HACCP: Record-Keeping

• Record-keeping is the seventh and final principle of HACCP, and is critical for documenting that products were produced safely and pose no public health hazard.
• Accurate records are essential for processors in case of a recall or outbreak.
• Records serve as documentation for audits requested by consumers or customers.
• Record-keeping is important for employee training, showing how to collect records properly and identifying potential issues in the process.
• Records provide evidence for problem-solving by revealing trends in data that can help prevent food safety hazards.

Types of Records

• The entire HACCP plan, covering all seven principles.
• Daily records related to monitoring, verification, and corrective actions.
• Supportive documentation such as scientific studies or expert opinions that justify decisions made to ensure product safety.
• HACCP plan components include product descriptions, flow diagrams, hazard identification, CCP establishment, critical limits, monitoring systems, corrective actions, record-keeping procedures, and verification procedures.
• Daily records include critical control point records, calibration records, receiving logs for ingredients and packaging, employee training records, and HACCP verification records.
• Supporting documentation includes Good Manufacturing Practices (GMPs), sanitation records or Sanitation Standard Operating Procedures (SSOPs), and any data from the plant or scientific literature.
• Ingredients, manufacturing specifications, and Material Safety Data Sheets (MSDS) may also be included.

Record Review

• Records should be reviewed daily for completeness and to identify any deviations or irregularities in data collection.
• Records can be used to determine what to do with product, including whether the product needs to be disposed of due to unsafe production conditions.
• A designated person should sign and date documents to confirm responsibility for the HACCP plan.
• Records must be organized and readily accessible to both planning employees and regulatory officials.
• Consistent, unchanging data may indicate inaccurate record-keeping.
• Actual measurements should show some variation.

Regulatory Requirements

• USDA requires records to be retained for one year in slaughter plants and for refrigerated products.
• Records for frozen, preserved, or shelf-stable products must be kept for two years.
• USDA Food Safety and Inspection Service (FSIS) inspectors have the right to review HACCP plans for meat and poultry products.
• Records stored off-site are permitted after six months, but must be retrievable within 24 hours for review and photocopying.

Proper Recordkeeping Procedures

• Create clean, organized records.
• Do not pre-record data or ditto information.
• Make entries immediately rather than relying on memory.
• Never use white-out or erase numbers when modifying data.
• Always record in pen, not pencil.
• When correcting a value, put one line through it, initial, record the correct measurement, and explain the change.
• Use standardized forms for daily data collection.

HACCP Plan as a Dynamic Document

• The HACCP plan should be kept current and simple and organized into a HACCP manual for easy access.
• Daily forms are recorded and reviewed to ensure completeness, Critical Limits (CLs) are met, corrective actions were taken, and verification was conducted before shipping the product.
• Records are then compiled into a daily record notebook, with weekly or monthly analysis for trends and compliance to modify the HACCP plan, if necessary.
• After six months, records are moved to a less accessible file either on-site or off-site, but within the first six months, records should remain accessible within the facility.
• Electronic storage of records is acceptable, but backups are mandatory to prevent data loss.
• Records include the HACCP plan, daily records, calibration records, pre-shipment review (if applicable), verification activities, and supporting documentation.