Validation & Verification of Control Measures

Aligned with SQF Code Edition 9 – System Element 2.10.2

Requirement Overview

SQF Code Edition 9, System Element 2.10.2, states:

“Control measures, including Critical Control Points (CCPs), operational prerequisite programs (OPRPs), and other food safety controls, shall be validated and verified to ensure they achieve the intended food safety outcome.”

Validation confirms that your controls can effectively prevent or minimize food safety hazards. Verification ensures they are consistently applied and functioning as intended.

Disclaimer: Food Safety Systems is not affiliated with or endorsed by the Safe Quality Food Institute (SQFI). This content is intended for educational and compliance guidance only. Please refer to www.sqfi.com for official certification and audit materials.

Key Compliance Objectives

  • Apply scientific validation to all critical and operational control measures

    Routinely verify CCPs, OPRPs, and PRPs

    Maintain traceable validation records

    Engage qualified individuals (e.g., PCQIs) in oversight and review

Step-by-Step Compliance Implementation

1. Identify Controls That Require Validation & Verification

  • Control Categories:

    • • CCPs – e.g., cooking, chilling, metal detection

      • OPRPs – e.g., allergen changeover cleaning, weight checks

      • PRPs – e.g., sanitation, personal hygiene, pest control

    Evidence to Maintain:

    • Inventory of all food safety controls

      Classification (CCP, OPRP, PRP) and rationale

2. Conduct Scientific Validation Studies

  • Accepted Validation Methods:

    • Published scientific literature or regulatory standards

      In-plant studies (e.g., challenge or inoculation studies)

      Third-party testing or industry benchmarks

    Evidence to Maintain:

    • Completed validation studies with documented methodology

      References used to justify control effectiveness

      Validation sign-off by PCQI or qualified personnel

3. Verify Control Measures Routinely

  • Routine Verification Includes:

    • Direct observation of CCP monitoring

      Review of records (e.g., sanitation logs, temperature checks)

      Equipment calibration (e.g., metal detectors, thermometers)

    Evidence to Maintain:

    • Verification logs/checklists

      Equipment calibration reports

      Monitoring activity records

4. Implement Corrective Action Protocols

  • Triggers for Action:

    • Deviation from critical limits or procedures

      Validation study failures

      Inadequate verification results

    Evidence to Maintain:

    • Corrective action request (CAR) forms

      Root cause analyses

      Documentation of follow-up and resolution

5. Review and Revalidate When Needed

  • Revalidation May Be Required After:

    • Equipment or process changes

      New scientific findings or audit recommendations

      Recalls or serious food safety incidents

    Evidence to Maintain:

    • Revalidation schedule and review log

      Updated control documentation

      Version-controlled validation reports

Common Audit Findings & Recommended Fixes

Audit Finding Recommended Action
No scientific support for CCP parameters Conduct or reference formal validation studies
Missing calibration logs for critical tools Schedule regular calibration and keep logs
PRPs not routinely verified Implement a verification checklist for all PRPs
Controls not revalidated after process change Trigger revalidation based on risk-based assessment

Auditor Verification Checklist

Auditors will typically:

  • Review validation protocols and data

    Verify equipment calibration and verification records

    Observe monitoring and verification practices

    Confirm corrective actions and revalidation documentation

Implementation Roadmap

Build Your Program

  • Identify all applicable control measures

    Categorize each as CCP, OPRP, or PRP

Train and Validate

  • Conduct or obtain scientific validation studies

    Train team on control application and verification

Operate and Monitor

  • Implement scheduled verification activities

    Maintain daily logs and calibration records

Improve Continuously

  • Revalidate controls after key changes

    Review validation effectiveness annually

Why This Matters?

Validated and verified controls:

  • Provide confidence that food safety hazards are effectively managed

    Reduce the risk of non-compliance, product recalls, and legal liability

    Strengthen your SQF program and audit performance

    Demonstrate a data-driven commitment to food safety

Looking for Support Materials?

Food Safety Systems offers:

  • Validation protocol templates (CCP, allergen, sanitation)

    CCP/PRP verification checklists

    Calibration record forms

    Revalidation and change control logs