Establishing & Maintaining a Food Safety Policy Signed by Leadership
Aligned with SQF Code Edition 9 – System Element 2.1.2
Requirement Overview
According to SQF Code Edition 9, System Element 2.1.2 requires that:
“A food safety policy shall be established, documented, signed by senior management, and communicated to all personnel. The policy shall be reviewed annually and updated as necessary.”
This requirement ensures leadership commitment is documented and actively shared throughout the organization.
Note: This article is for educational and implementation support purposes and is not affiliated with or endorsed by the Safe Quality Food Institute (SQFI). For official SQF resources, visit www.sqfi.com.
Key Compliance Objectives
To meet compliance expectations, your food safety policy must be:
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✓ Documented (not verbal)
✓ Signed by senior leadership (e.g., CEO, GM, Plant Manager)
✓ Communicated clearly to all employees
✓ Reviewed annually and updated as needed
Key Implementation Steps
1. Develop a Compliant Food Safety Policy
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Your policy should align with:
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• GFSI-recognized schemes like SQF
• Applicable regulations (e.g., FSMA, FDA, CFIA)
• Internal goals and customer expectations
Include commitments to:
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• Meeting food safety and quality objectives
• Regulatory compliance
• Continuous improvement
• Accountability and employee engagement
Evidence Required:
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• Final signed policy document
• Document control metadata (version, date, approver)
- • GFSI-recognized schemes like SQF • Applicable regulations (e.g., FSMA, FDA, CFIA) • Internal goals and customer expectations
- • Meeting food safety and quality objectives • Regulatory compliance • Continuous improvement • Accountability and employee engagement
- • Final signed policy document • Document control metadata (version, date, approver)
2. Secure Leadership Signatures & Display the Policy
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Best Practices:
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• Use wet ink or secure digital signatures
• Display the signed policy in break rooms, production entrances, and common areas
• Include the policy in onboarding and handbooks
Evidence to Maintain:
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• Signed digital/hard copy of the policy
• Photos or location references where the policy is displayed
- • Use wet ink or secure digital signatures • Display the signed policy in break rooms, production entrances, and common areas • Include the policy in onboarding and handbooks
- • Signed digital/hard copy of the policy • Photos or location references where the policy is displayed
3. Communicate the Policy to All Employees
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Communication Methods:
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• New hire orientations
• Annual refresher trainings
• Team meetings or toolbox talks
• Company intranet or LMS
Evidence to Maintain:
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• Training logs or attendance sheets
• Sign-offs acknowledging policy awareness
• Meeting minutes or training materials
- • New hire orientations • Annual refresher trainings • Team meetings or toolbox talks • Company intranet or LMS
- • Training logs or attendance sheets • Sign-offs acknowledging policy awareness • Meeting minutes or training materials
4. Conduct Annual Policy Reviews & Updates
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Review Triggers:
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• Once per year (minimum)
• After significant incidents (e.g., recalls, audits)
• When standards or regulations change
Evidence to Maintain:
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• Annual review meeting notes
• Change records showing updates
• New version logs and policy re-distribution plans
- • Once per year (minimum) • After significant incidents (e.g., recalls, audits) • When standards or regulations change
- • Annual review meeting notes • Change records showing updates • New version logs and policy re-distribution plans
Common Audit Findings & Recommended Fixes
Finding
Recommended Fix
No signed policy available
Ensure proper documentation and leadership sign-off
Employees unaware of the policy
Reinforce communication via training and signage
Policy not reviewed annually
Schedule recurring review reminders
Policy too generic or outdated
Customize per site, sector, and current requirements
| Finding | Recommended Fix |
|---|---|
| No signed policy available | Ensure proper documentation and leadership sign-off |
| Employees unaware of the policy | Reinforce communication via training and signage |
| Policy not reviewed annually | Schedule recurring review reminders |
| Policy too generic or outdated | Customize per site, sector, and current requirements |