The public contents of the draft name the clause structure. Each page below states the requirement that applies today in our own words, what the draft does to that clause, the evidence an auditor asks for, the common gaps and how to prepare. Requirement text is from the held 2018 edition and its 2024 amendment. Draft status is from the public contents and foreword. Where the draft text is sold by ISO and not held here, the page says so.
The count of 70 is a count of records, not a count of entries on the draft contents page. It includes the numbered 2018 subclauses at 8.5.1 to 8.5.4 that the public contents page prints only at parent level, and the separate records for 8.1 and 8.1.1. The draft contents page itself lists 54 numbered entries. Both numbers are given so a reader can reconcile them.
| Clause | Title | Draft status | Why it matters |
|---|---|---|---|
| 4.1 | Understanding the organization and its context | Unchanged title; climate change is now explicit | This is where the system shows it is looking outward, not only at its own factory. Auditors read the context n... |
| 4.2 | Understanding the needs and expectations of interested parties | Unchanged title | Most audit findings here are not about missing parties but about unnamed requirements. A customer code of prac... |
| 4.3 | Determining the scope of the food safety management system | Unchanged title | The scope decides what the auditor can look at and what the certificate covers. A narrow scope that leaves out... |
| 4.4 | Food safety management system | Unchanged title | This is the clause an auditor uses when the system has drifted: documents that no longer match practice, proce... |
| 5.1 | Leadership and commitment | Unchanged title | Auditors increasingly test this clause by interviewing operators and supervisors, not only the site director. ... |
| 5.2 | Food safety policy | Retitled; possible consolidation, wording not verified | The policy is the one document every auditor reads and every employee is expected to recognise. The test is no... |
| 5.3 | Organizational roles, responsibilities and authorities | Unchanged title | This clause is the difference between a system with a named owner and a system that belongs to everyone in the... |
| 5.4 | Food safety culture | New in the draft; obligation from held FSSC 22000 v7 2.5.8 | This is the largest new ISO management demand, and for an EU food business a culture duty already exists under... |
| 6.1 | Actions to address risks and opportunities | Unchanged title | This clause is about the management system, not the hazard analysis. Teams confuse the two and put HACCP hazar... |
| 6.2 | Food safety management system objectives and planning to achieve them | Retitled; possible consolidation, wording not verified | Objectives are where a policy becomes a plan. The common failure is a set of objectives that are really target... |
| 6.3 | Planning of changes | Unchanged title | This is the clause that governs the revision project itself. A standard change is a change to the system, and ... |
| 7.1.1 | Resources: general | Unchanged title | Resource decisions are where food safety commitments are tested. A site can have a perfect hazard plan and no ... |
| 7.1.2 | Resources: people | Unchanged title | External help is normal in a transition, and this clause is the reason a consultant engagement needs a written... |
| 7.1.3 | Resources: infrastructure | Unchanged title | Infrastructure is where food safety and capital planning meet. A failing chiller, a roof leak over a productio... |
| 7.1.4 | Resources: work environment | Unchanged title | This clause connects the factory floor to the food safety system. A hot, rushed, understaffed line makes short... |
| 7.1.5 | Externally developed elements of the food safety management system | Unchanged title | Buying a HACCP pack or a consultant’s manual is allowed, but dropping it in unchanged is not. The clause requi... |
| 7.1.6 | Control of externally provided processes, products or services | Retitled in the draft | Supply chains are where a site’s food safety is most exposed to things it does not control. The clause asks fo... |
| 7.2 | Competence | Unchanged title | Competence is the most sampled clause in any audit, and the easiest to fake with a training matrix. The real q... |
| 7.3 | Awareness | Unchanged title | Awareness is competence’s quieter sibling: not can they do it, but do they know why it matters and what their ... |
| 7.4.1 | Communication: general | Unchanged title | Communication failures are the root of many recalls: a supplier change nobody told production about, a custome... |
| 7.4.2 | Communication: external | Unchanged title | This is the clause behind the label, the customer letter, the supplier specification and the regulator notific... |
| 7.4.3 | Communication: internal | Unchanged title | The list in this clause is a useful checklist for a transition: every item on it is a place where a change can... |
| 7.5.1 | Documented information: general | Unchanged title | The clause gives permission to be proportionate, which is often ignored in both directions: some sites drown i... |
| 7.5.2 | Documented information: creating and updating | Unchanged title | This is unglamorous and it is where transition projects fail. A new clause map pasted into an old template, wi... |
| 7.5.3 | Documented information: control | Unchanged title | This clause decides whether an auditor can find the current document in under a minute, and whether a recall c... |
| 8.1 | Operational planning and control | Split into 8.1.1, 8.1.2 and 8.1.3 | This is the parent of the operational requirements. It decides how the site turns a hazard plan into a running... |
| 8.1.1 | Operational planning and control: general | Split into 8.1.1, 8.1.2 and 8.1.3 | This is the operational spine: the process criteria, the control points and the records that show the product ... |
| 8.1.2 | Food defence | New in the draft; obligation from held FSSC 22000 v7 2.5.3 | Food defence is deliberate harm: an insider, a visitor, a supplier or an attacker. Most sites have access cont... |
| 8.1.3 | Food fraud prevention | New in the draft; obligation from held FSSC 22000 v7 2.5.4 | Food fraud is substitution, dilution, mislabelling or adulteration for economic gain, and it usually enters th... |
| 8.2 | Prerequisite programmes (PRPs) | Unchanged title | PRPs are the hygiene foundation under the hazard plan, and they are where most day-to-day food safety actually... |
| 8.3 | Traceability system | Unchanged title | Traceability is the clause that decides how a recall goes. The test is not whether a system exists but whether... |
| 8.4.1 | Emergency preparedness and response: general | Unchanged title | The clause is about being ready before something happens: loss of water, power or refrigeration, a fire, a flo... |
| 8.4.2 | Emergency preparedness and response: handling of emergencies and incidents | Unchanged title | This is the clause that governs the first 24 hours. The decisions that matter are who declares the event, who ... |
| 8.5.1 | Preliminary steps to enable hazard analysis | Unchanged title | The quality of the hazard analysis is capped by this preparation. A team that starts from a blank hazard table... |
| 8.5.2 | Hazard analysis | Unchanged title; new Annex B supports the selection step | This is the technical heart of the system. The parent page shows the four steps together; the subclause pages ... |
| 8.5.4 | Hazard control plan (HACCP/OPRP plan) | Unchanged title | The plan is the document the line actually uses. The parent page is the index to the five parts; the subclause... |
| 8.5.1.1 | Preliminary steps: general | Subclause of 8.5.1; not listed separately in the public contents | The quality of the hazard analysis is capped by the quality of this preparation. A team that starts with a bla... |
| 8.5.1.2 | Preliminary steps: characteristics of raw materials, ingredients and product contact materials | Subclause of 8.5.1; not listed separately in the public contents | This is the single richest input to the hazard analysis, and the place where food fraud, allergens and supplie... |
| 8.5.1.3 | Preliminary steps: characteristics of end products | Subclause of 8.5.1; not listed separately in the public contents | The end product description is what connects the factory to the consumer. If the shelf life, the storage condi... |
| 8.5.1.4 | Preliminary steps: intended use | Subclause of 8.5.1; not listed separately in the public contents | Intended use is where the analysis decides who it is protecting. A product intended for cooking is a different... |
| 8.5.1.5 | Preliminary steps: flow diagrams and description of processes | Subclause of 8.5.1; not listed separately in the public contents | A flow diagram that does not match the line is the most common root cause of a weak hazard analysis. The on-si... |
| 8.5.2.1 | Hazard analysis: general | Subclause of 8.5.2; not listed separately in the public contents | The clause sets the purpose of the whole operation: decide what must be controlled and how much control is eno... |
| 8.5.2.2 | Hazard analysis: identification and acceptable levels | Subclause of 8.5.2; not listed separately in the public contents | This is the technical heart of the system. The acceptable level is the anchor: without it, a critical limit ha... |
| 8.5.2.3 | Hazard analysis: hazard assessment | Subclause of 8.5.2; not listed separately in the public contents | The assessment is a judgement, and the clause asks for the judgement to be visible. A risk matrix with no rati... |
| 8.5.2.4 | Hazard analysis: selection and categorization of control measures | Subclause of 8.5.2; not listed separately in the public contents | The OPRP versus CCP decision is the most argued point in food safety audits. The clause does not say "use a tr... |
| 8.5.3 | Validation of control measures and combinations | Unchanged title | Validation answers the question "would this actually work", before the site relies on it. Verification, later,... |
| 8.5.4.1 | Hazard control plan: general | Subclause of 8.5.4; not listed separately in the public contents | The plan is the operational document the line actually uses. If it is 80 pages in a quality office and the lin... |
| 8.5.4.2 | Hazard control plan: critical limits and action criteria | Subclause of 8.5.4; not listed separately in the public contents | The distinction between a measurable critical limit and an observable action criterion is practical, not acade... |
| 8.5.4.3 | Hazard control plan: monitoring systems | Subclause of 8.5.4; not listed separately in the public contents | Monitoring is only useful if it is fast enough to hold product before it ships. A laboratory result that arriv... |
| 8.5.4.4 | Hazard control plan: actions when limits or criteria are not met | Subclause of 8.5.4; not listed separately in the public contents | This is the clause that decides what happens on a bad shift. The plan needs to say who holds the product, who ... |
| 8.5.4.5 | Hazard control plan: implementation | Subclause of 8.5.4; not listed separately in the public contents | The shortest subclause in the operation carries the biggest practical risk: a plan that is not implemented is ... |
| 8.6 | Updating the information specifying the PRPs and the hazard control plan | Unchanged title | This clause closes the loop between a change and the documents that depend on it. A new supplier, a new recipe... |
| 8.7 | Control of monitoring and measuring | Unchanged title | Calibration is the quiet clause that can invalidate months of records. If a thermometer, pH meter or scale was... |
| 8.8.1 | Verification related to PRPs and the hazard control plan | Unchanged title | Verification is the independent check that the controls worked. The independence requirement is the part most ... |
| 8.8.2 | Verification: analysis of results | Unchanged title | Results that are filed but not analysed are cost without benefit. The analysis is where a trend becomes visibl... |
| 8.9.1 | Control of product and process nonconformities: general | Unchanged title | This is about authority at the point of decision. A deviations log that waits for a weekly meeting is not cont... |
| 8.9.2 | Control of product and process nonconformities: corrections | Unchanged title | A correction is the immediate action: hold, segregate, rework, reject. The clause separates that from the corr... |
| 8.9.3 | Control of product and process nonconformities: corrective actions | Unchanged title | The clause is a small root cause programme. The most common weakness is a corrective action that treats the sy... |
| 8.9.4 | Control of product and process nonconformities: potentially unsafe products | Unchanged title | This is the clause that stands between a bad batch and a public incident. It is long because the decisions are... |
| 8.9.5 | Control of product and process nonconformities: withdrawal and recall | Unchanged title | A recall is the moment the whole system is tested in public. The clause asks for a plan, authority, notificati... |
| 9.1.1 | Monitoring, measurement, analysis and evaluation: general | Unchanged title | This clause is about the system's own instruments, not the product controls in clause 8. A site can monitor ev... |
| 9.1.2 | Monitoring, measurement, analysis and evaluation: analysis and evaluation | Unchanged title | This is where data becomes a decision. The clause lists five purposes, and a report that meets none of them is... |
| 9.2 | Internal audit | Headings added to existing subclauses | Internal audit is the system’s own early warning. The parent page is the place to see the purpose and the prog... |
| 9.2.1 | Internal audit: general | Retitled in the draft contents | Internal audit is the system's own early warning. The clause sets the standard: conformance and effectiveness.... |
| 9.2.2 | Internal audit: programme | Retitled in the draft contents | The programme is where audit becomes a system rather than an event. The risk-based frequency is the part teams... |
| 9.3 | Management review | Retitled; possible consolidation, wording not verified | The review is where the system meets the business. A review that walks through a fixed agenda and produces no ... |
| 10.1 | Continual improvement | Renumbered from 10.2 to 10.1 | The draft moves continual improvement from 10.2 to 10.1, which puts it first in the improvement clause. The su... |
| 10.2 | Nonconformity and corrective action | Renumbered from 10.1 to 10.2 | This is the system-level corrective action clause, distinct from the product-level actions in 8.9.3. It applie... |
| 10.3 | Complaints management | New in the draft; obligation from held SQF Code Edition 9 2.1.3 | Complaints are the cheapest early warning a food business has, and most sites bury them in customer service. T... |
| 10.4 | Update of the food safety management system | Renumbered from 10.3 to 10.4 | This is the clause that makes a management system a living thing rather than a certificate. It is also the cla... |