Tip of the Week: Records Requirements

Once you have performed hazard analysis to identify the application of preventive controls and any applicable supply chain and environmental monitoring, it is time to document what preventive controls were chosen and maintain implementation records. Your records can be hard copies or electronic, and some different stipulations apply depending on which you choose. 

Your food safety plan documentation includes hazard analysis; preventive controls for process, allergens, and sanitation or other controls; supply chain program procedures; recall plan; monitoring procedures' corrective action procedures; and verification procedures. 

Your implementation records consist of preventive control monitoring data, corrective actions taken, verification records, validation documentation, supply chain program implementation verification records, and training records for preventive control qualified and other qualified individuals. 

Records can be hard copies or electronic versions such as scans or other electronic files. Records must be the original or reproductions if electronic versions are used. Record content must consist of actual values or observation, must be accurate, must be recorded when the activity is performed and be of adequate detail to demonstrate compliance or non-compliance. If electronic records are being kept, this is acceptable as long as they have electronic signatures equivalent to typical hard copy records. Electronic records should be protected from unauthorized changes, be reviewed on an adequate frequency to demonstrate that controls are compliant, and must be available for review if requested by the regulators. It is likely that you will validate your electronic recordkeeping system to ensure that the electronic records are accurate, retrievable, and can provide an auditable trail.

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