I. When is a CAPA required?
o Whenever there is an identified non-conformance triggered by a deviation from the requirements of any relevant module(s) of the SQF Food Safety Code a CAPA must be initiated. Identify the supporting element, description and the extend of the non-conformance.
o You need to take appropriate corrective action for every non-conformance identified by the SQF food safety auditor (corrective action is the action you take to eliminate the cause of a detected non-conformance to prevent its recurrence).
o Below I have added what as a minimum is required to start a CAPA’s per SQF Code.
2.1.3 Complaint Management (Mandatory)
184.108.40.206 Corrective and preventative action shall be implemented based on the seriousness of the incident and the root cause analysis as outlined in 2.5.3. Records of customer complaints, their investigation, and resolution shall be maintained.
2.4.5 Non-conforming Materials and Product
220.127.116.11 Quarantine records and records of the handling, corrective action, or disposal of non-conforming materials or product shall be maintained.
2.4.8 Environmental Monitoring
18.104.22.168 Environmental testing results shall be monitored, tracked, and trended, and preventative actions (refer to 22.214.171.124) shall be implemented where unsatisfactory results or trends are observed.
2.5.4 Internal Audits and Inspections (Mandatory)
126.96.36.199 Records of internal audits and inspections and any corrective and preventative actions taken as a result of internal audits shall be recorded as per 2.5.3.
Changes implemented from internal audits that have an impact on the site's ability to deliver safe food shall require a review of applicable aspects of the SQF System (refer to 188.8.131.52).
184.108.40.206 A food safety plan shall be validated and verified by the site food safety team for each new product and its associated process through conversion to commercial production and distribution or where a change to ingredients, process, or packaging occurs that may impact food safety.
2.6.3 Product Withdrawal and Recall (Mandatory)
220.127.116.11 Records shall be maintained of withdrawal and recall tests, root cause investigations into actual withdrawals and recalls, and corrective and preventative actions applied.
11.1.7 Equipment and Utensils
18.104.22.168 Non-conforming equipment shall be identified, tagged, and/or segregated for repair or disposal in a manner that minimizes the risk of inadvertent use, improper use, or risk to the integrity of finished product. Records of the handling, corrective action, and/or disposal of non-conforming equipment shall be maintained.
11.6.2 Cold Storage, Freezing, and Chilling of Foods
22.214.171.124 The site shall have a written procedure for monitoring temperatures, including the frequency of checks, and corrective actions, if the temperature is out of specification.
Freezing, chilling, and cold storage rooms shall be fitted with temperature monitoring equipment that is located to monitor the warmest part of the room and be fitted with a temperature measurement device that is easily readable and accessible. Records shall be kept of frozen, cold, and chilled storage room temperatures.
11.7.4 Detection of Foreign Objects
126.96.36.199 Records shall be maintained of the inspection of foreign object detection devices, of any products rejected or removed by them, and of corrective and preventative actions resulting from the inspections.
II. CAPA Record, Verification and Follow-up Requirements
o Evidence of all corrective actions is required (supporting documentation).
o A close out time frame must be established for all CAPAs.
o I recommend that all CAPAs classified as a “Minor and / or “Major” must be verified and closed out at least within thirty (30) calendar days after the date of initiation.
Hope it helps