I agree Charles
Everyone ought to follow Codex HACCP verification and validation systems and ignore the SQF confusion entirely (the definitions in SQF 8 do not clarify things at all)
2.5.1 Validation and Effectiveness (Mandatory)
188.8.131.52 The methods, responsibility and criteria for ensuring the effectiveness of all applicable elements of the
SQF Program shall be documented and implemented. The methods applied shall ensure that:
i. Good Manufacturing Practices are confirmed to ensure they achieve the required result;
ii. Critical food safety limits are validated, and re-validated annually; NO absolutely not........if your CCP has not changed (equipment, type, pack size etc) then you NEVER need to perform a VALIDATION again..........you're annual CCP review would require you to VERIFY all of the CCP including records and deviations to ensure the CCP VALIDATION is still controlling the hazard----if you were in constant deviation then you would want to perform a NEW validation with NEW parameters......................SQF has got this backwards completely
iii. Changes to the processes or procedures are assessed to ensure controls are still effective; and
iv. All applicable elements of the SQF Program are implemented and effective.
184.108.40.206 Records of all validation activities shall be maintained. You would only have VALIDATION activities that were NEW if a new process etc. had been implemented. The only documentation you should have otherwise is the ORIGINAL validation(s) that were performed.
2.5.2 Verification Activities (Mandatory) This would be ALL of the records used to VERIFY things.........so CCP records etc.
220.127.116.11 A verification schedule outlining the verification activities, their frequency of completion and the person
responsible for each activity shall be prepared and implemented.This schedule would be super high level broken down by frequency then I would just use the sub element and add no further detail
18.104.22.168 The methods, responsibility and criteria for verifying monitoring of Good Manufacturing Practices, critical
control points and other food safety controls, and the legality of certified products, shall be documented and
implemented. The methods applied shall ensure that personnel with responsibility for verifying monitoring
activities authorize each verified record.
22.214.171.124 Records of the verification of monitoring activities shall be maintained.
Below are well explained (correct IMHO) definitions of verification vs validation
Webster defines verification as “To establish the truth, accuracy, or reality of.” The National Academy Committee on Microbiological Criteria further defines verification for HACCP for Foods (NACMCF, 1997) as “Those activities other than monitoring that determine the validity of and compliance with the HACCP plan.” Several tasks should be identified as verification activities for the HACCP system. These include verification of prerequisite programs, verification of the critical control points, and verification of the overall HACCP plan. In addition, the regulations in 9 CFR 417 identifies verification activities that which will be performed by the USDA inspectors. Companies may also consider involving outside experts in an audit or may send personnel to suppliers of food ingredients to verify HACCP and food safety plans.
Validation is also part of Principle 6, Establish Verification Procedures. Validation is defined as “to support or corroborate on a sound or authoritative basis” or to “establish validity of the HACCP plan by supplying factual proof.” Within HACCP, validation is “the element of verification focused on collecting and evaluating scientific and technical information to determine if the HACCP plan, when properly implemented, will effectively control the hazards” (NACFMF, 1997). Validation can be accomplished by conducting in-plant studies, providing literature citations, and conducting pathogen inoculation studies in controlled laboratory settings.