Recordkeeping

Photo of Michele Pfannenstiel, aka Dr. HAACP

Michele Pfannenstiel, aka Dr. HAACP

Know this: When it comes to food safety, if you didn’t write it down, it didn’t happen. And frankly, if you don’t write it down the way the USDA/FDA wants you to write it, you will get written up for lousy record-keeping. All good food safety plans, HACCP or no, require records. Keep records and do it correctly.

Why? Because good records are essential to good operations. Even if you are a one woman shop, you need good records to work with. It baffles me that “Establish Record Keeping” is the 7th step in the 7 step HACCP process. I’ve changed up my training to start off with teaching good record keeping and records maintenance because from the minute a producer/processor decides to write a HACCP, they need to start keeping records.

First, let’s get the regulations understood:
USDA records requirements are outlined in 9CFR 417.5 and must have

  • Date and time of each activity
  • Each entry is initialed
  • Information is entered at the time observed
  • Actual observations and values are recorded
  • Reviewers signature and date of review

FDA records requirements are outlined in 21CFR 123 (juice) and 21CFR 120 (seafood)

  • Name and location of processor or importer
  • Date and time of activity
  • Initials/signature of person doing recording
  • Production ID code when appropriate
  • Processing info entered at the time observed
  • Actual observations and values obtained
  • Reviewers signature and date of review

But, the fun doesn’t stop there. Good records should also follow these other guidelines:

Do not recopy. Recopying records is an indication that a processor wants to expunge them of something. Real records from production are messy, and that shows that the plant takes record keeping seriously. Include Company/plant name and location. An inspector needs to know where the record was generated. And even if you have a small operation, you’d be surprised how quickly geography of what record was generated where can become confusing. Put the title of the record on the record.

Be really specific. Time/Temperature log of what product? What cooler? Include the critical limit that you are monitoring. This applies to monitoring records. The person who is writing the records needs the critical limit in front of them, because they have to meet the critical limit every time. Document Corrective Actions taken and by whom, if necessary. CAR (corrective action records) are their own records, and need to comply with the USDA/FDA records requirements.

Review them. Have an SOP that details how you review your records. Retain them as your regulatory agency requires (1 year for slaughter and chilled products; 2 years for frozen, preserved, or shelf stable; 3 years for canned). Consider a records access SOP. Production records are FOIA-able (Freedom of Information Act), and once they are in the hands of your inspector, they can become public record. Be smart, and do your best to ensure that never happens.

About Michele Pfannenstiel

Dr. Michele Pfannenstiel is the founder and CEO of Dirigo Food Safety. Dr. P earned her BA in Economics and Geology from Wellesley College, after which she served in the Peace Corps in Irbid, Jordan. In her second year of study at the University Of Georgia College Of Veterinary Medicine, the future Dr. P was chosen for the prestigious Health Professions Scholarship Program through the US Army. Upon receiving her DVM, Dr. P commissioned into the US Army Veterinary Corps, where she learned the food safety skills she now brings to the local food and meats industry across the country. After fulfilling her active duty commitment, Dr. P settled with her family in Southern Maine, where they raise chickens and the occasional ruminant, experiment in the kitchen, and explore the woods around their home. Dr. P is a certified HACCP auditor through ASQ. She serves as the President of the Maine chapter of the Farmer Veteran Coalition, and as the Director of Food Safety for the national Farmer Veteran Coalition. A sought after speaker, Dr. P has taught food safety workshops at the Stone Barns Center, Pigstock, the Wallace Center Food Hub Conference, the New England Meat Conference, and the Empowering Women Veterans in Business and Agriculture Conference.
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