Based on SQF Code Edition 9 – System Element 2.11.1
Requirement Overview
SQF Edition 9, System Element 2.11.1 requires:
“A documented corrective and preventive action procedure shall be prepared and implemented to address non-conformities impacting food safety, legality, or regulatory compliance, and to prevent their recurrence.”
A CAPA program is essential to identify root causes of non-conformities and ensure lasting improvements in your food safety management system.
Disclaimer:Food Safety Systems is an independent training and advisory resource. This content is not affiliated with, endorsed by, or certified by the Safe Quality Food Institute (SQFI). Please visit www.sqfi.com for official certification details.
Key Compliance Objectives
✓ Establish a documented CAPA procedure
✓ Conduct structured root cause analysis
✓ Implement and verify corrective actions
✓ Maintain complete records for accountability and audits
Step-by-Step Compliance Implementation
1. Develop a Documented CAPA Procedure
Your Procedure Should Cover:
• Identification and documentation of non-conformities
• Root cause analysis (RCA) methodology
• Implementation of corrective and preventive actions
• Assignment of responsibilities and deadlines
• Verification of action effectiveness and closure
Evidence to Maintain:
• Approved CAPA SOP (Standard Operating Procedure)
• Records of staff training on CAPA roles
2. Identify and Record Non-Conformities
Common Sources:
• Internal or external audit findings
• Customer complaints
• Product deviations
• Equipment or process failures
• Completed RCA forms
• Justification of identified root cause(s)
• Investigator notes or facilitator sign-off
4. Implement Corrective and Preventive Actions
Plan Requirements:
• Defined tasks and responsible personnel
• Implementation timeline
• Preventive actions to reduce recurrence
Evidence to Maintain:
• Corrective Action Request (CAR) forms
• Preventive action plans
• Task completion logs with responsible party signatures
5. Verify CAPA Effectiveness
Verification Steps Include:
• Re-auditing affected process or area
• Confirming root cause has been eliminated
• Reviewing data for recurrence
Evidence to Maintain:
• Closed CAPA forms with verification sign-off
• Effectiveness review documentation
• Updated SOPs or training records as needed
Common Audit Findings & Solutions
Audit Finding
Recommended Action
No written CAPA procedure
Develop and approve a formal CAPA SOP
Root cause not identified or documented
Train on structured RCA techniques
Incomplete corrective action tracking
Use a CAPA tracking log and accountability form
No verification of effectiveness
Schedule follow-ups and maintain closure logs
Auditor Verification Checklist
Auditors will typically:
• Review your CAPA SOP
• Examine open and closed CAPA records
• Validate the use of RCA methods
• Confirm documented evidence of CAPA implementation and results
CAPA Program Roadmap
Build Your Program
✓ Approve your CAPA SOP
✓ Assign team roles and responsibilities
Train and Validate
✓ Train teams on reporting and RCA practices
✓ Conduct CAPA simulations or case studies
Operate and Monitor
✓ Record non-conformities and track actions
✓ Monitor deadlines and resolution
Improve Continuously
✓ Analyze CAPA trends
✓ Revise SOPs and training to prevent repeat issues
Why This Matters?
A strong CAPA process:
✓ Reduces repeat food safety issues
✓ Demonstrates regulatory readiness
✓ Supports a culture of continuous improvement
✓ Increases operational efficiency and accountability
Need Support Materials?
Food Safety Systems provides:
✓ CAPA SOP templates and workflows
✓ Root cause analysis tools and examples
✓ Action planning forms and closure logs
✓ Auditor-ready CAPA recordkeeping sheets