Documentation and records

Step 12 asks for documentation and record keeping. Codex says efficient and accurate record keeping is essential, and that documentation should be appropriate to the nature and size of the operation. Article 5 says the same in law.

Examples of documentation are the HACCP team composition; the hazard analysis and the scientific support for hazards included or excluded; CCP determination; critical limit determination and the scientific support for the limits; validation of control measures; and modifications to the plan. Examples of records are CCP monitoring, deviations and corrective actions, and verification carried out.

A simple system can be effective. It may use existing paperwork, such as delivery invoices and checklists, and records may be electronic. Expert sector guides may form part of the documentation, as long as they reflect the actual operation. Codex also accepts that certain types of business may record monitoring results only when there is a deviation.

The law says records must be kept for an appropriate period, and sets no single figure. Decide your period and write down why. Consider the shelf life of the product, and how long a complaint or an investigation might take to arrive.

Control your documents. Each one should show a version, a date and an owner, and old versions should be withdrawn from the floor. For electronic records, control who has access, keep a history of changes, and back the data up. Where product is released on the basis of its records, those records should be reviewed before release.