I'm not a SQF user so disagreements welcome. Here's my take (below) based on these quotes from SQF Standard/Guidance -
(1) HACCP The Hazard Analysis Critical Control Point and refers to the following two universally
accepted guidelines and definitions contained therein:
(a) HACCP guidelines developed and managed by the Food and Agriculture
Organization’s CODEX Alimentarius Commission. Hazard Analysis and Critical
Control Point (HACCP) System and
Guidelines for its Application – Annex to CAC/RCP 1 – 1969, Rev. 4-2003), – “A
system, which identifies, evaluates and controls hazards which are significant for
(b) HACCP guidelines developed and managed by the National Advisory Committee on
Microbiological Criteria for Foods (NACMCF). Hazard Analysis and Critical Control
Point Principles and application Guidelines, Adopted August 14, 1997. “A systematic
approach to the identification, evaluation, and control of food safety hazards”
together referred to as the HACCP Guidelines.
(2) HACCP Method The implementation of pre-requisite programs and the application of HACCP principles in
the logical sequence of the twelve steps as described in the current edition of the CODEX
Alimentarius Commission Guidelines, or the current edition of the HACCP guidelines
developed and managed by the NACMCF. The SQF Code utilizes the HACCP method to
control food safety hazards and other quality threats in the segment of the food chain
(3) HACCP Plan A document prepared in accordance with the HACCP method to ensure control of hazards
which are significant for food safety in the segment of the food chain under consideration.
(4)(a) SQF Level 2 – Food Safety Plan
Level 2 incorporates all Level 1 requirements, but also requires the supplier to first, identify hazards
that can impact product safety; second, conduct a food safety hazard analysis of the product (s) and
its process (es); and third, identify actions to eliminate, prevent or reduce identified hazards to an
acceptable level. These steps must be achieved using an approved HACCP methodology (refer to
section 2, below). Level 2 requirements are found in the center column in module 2 of the SQF Code,
(4)(b) SQF Level 3 – Food Quality Plan
Level 3 incorporates all Level 1 and Level 2 System requirements. At this level, the supplier is also
required to use an
d approved HACCP methodology to identify and assess food quality hazards and
document the action (s) taken to eliminate, reduce or prevent their occurrence. Quality hazards and
their controls can be included in the same HACCP study as performed for food safety hazards, or can
be documented separately. However, if incorporated food safety hazards and their controls must be
clearly distinguished from food quality hazards.
As I understand, Food Safety Plan is an SQF synonym for HACCP Plan
AFAI can see yr phrase “critical raw material” is nowhere mentioned in the SQF Code.
From above quotes I suggest allergenic hazards are positioned within (4a)
From (2,3) this would also apply to allergenic control programs if categorized as Prerequisites.
Any relevant factors which are not safety-related should then be positioned in (3b), ie within the SQF Food Quality Plan. The scope of the “relevant factors” is illustrated in the Guidance. It will (specifically) obviously depend on yr product/process.
PS - Just as a side-note, "Quality" has a wide and varied range of interpretations. For example ISO 9001 = (ISO) Quality, ISO 22000 = (ISO) Safety. Many haccp food texts refer (loosely) to "safety and wholesomeness" as = Haccp/Quality respectively. Predictably, "Quality" is not defined in the SQF Glossary.