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HACCP Principle No. 7: Compliance requires the right records

foodsafetynews.com by Laura Mushrush, April 9, 2018 

Editor’s note: This is the final installment of a seven-part series on Hazard Analysis and Critical Control Points sponsored by PAR Technologies. There are seven HACCP principles outlined by the Food and Drug Administration to serve as a guideline for creating a systematic approach in the identification, evaluation and control of food safety hazards.

To ensure a food company has operated in compliance with its own HACCP plan, records must be kept as evidence that all procedures were followed, and that all procedures included in the plan were backed with rationale.

Failure to provide documentation that food was produced in a safe manner could result in a recall, according to Donna Schaffner, HACCP consultant microbiologist and the Associate Director of Food Safety, Quality Assurance and Training for Rutgers Food Innovation Center South. 

National Advisory Committee on Microbiological Criteria for Foods says four types of records are needed: 

· Written documentation of the HACCP plan; 

· Summary of the hazard analysis and scientific rationale supporting methods; 

· Validation records; 

· Verification of daily operation records; 

All this leads into food companies keeping compliance with the Food Safety Modernization Act, which allows the FDA to review all food processing related records, which must be presented within a reasonable time (24 hours from the time of the request.) 

Paper-based records, which are still an industry standard, have a lot of potential to be a logistical nightmare because of human error and labor time. However, as technology continues to develop, more food retailers are switching to cloud-based systems, with sensors automatically streaming into the online data base via the Internet of Things, otherwise known as IOT.

Schaffner cautioned, however, that companies utilizing digital records must be prepared to provide the FDA evidence that they are true copies of the original paper versions or that they have a secure paper trail to document any changes made to the original data. 

Pick the right person for the right results
When choosing which employees to maintain records, food companies must identify which ones will be successful with the responsibility, explains Schaffner. 

“It takes a good deal of time and resources to collect and maintain records. People can be very good for their job positions but may not have the skills to document things. For example, a production supervisor may be great at motivating people and keeping the line moving, but not good at filling out records and tracking numbers,” she says.

“It’s essential to recognize what employees are good at, instead of just what their position is.”