Good record keeping is paramount for any business. Record keeping is not only required by different laws but forms the basis for objective evidence of your food safety HACCP system. For any food business that has been through a HACCP audit or third party HACCP certification audit, having clear, legible food safety HACCP records can contribute to a stress-free audit process.
All HACCP certification standards, for example, BRCGS, SQF, Codex HACCP, Global Gap and FSSC 22000 require a food business to keep records. Documented food safety HACCP records provide the support and evidence that something actually took place. In the world of auditing, it is often said that “if it is not recorded or written down – it did not happen”.
Record keeping must be legible
It is all well and good to have information written down, but if you cannot read it or it is not legible it may cause some issues during the food certification audit process. A food business should consider the language used, the medium to which the information is recorded, for example, paper, video or electronically and also the ability for the information not to diminish or fade over time.
Retention Time for food safety HACCP Records
The time frame that records should be kept is based on a number of factors. Legal requirements may stipulate the retention time for food business record keeping. If you are required to comply with FSMA’s Human Food PC Rule, you are required to retain your records for a minimum of 2 years.
As a general rule of thumb, I recommend keeping your records for a minimum of the product shelf-life + 1 year. However, you must always comply with the most stringent record retention periods that exist in your governing laws before applying this recommendation.
The food business may also state in its company policies how long records are to be kept. It is a good idea to understand what the purpose of the record-keeping including what the record is about before retention times are set.
Control of HACCP Records
The best way to control food safety and HACCP records is to firstly have document control applied to the form that gets completed. Remember, a record really is just a form that has been filled out. You can then state in your document control procedure that the way you control records is by:
- Only using controlled forms
- Storing records securely
- Retaining the record (as per your record retention policy)
Make sure the form is listed in your document register (list of forms). You can also say that the date that the form was completed is used as the record control mechanism.
Disposal of HACCP Records
Like any type of food business documentation, the records produced may be highly confidential. Care should be taken when disposing of any food safety and HACCP records to ensure that this information does not end up in the wrong hands. Document security and disposal procedures should be documented and enforced within your food business.
Retrieval of food safety HACCP Records
During the audit process, the food business needs to provide records for the food auditor to review. To lessen the stress of an audit, it is recommended that all relevant records are easily retrievable. If your food business stores paper records off-site, access should be available during the audit. This may mean having to bring all the required food safety and HACCP records back to the site for audit. Electronic food safety HACCP records are also required to be retrievable. Please be mindful of computer programs or formats to which the records are stored and make sure they are accessible.
Factual record keeping
The recording of food safety information within HACCP records is required to be factual and undertaken at the time of any testing. A good food auditor will always be able to tell if your food business and HACCP records have been falsified. There are also very strong penalties that can be applied for business record falsification.
By following these easy record-keeping steps when recording information and managing the resulting records, a food business can position itself to reduce stress during the HACCP certification process and also meet it’s relevant record keeping legal requirements.