SQF Edition 10: Unfixed Minor Non-Conformances Could Become Majors

Under SQF Code Edition 10, if a non-conformance from the previous audit is repeated, the auditor may, at their discretion, assign an additional non-conformance under clause 2.5.3, Corrections, and Corrective and Preventative Actions.

You may ask: why are they doing that? Because if a previously flagged minor issue hasn’t been properly corrected and verified, it probably indicates a deeper problem—one that could impact your certification status.

In this post, we’ll explore how this update affects your Corrective and Preventive Action (CAPA) Program and how you can stay on top by tightening your response and resolution processes.

What This Means for Your CAPA Program

The repeat non-conformance is assessed based on what the auditor finds. The auditor may also, at their discretion, raise an additional non-conformance against your Corrective and Preventive Action (CAPA) Program.

This is not a new requirement; effectively addressing all non-conformities has always been expected. Under Edition 10, clause 2.5.3 is both Mandatory and a Core Clause. When there is a repeat non-conformance from the previous audit, the auditor may, at their discretion, assign an additional non-conformance under this clause. This can have a greater impact on the final audit score.

Why This Matters

• The minor finding itself isn’t the real concern. A minor means the food safety system hasn’t broken down, but something isn’t being implemented as it should be. If it isn’t properly addressed, it could develop into a bigger problem.

• The real issue is that the way non-conformities are being addressed is inadequate, so there is no guarantee that the problems are being effectively resolved.

This change reinforces a clear message: no issue is too small to fix. Each audit finding must be fully resolved and documented in a timely manner. With SQF Edition 10 audits on the horizon, now is the time to ensure your CAPA program is working as it should, and issues are being effectively addressed.

Real-World Tips to Stay Ahead

• Set Internal Deadlines, Not Audit Deadlines: Don’t wait until just before your next SQF audit. Establish your own internal deadlines well before the applicable SQF closeout deadline to allow time for verification and follow-up.

• Check Your Corrective Action Log: Ask:

  • Are corrective actions being verified for effectiveness?

  • Are we fixing every instance of the issues we find?

  • Are problems recurring?

  • Are we truly finding and fixing root causes?

• Use “Minors” as Training Opportunities: Small issues can teach big lessons. Turn minor non-conformances into real-time training to reinforce how attention to detail strengthens your food safety system.

• Involve Department Leads: CAPA should be a shared responsibility. Bring in maintenance, sanitation, and production leads—not just QA. Cross-functional involvement boosts accountability and better root cause analysis.

• Document Everything: Auditors want to see not just the action, but evidence that it was effective. Keep clear, dated records of what was done and when. (back to the Corrective Action Log!). Furthermore, this will allow you to identify what might have gone wrong if you are experiencing a recurring problem.

The Bottom Line

Stay proactive. By consistently tying non-conformances back to your CAPA program and closing the loop, even on minor issues, you reduce risk, prevent serious problems, and keep your SQF certification secure. It’s also a good way to practice and strengthen your CAPA process, building everyday habits that make your system more resilient and audit-ready.

The purpose of this update is evident: to ensure food safety improvements are real, lasting, and verifiable. It’s about establishing a corrective action process that enables you and your team to manage risk effectively, every day, not just on audit day.

Resources

Our QIMA team hosted a roundtable discussion featuring guest panelists from SQFI and Navigate Food Safety Solutions, where we explored how upcoming changes could impact facilities. Watch the full recording here.

QIMA offers SQF certification and audits for brands across the food industry.

Contact us to learn more about SQF certification or book an audit today.