At every station: rules and costs
The Role of Bread Trays in Bakery Audits and Inspections
Contents: 5 sections
This page is an audit-readiness self-check for a tray program, not a map of SQF or BRCGS clauses: this guide has not verified those codes clause by clause, so it does not claim to know what their auditors are instructed to check. What it can map is FDA’s manufacturing rule, which is public, against the evidence a tray program produces. Use the evidence map and the walk below before any audit, and get the clause numbers for a private scheme from your certification body.
What evidence does a tray program produce for FDA’s rule?
For a facility that must register with FDA, the manufacturing rule in 21 CFR Part 117 is the regulatory text a tray program answers to, though not every part of it applies to every facility. Each row pairs a requirement with what it looks like on the floor and in the files, for direct-contact trays:
| Requirement (21 CFR Part 117) | On the floor | In the records |
|---|---|---|
| 117.35(d): food-contact surfaces cleaned as frequently as necessary | Trays in clean storage with no residue, film or odor | The written wash frequency and its reasons; wash records |
| 117.35: cleaned portable equipment stored to protect food-contact surfaces | Clean trays apart from returned trays, off the floor, covered where needed | A storage layout that marks clean, dirty and quarantine areas |
| 117.40: equipment adequately cleanable and maintained | No cracked or gouged food-contact trays in use; a marked quarantine spot | Inspection and retirement log by tray model |
| 117.135: allergen controls, including protection from cross-contact during storage, handling and use | Allergen trays marked and stored apart | Tray allocation list; cleaning validation and changeover verification records |
| 117.150: corrective actions written into records | The fix visible where the problem was | Corrective action records with cause and check |
| 117.315: records kept at least 2 years | Not a floor check | Tray records filed on the food safety plan's schedule |
Sources for the table: 21 CFR 117.35, 117.40, 117.135, 117.150, 117.315; each is quoted on the page that applies it. The “on the floor” and “in the records” columns are this guide’s suggested evidence, not text from the rule. The rows do not all apply at the same level. 117.35 and 117.40 are current good manufacturing practice in Subpart B. 117.135 and 117.150 belong to Subpart C, the preventive controls, which apply only where the facility and the activity are subject to it: the exemptions in 21 CFR 117.5 begin, “Except as provided by subpart E of this part, subparts C and G of this part do not apply to a qualified facility” (21 CFR 117.5). Check that section before using those two rows. Where Subpart C does apply, whether 117.135’s allergen controls reach your trays depends on your hazard analysis.
Where each requirement is worked out: the crack and retirement rules for trays, the cleaning sequence and wash records, allergen tray marking and dedication, and the tray records a food safety plan relies on.
How do you walk your tray program before an audit?
Follow a tray through the building, in the order it travels, at a time nobody has prepared for. This walk is this guide’s suggested practice; have someone outside tray handling do it, because people who run the program every day stop seeing its gaps.
- Return dock. Are returned trays kept apart from clean ones? Is there a marked quarantine spot, and does anything in it have a recorded decision?
- Wash. Pull today’s wash record and compare it with what the operator says the machine or sink ran at. Check the sanitizer strength yourself.
- Clean storage. Pull a sample of trays and inspect them closely for cracks, warping, residue and wet trays nested in stacks.
- Loading line. Check every tray in use. Ask the person loading what they do with a cracked tray.
- Allergen area. Check marking, storage and whether a tray of the wrong color is on a dedicated line. Ask what each color means.
- Records. Open the retirement log, the corrective action log and the allergen validation file. Every past corrective action should have its completion evidence.
Rules and records that nobody on the floor can explain read as a program that exists on paper only, whoever is doing the reading.
Which scheme and edition will you be audited against?
That depends on your customers and your facility, and the editions change.
Scheme editions (checked September 26, 2026). SQFI published SQF Edition 10 in March 2026. Its guidance on which edition to use says: “The date audits are to start with the Edition 10 SQF Food Safety and Quality Codes is expected to be January 2, 2027.” An audit before that date is to Edition 9, and SQFI ties the date to GFSI benchmarking, so it can move (SQFI, which code edition should I use, SQFI, food safety program). The BRCGS Food Safety standard page says the standard is “Now in its 9th issue”; BRCGS has posted news about Issue 10 (August 11, 2026) without a publication date on the standard page (BRCGS, Food Safety). Issue 9 audits also carry position statements: BRCGS writes that “Since 10 August 2026, the following position statements have come into effect,” and the list includes F926 for Food Safety, which its link identifies as the position statements for Issue 9 (BRCGS, position statements, August 2026). Ask your certification body which position statements your next audit will apply.
Ask your certification body for the edition and the clauses that cover equipment, cleaning, storage, allergens and corrective action, and put those clause numbers into the evidence map above next to the FDA rows. That turns this page into your own map, built from the code you will actually be audited against.
How do you write a corrective action that closes a finding?
With four parts, each written down. FDA’s rule sets what corrective action procedures must achieve, as quoted on the food safety plan page; the four-part form is this guide’s suggested way to write one:
- The correction. What was done about the thing found: the damaged tray removed, the missing log completed, the mixed storage separated.
- The cause. Why it happened: no written retirement criteria, a log template the night shift never received, a storage area with no marked boundary.
- The preventive action. The change that removes the cause: published retirement criteria with photos, the template issued to every shift and confirmed, a marked and signed boundary.
- Owner, date and check. Who does it, by when, and how you will confirm it worked, with the confirmation recorded.
The common trap is a cause written as “staff re-trained.” If the original training did not produce the behavior, training again without asking why will not either; look for what in the system made the wrong action easy. A finding that comes back at the next audit shows the cause was never found.
Keep one log of every tray-related finding from internal, customer, certification and regulatory audits. Three findings about the same kind of record, from different people, point to how the record is designed, not to three careless people.
What would your own walk find today?
Start where the walk is fastest: damaged trays in use and clean trays stored with dirty ones. Those are visible in minutes, point straight at food contact, and are fixed by action, not paperwork. Records come next, then open corrective actions. After each audit, add its tray findings to your log and check for a repeat before you write the next corrective action.