provided for educational purposes only and is not affiliated with or endorsed by the Safe Quality Food Institute (SQFI). For official SQF documentation, visit www.sqfi.com.

Key Compliance Objectives

  • Review the full SQF System at least once per year

    Engage cross-functional leadership in the review process

    Generate clear action plans with timelines

    Maintain formal documentation and follow-through

Step-by-Step Implementation Guide

1. Schedule and Prepare for the Review

  • Preparation Tips:

    • Schedule the review 10–11 months after your last certification audit

      Prepare key inputs such as:

      • - Audit results (internal, external, regulatory)

        - Customer complaints and non-conformance reports

        - Corrective and preventive actions (CARs/CAPAs)

        - Resource needs and policy changes
    Evidence to Maintain:

    • Scheduled meeting invitations with attendee list

      Pre-meeting documentation packet (inputs and review summaries)

2. Conduct the Structured Review

  • Discussion Points Must Include:

    • 1. Review of previous action items

      2. Internal/external audit results

      3. Incident and complaint analysis

      4. Resource adequacy (staffing, training, equipment)

      5. Updates needed to policies, SOPs, or food safety plans

    Evidence to Maintain:

    • Meeting agenda (pre-formatted or custom)

      Attendance logs signed by leadership

3. Document Decisions and Action Plans

  • Outputs Should Cover:

    • Approved system updates or changes

      Allocated resources or budget adjustments

      New measurable objectives

      Assignments of responsibility for follow-up actions

    Evidence to Maintain:

    • Signed and dated meeting minutes

      Action plan with assigned owners and timelines

4. Implement and Monitor Follow-Up Activities

  • Post-Review Execution Steps:

    • Communicate decisions and assignments to the relevant staff

      Track the implementation of each action item

      Document results and verify completion

    Evidence to Maintain:

    • Completed task records

      Implementation logs or verification forms

      Status reports for leadership review

Common Audit Findings & Recommended Fixes

Finding Corrective Strategy
No annual review conducted Implement a recurring meeting schedule and reminders
Incomplete documentation Use structured minute-taking templates
Lack of leadership participation Distribute pre-briefs and request signatures in advance
No follow-up actions implemented Track actions through a centralized review dashboard

Auditor’s Checklist for 2.1.4 Compliance

Auditors will review:

  • Official meeting minutes with documented leadership involvement

    List of previous action items and their implementation status

    Evidence of changes made to the food safety system

    Staff understanding of review outcomes during interviews

Implementation Roadmap

Plan the Review

  • Schedule the annual review on a shared calendar

    Collect relevant system data and previous review notes

Conduct the Review

  • Use a structured agenda aligned with SQF expectations

    Ensure attendance of top management and system owners

Document the Outcomes

  • Draft and approve meeting minutes

    Assign follow-up actions with due dates

Monitor Implementation

  • Track each action to closure

    Revisit progress at regular intervals

Why This Matters?

Annual management reviews are more than a certification requirement—they are a strategic tool to:

  • Ensure system adaptability and adequacy

    Identify and prioritize improvement opportunities

    Allocate appropriate resources for risk mitigation

    Reinforce leadership engagement and accountability

Need Support Conducting or Documenting a Management Review?

Food Safety Systems offers:

  • Review planning templates and checklists

    Meeting facilitation guides

    Structured minutes and action plan templates

    Implementation tracking tools for leadership