Can a Consultant Be SQF Practitioner Under Edition 10?

No. Under SQF Edition 10, both the primary and substitute SQF Practitioner must be facility employees. Consultants can advise, train, and support your team. But they cannot serve as the accountable practitioner.

This is a change that some food facilities will welcome and others will find uncomfortable. If your facility has been relying on an outside consultant to fill the practitioner role, Edition 10 is telling you that arrangement no longer works.

Why This Requirement Makes Sense?

The SQF Practitioner is responsible for overseeing the development, implementation, review, and maintenance of the entire SQF system. That is not a role someone can fill from outside your building.

Think about what a practitioner actually needs to do:

• They need to understand your processes, your people, your equipment, and your day-to-day challenges.
• They need to be present when things go wrong.
• They need to know what changed on second shift last Tuesday.
• They need to recognize when a process is drifting before it becomes a food safety issue.

A part-time consultant who visits your site once a week, or once a month, cannot do that. They do not know what is going on. They are not there when the decisions are being made and they are certainly, not the one who is walking the floor when production is running.

At SFPM Consulting, we have never served as a client’s SQF Practitioner. That has always been our position. We teach our clients to own that role internally because the practitioner needs to be embedded in the operation. Edition 10 now makes that the standard for everyone.

What Was Happening Before?

Under Edition 9, the requirement was less explicit. Some food facilities interpreted this as allowing a consultant to serve as the designated practitioner, especially smaller operations that felt they did not have the internal expertise.

The problem with that arrangement is accountability. When the practitioner is an outsider, there is a gap between who is responsible for the food safety system and who is actually running the facility. The consultant builds the system, maybe updates it periodically, and shows up for the audit. But the daily execution falls to people who may not fully understand the system they are expected to maintain.

I have seen what happens when this setup fails. The consultant leaves, or the contract ends, and the site is left with a food safety system they do not know how to manage. The documentation exists, but nobody on-site truly owns it. That is not a foundation for food safety and create a dependency.

The Backup Practitioner Requirement

Edition 10 does not just require a primary practitioner to be a facility employee. It requires the substitute practitioner to be one as well.

This is SQF Clause 2.1.1.5. Both the primary and backup must be designated with the responsibility and authority to oversee the SQF system. And both must be your own team.

This means you cannot have one internal practitioner and use your consultant as the backup. You need two facility employees trained and capable of managing the system.

For smaller manufacturers, this might feel like a stretch but it is also a protection. If your primary practitioner gets sick, leaves the company, or is unavailable during an audit, you need someone who can step in without scrambling. That person needs to already know the system, the facility, and the team.

How to Transition from Consultant Dependency to Internal Capability?

If your site has been leaning on a consultant as the practitioner, the path forward is a transition, not a panic.

• Start by identifying who on your team has the aptitude and interest to take on this role. 

• They do not need to be a food safety expert on day one.

• They need to be capable of learning the system and willing to own it.

• Then invest in their development. 

• SQF Practitioner training is available and it covers the fundamentals of the SQF system, HACCP principles, and how to implement and maintain the code.

• Get your primary and backup through the training.

• The consultant’s role shifts from doing the work to supporting the people who do the work. 

• That is how we operate with every client. We teach them the system, we train their practitioners, and we build their confidence to manage it independently.

When higher-level food safety issues arise, such as a complex hazard analysis, a regulatory change, or preparation for a challenging audit, that is when consultant support makes the most sense.

The goal is a system where your internal team runs the food safety program daily, and your consultant is a resource you call on strategically, not a crutch you depend on for basic operations.

What Your Internal Practitioner Needs to Succeed?

Designating someone as the SQF Practitioner is not enough. They need real support from management.

• That means giving them the authority to make food safety decisions.
  •  If your practitioner identifies a problem but does not have the power to stop a line or reject a shipment, the title is meaningless.
• Provide time to do the work.
  •  If your practitioner is also your production manager, your quality manager, and your HR coordinator, they will not have the bandwidth to manage the SQF system effectively. The role requires dedicated attention.
• The Access to training, resources, and the information they need to stay current.
  • Food safety regulations change and the SQF Code is evolving.
  • Your practitioner needs to keep learning.
• Most importantly, backing them up.
  • When your practitioner raises a concern that costs money to fix, management needs to support that decision. If the practitioner learns that food safety concerns get overruled by production priorities, they will stop raising them and you will ended up with system breakhown.

Do Not Wait for the SQF 10 Audit Start Date

Building internal practitioner capability takes time. If your current setup relies on a consultant filling this role, start the transition now.

• Get your primary and backup identified.
• Get them trained.
• Have them start working alongside your consultant so the knowledge transfer happens gradually, not in a rush.

The SQF Edition 10 audit start date has not been announced yet. But when it is, you will want your practitioners already confident, already trained, and already running the system. That is not something you can build in a few weeks.

If you are looking for support transitioning your food safety system from consultant-dependent to internally managed, book a complimentary strategy call at https://tidycal.com/sfpmconsulting/strategy-call.  We specialize in teaching food manufacturers to own their SQF system, not outsource it.