Establishing accurate documentation and efficient record keeping is essential to the successful application of HACCP. Documentation demonstrates that the principles of HACCP have been correctly applied. Records provide the written evidence that all HACCP activities were carried out as specified. Record keeping, admittedly, can be a boring, tedious task; yet, in the words of a USDA inspector, if it was not written down, as far as he was concerned, it was not done! Experience has demonstrated that inadequate or inefficient record keeping is a major reason for HACCP audit failures.
All HACCP records should be kept in a separate master file so that only product/process safety is reviewed during a HACCP audit. Software systems are available to assist in the documentation of HACCP plans and keeping of records. The FDA requires that HACCP records be kept on file for at least one year from the date of production for refrigerated foods (e.g., fresh-cut produce). Although record keeping may appear to be a burden, there are sound reasons for this activity which will benefit the processor, including the following :
1. Documents that all CCPs are within CLs to ensure product safety.
2. Provides the only reference available for produce traceability once the product leaves the plant.
3. Documents corrective actions taken when CLs were exceeded.
4. Provides a monitoring tool so process adjustments can be made to prevent loss of control.
5. Provides data for review during regulatory, customer, and third-party auditing.
6. Provides demonstrable evidence that procedures and processes were followed in strict accordance with the written HACCP plan.
Record keeping includes records that go beyond those that are tabulated on a day-to-day basis. NACMCF endorses the maintenance of four types of records :
1. Summary of the hazard analysis — includes records on the HACCP team's deliberations on the rationale for determining hazards and control measures.
2. The HACCP plan for each product, including records of the product description, distribution and end use, verified flow diagram, and all HACCP plan summaries addressing the seven required components.
3. Support documentation — CCP records, CL records monitoring and corrective action records, verification and validation records.
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