SQF’s own non-conformance definitions make records the pressure point of a training program: training that ran but can’t be evidenced falls squarely under the major definition’s “absence of evidence.” The code is unusually concrete here: Edition 9 clause 2.9.2.3lists exactly six elements a training record must contain. If your records template captures all six, every completion you file is audit-evidence; if it captures five, every completion you file is a finding you haven’t received yet.
- Clause 2.9.2.3 requires six elements per record — name, skills description, training description, date, trainer, and competency verification.
- Competency verification is the element SQFI's own guidance singles out as most critical — quizzes or direct observation both count.
- SQF's records element (2.2.3) sets retention: at minimum the product's shelf life, or a site-defined period.
- 'Absence of evidence demonstrating compliance' is written into SQF's major non-conformance definition.
- Systemic falsification of records is a critical non-conformance — at initial certification, an automatic failure.
The six required elements
| Capability | Element (2.9.2.3) | What the auditor checks |
|---|---|---|
| i. Participant name | The record ties to a real, identifiable person on your roster | |
| ii. Skills description | What the person needed to be able to do — not just a course title | |
| iii. Description of the training provided | What was actually delivered against that skill | |
| iv. Date training completed | Current, and consistent with your refresher cadence | |
| v. Trainer or training provider | Who delivered it — internal trainer or external provider | |
| vi. Verification the trainee is competent | Evidence the person can do the task: quiz, observation, sign-off |
Element vi is the one that separates attendance from competency. SQFI’s own training guidance calls verification of competency the most critical part of the record and accepts practical evidence — a short quiz or direct observation of the task — as the verification. A signed sign-in sheet satisfies elements i and iv; it says nothing about vi.
The skills register and the training matrix
SQFI’s tip-sheet guidance describes keeping a training skills register — a per-event file of training records identifying the training applied, the skill gained, and the assessment used — and explicitly acknowledges a training matrix as a register format suited to large or rotational teams. That is the same structure as our free training matrix generator: people down one side, required training across the top, each cell holding the dated evidence. If you keep one, keep it current — a matrix that contradicts your records is worse at an audit than no matrix at all.
Retention: how long records must live
Training records fall under SQF’s mandatory records element. Clause 2.2.3.3 requires records to be securely stored and retained to meet customer, legal, and regulatory requirements — at minimum the product’s shelf life, or a site-established period where no shelf life applies. The records clauses also require that record-keeping methods, frequency, and responsibility are documented (2.2.3.1) and that records are legible and confirmed by the people doing the monitoring (2.2.3.2). A common conservative choice is to retain training records for the length of employment plus a defined period, since the same records serve HR and regulatory needs — but the code’s stated minimum is the shelf-life rule.
How records fail at audit
SQF grades findings as minor, major, or critical, and the definitions matter for records specifically: the major non-conformance definition explicitly includes the absence of evidence demonstrating compliance. Training that ran but can’t be evidenced tends to grade major, not minor. At the other end, systemic falsification of records is a critical non-conformance — and a critical at an initial certification audit is an automatic failure requiring re-application. Backdating a completion to survive an audit is the single most expensive shortcut in this system.
If you run this on software, the six elements become a form instead of a discipline: a tool like TrainGrid stores every completion with the person, the course and its skills description, the date, the trainer, and an attached competency sign-off or assessment — in an append-only log — so “show me this operator’s training history” is a thirty-second answer rather than a filing-cabinet afternoon.