Is Direct Observation required in SQF if not required by regulatory?

I know as part of HACCP through for high risk processes, direct observation is required to verify CCPs and PRPs. In a low risk facility that is not governed by these rules (USDA/FSIS/FDA) are direct observations as part of your verification required for SQF? The phrase "direct observation" isn't even used in the entire SQF Code 7.2. I want to make sure I'm reading on this correctly. Anyone else have any experience with auditors for SQF on this?

We're a paper converting facility making paper products for restaurant industry. Low risk, SQF Certified Level 2.

It can be and is used as part of the validation and verification process and there is a lot of that in SQF :ejut:

It can be and is used as part of the validation and verification process and there is a lot of that in SQF :ejut:

It can be if I say I'm doing direct observation but if I don't say I'm doing direct observation for verification purposes I can verify by record review or perform direct observation less frequently along with record review correct? If I use direct observation for validation purposes could I successfully complete it twice a year and be ok?

I think it would depend on your process.  I just took an advanced HACCP class and my head is still sorting out terminology. 

Here's how we define our observations:

Monitoring - someone is actually observing and recording.

Verification - someone else (usually supervisor or manager) is check that the monitoring is being done correctly.

Validation - upper management is looking at trend charts to make sure the control is working.