Answering this one first --
Do I need a policy to say the code doesn't apply to us? Help!!
The best SQF (and it was paper) system I ever audited as an SQF Auditor was one that was indexed per the code sequence and for one or two items there was simply a sheet of paper - such as one for contract manufacturers - that simply declared that the company did not utilized the services of a contract manufacturer but that if they ever do they will follow such and such code, etc.
I found their documentation system so well laid out and informative to me as the Auditor that we took the same idea and do the same for our clients - thus our past and the next development client gets indexed binders, for modules 2, 11 and 12 and may include pages that simply indicate that certain items are not applicable.
I liked that when I was an Auditor and Auditors that audit the doc systems that we create now like it too - makes for non-events during the process of an audit.
You could of course buy a BIG binder and put it all in there - indexes in code sequence for 2 and whatever your separate modules are.
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