Internal Audit Program

Aligned with SQF Code Edition 9 – System Element 2.10.1

Requirement Overview

SQF Code Edition 9, System Element 2.10.1, requires:

“The methods and responsibilities for scheduling and conducting internal audits to verify the effectiveness of the SQF System shall be documented and implemented. Internal audits shall cover all applicable requirements of the SQF Food Safety Code and be conducted at least annually.”

Internal audits are essential for validating that the SQF System is fully implemented, effective, and continuously improving. A strong internal audit program ensures your business identifies risks before external audits do.

Disclaimer: Food Safety Systems is not affiliated with or endorsed by the Safe Quality Food Institute (SQFI). This document is for internal use and guidance. For official requirements, visit www.sqfi.com.

Key Compliance Objectives

  • Verify all elements of the SQF Code are implemented and maintained

    Identify non-conformances and improvement opportunities

    Ensure objective audit practices with qualified personnel

    Maintain comprehensive records of audits and actions taken

Step-by-Step Compliance Implementation

1. Establish an Internal Audit Program

  • Audit Program Must Include:

    • An annual schedule covering all SQF Code modules

      Assigned competent auditors, independent of the audited area

      Documented audit criteria and scope

    Evidence to Maintain:

    • Signed annual audit plan

      Auditor competency records and training certificates

      Audit scope mapped to relevant SQF Code clauses

2. Conduct Internal Audits

  • Audit Activities:

    • Review of policies, SOPs, and records

      Physical inspections and operational observations

      Interviews with team members on key procedures

    Evidence to Maintain:

    • Completed audit checklists

      Interview notes and photographic records (if applicable)

      Summary reports with objective findings

3. Identify Non-Conformances and Improvement Areas

  • Key Reporting Requirements:

    • Clearly categorize findings (e.g., major, minor, observation)

      Link each issue to specific SQF Code sections

      Include sufficient evidence or justification

    Evidence to Maintain:

    • Internal audit findings report

      Supporting documentation (photos, records, logs)

      Categorized non-conformance logs

4. Implement and Track Corrective Actions

  • Corrective Action Process:

    • Assign a responsible person

      Define deadlines and follow-up requirements

      Conduct effectiveness checks after implementation

    Evidence to Maintain:

    • Corrective action request (CAR) forms

      Root cause analysis documentation

      Verification notes showing resolution

5. Review and Update the Audit Program Annually

  • Update Triggers:

    • Completion of all scheduled audits

      Recurring findings or unresolved issues

      Organizational or regulatory changes

    Evidence to Maintain:

    • Annual review summary and sign-off

      Revised audit schedule or updated procedures

      Minutes from audit review meetings

Common Audit Findings & Recommended Fixes

Audit Finding Recommended Action
Internal audit not completed annually Establish an annual calendar with due dates
Audit scope missing SQF requirements Cross-reference plan with SQF Code checklist
Corrective actions not verified Implement CAR tracking and follow-up documentation
Auditor not independent or trained Train additional auditors and assign by department

Auditor Verification Checklist

SQF auditors will typically:

  • Review your internal audit plan and calendar

    Inspect completed audit reports and checklists

    Evaluate effectiveness of implemented corrective actions

    Verify auditor qualifications and role independence

Implementation Roadmap

Build Your Program

  • Develop a comprehensive internal audit schedule

    Assign independent and trained auditors

Train and Validate

  • Educate staff on audit procedures and roles

    Provide competency training for internal auditors

Operate and Monitor

  • Conduct internal audits according to schedule

    Record findings and corrective action follow-up

Improve Continuously

  • Analyze audit trends and system gaps

    Update audit plans and documentation annually

Why This Matters?

A well-executed internal audit program:

  • Confirms the SQF System is functioning as designed

    Detects potential gaps before they result in non-conformances

    Prepares your team for successful external certification

    Reinforces a culture of compliance and accountability

Need Help Structuring Your Internal Audit Program?

Food Safety Systems offers:

  • Editable internal audit SOP templates

    Sample audit checklists by SQF module

    Auditor competency evaluation forms

    Corrective action tracking logs and reports