You Can Outsource the Work. You Cannot Outsource the Accountability.

SQF Edition 10 published in March 2026, and buried in it is a requirement that says something larger than it appears.

Both the primary and the backup SQF Practitioner must be site employees. A consultant can build your system, write your plans, train your team, and sit beside you through the audit. A consultant cannot be the person on the hook.

Read that as a signal rather than a rule, because it reflects where the entire compliance field is heading: regulators and certification bodies have stopped accepting outsourced ownership.

For a growing food business, this creates a real bind. You need senior compliance judgment — the kind that knows which battles with a co-packer are worth having, when a label claim invites a lawsuit, what a buyer's quality team will actually flag. That expertise costs $150,000 or more a year in salary. At $3 million in revenue, you cannot justify it. You also cannot afford to be without it, because the mistakes it prevents cost more than the role does.

Most companies resolve this badly. They hand compliance to whoever has capacity — an operations manager, a founder, sometimes an office manager with a binder — and hope the gaps stay small. They stay small right up until a retailer audit, a consumer complaint, or a recall makes them enormous.

The fractional model exists for exactly this gap. Senior compliance leadership on retainer: someone who holds the whole regulatory picture, sits in on the decisions that create risk, and builds internal capacity rather than dependency. Your team keeps the accountability. You rent the judgment.

How to tell you have outgrown ad-hoc compliance support:

• You are hiring project consultants more than twice a year, and each one has to relearn your business

• Regulatory questions are reaching you as emergencies rather than as planned decisions

• A retailer has asked for documentation you did not know existed

• Someone on your team is doing compliance work that is not in their job description and not in their training

That last one is the most common and the most expensive. Talented people quietly absorbing work they were never equipped for is how compliance failures happen in growing companies — not through negligence, but through drift.

The goal of good consulting is not to become permanent. It is to build a system your team can run, and to be there for the decisions that need a second set of trained eyes.

Our Fractional Chief Compliance Officer retainer gives growing food businesses senior regulatory leadership without the senior salary. See if it fits.