Don’t panic!. So, it appears that you are compliant with the SQF Code requirements and the guidance supports this:
The SQF Code, Edition 8 SQF System Elements for Food Manufacturing
2.2.2 Document Control (Mandatory)
188.8.131.52 The methods and responsibility for maintaining document control and ensuring staff have access to documents shall be documented and implemented.
184.108.40.206 A register of current SQF System documents and amendments to documents shall be maintained.
220.127.116.11 Documents shall be safely stored and readily accessible.
2.2.2 Implementation Guidance
What does it mean?
Documents can be stored electronically or be paper-based, or a blend of both. However the current copy of the relevant documents must be available to staff and employees that need to use them. A list of documents and amendments to documents must be maintained to identify the current documents in use.
What do I have to do?
This element is mandatory. To comply with this requirement, the supplier must designate a staff member who is responsible for document storage and security and how documents are controlled; distributing current versions to relevant employees; and ensuring that documents are up-to-date. Worn, illegible or out-of-date documents must be replaced. A written procedure describing how documents will be maintained, updated and replaced must be developed and in place.
A register of all documents must be maintained including when they were issued, updated and who has a copy of each document. Documents referred to include, for example, pre-requisite programs, food safety plans, SSOPs, SOPs, other work instructions and raw material and finished product specifications, etc.
2.2.2 Auditing Guidance
The auditor needs to seek evidence of the existence of a document control procedure at the desk audit and compliance to this requirement by observation, interview with the responsible person and interviews with staff to ensure they have current documents available. Evidence may include:
- Review of the document control procedure;
- Review of the document register and list of amendments, and their accuracy;
- Availability and currency of documents in use;
- Security and storage of documents;
- All personnel who need access to specific documents such as food safety plans, procedures, customer specifications and applicable food regulations have such access.
Point all this out to the auditor, if they still persist you can take this up with the certification body (they will remove the non-conformance if you have evidence that contradicts the auditor findings).
Finally don’t get into a heated exchange with the auditor, merely present the facts.