This is one of those "clear as mud" requirements for me. Every SQF auditor I've come across expects annual refresher training, even though code posted above states it's up to the company to "include provisions for identifying and implementing the refresher training needs of the organization." So as long as you've defined when refresher training should occur in your organization's documents, and programs are running as intended, it should be acceptable.
For extra research, SQF Tip Sheet 13 states on page 3:
3. Plan and conduct refresher training
a. The site must provide refresher training as appropriate. This may be on an annual basis, start of a new season, or as changes occur to the product, process or SQF System, or if the site through their monitoring identifies if the process has gotten off track.
b. Consider using on-going coaching in addition to single-event training to ensure employees are on track at all times.
Tip-Sheet-13-Employee-Training-Program.pdf (sqfi.com)
Official Guidance Documents state:
When programs are updated, the impact to personnel and training or re-training needs identified.
Training, refresher training, and coaching is critical to ensure the success of the food safety and/or quality System(s). Consider relying on ongoing training rather than event-related training to keep skills at their peak.
Training-Guidance-Document.pdf (sqfi.com)
So again, I can't find specific requirements for annual refreshers, but auditors seem to expect it to be annual. I set up my docs to state that refresher training should happen each calendar year, which has gotten me out of a couple findings where an employee's last training was over 365 days (but the auditor that time wasn't thrilled and gave me one of those "Well, what I'm used to seeing..." type statements).