Record Retention Requirements

Aligned with SQF Code Edition 10 – System Element 2.2.2

Requirement Overview

Under SQF Code Edition 10, System Element 2.2.2 states:

“Records shall be maintained for a minimum of three years or as required by legislation, whichever is longer, and be made available to authorized personnel upon request.”

A compliant recordkeeping system ensures traceability, supports audit readiness, and meets legal and certification obligations.

Note: This resource is for educational and internal implementation use only. Food Safety Systems is not affiliated with or endorsed by the Safe Quality Food Institute (SQFI). For official SQF requirements, visit www.sqfi.com.

Key Compliance Objectives

  • ✓ Maintain records for at least 3 years or as required by applicable laws

    ✓ Implement secure, organized storage systems (digital or physical)

    ✓ Establish controlled access and retrieval procedures

    ✓ Develop a clear disposal protocol for obsolete records

Step-by-Step Implementation Guide

1. Develop a Record Retention Schedule

  • What to Include:

    • • List of required documents (e.g., audits, training, CCP logs, verifications)

      • Retention periods based on SQF and regulatory requirements

      • Destruction method (e.g., shredding, digital wipe) for expired records

    Evidence to Maintain:

    • • Approved record retention schedule

      • Documentation showing regulatory alignment (e.g., FDA, FSMA, CFIA)

2. Implement a Secure Storage System

  • Options:

    • • Physical Storage: Fireproof filing cabinets with environmental controls

      • Digital Storage: Encrypted cloud-based platforms with automated backups

      • Hybrid Systems: Paper archives + digital logs for cross-referencing

    Evidence to Maintain:

    • • SOP section outlining storage systems

      • Photos/screenshots and encryption/backup records

3. Control Access and Retrieval

  • Requirements:

    • • Assign designated record custodians

      • Maintain logs of access/viewing activity

      • Use indexing tools for efficient searching (manual or digital)

    Evidence to Maintain:

    • • Access logs or permission tracking

      • Retrieval test results (response times, accuracy)

4. Train Staff and Verify Competency

  • Training Should Cover:

    • • Record types and how to recognize/label them

      • Secure handling and retrieval

      • Disposal timing and process

    Evidence to Maintain:

    • • Training attendance and certification records

      • Observations or verification logs showing proper handling

Common Audit Findings & Recommended Fixes

Audit Finding Corrective Strategy
Missing or misplaced records Create a formal document locator matrix
Retention period below 3 years Adjust schedule to meet or exceed minimum requirements
No disposal records or procedure Establish a documented and logged disposal protocol
Slow or failed retrieval of records Digitize indexing and implement periodic retrieval drills

Auditor’s Checklist for Record Retention (2.2.2)

Auditors may request:

  • • Your current record retention policy

    • Records from various departments and categories

    • Documentation showing secure and accessible storage

    • Retrieval test or spot check results during audit

Implementation Roadmap

Design Your System

  • ✓ Create a customized retention schedule

    ✓ Align record types with retention requirements

Establish Secure Storage

  • ✓ Set up digital or physical storage infrastructure

    ✓ Include redundancy and backup systems

Train and Transition

  • ✓ Train staff on identification, access, and disposal

    ✓ Migrate legacy documents if needed

Monitor and Maintain

  • ✓ Set reminders for review or expiration

    ✓ Conduct annual compliance checks

Why This Matters?

A well-managed recordkeeping system:

  • ✓ Demonstrates compliance with food safety standards

    ✓ Reduces liability and supports regulatory inspections

    ✓ Facilitates fast recall response or legal defense

    ✓ Enhances operational consistency and traceability

Need Help Organizing Your Recordkeeping System?

Food Safety Systems offers:

  • ✓ Record retention schedule templates

    ✓ Cloud-based or physical storage setup guidance

    ✓ Training modules and competency verification tools

    ✓ Annual audit readiness assessments

GET STARTED NOW

This document is for internal training and compliance use only. It is not affiliated with or endorsed by the Safe Quality Food Institute (SQFI).

Please refer to www.sqfi.com for official certification requirements.

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