Professional Documents
Culture Documents
Food Safety Assurance Systems
Food Safety Assurance Systems
Table 1 Records required for a food safety management system Developing a Document-Control Program
Document/program title
Each and every processor should make a commitment to
1. Organizational Chart developing a document-control program. This program will
2. Quality Manual: Mission & Quality Policies help ensure the following.
3. Stakeholders List
1. Procedures and work instructions are developed using a
4. Communication Guidelines – Internal/External
standard format.
5. Food Safety Committee/HACCP Team
6. Master Cleaning Schedules 2. All documents and forms are subject to a review process
7. Cleaning Procedures before being put into use in the facility.
8. Ingredient Shipping & Receiving Procedures & Records 3. Only current protocols and forms are used.
9. Specification Manual: Ingredients, Packaging & Finished Goods 4. Old or outdated documents are removed from circulation.
10. Letters of Continuing Guarantee (COA) 5. A record of how protocols have evolved is maintained.
11. HACCP Program 6. There is an updated master list of all procedures, work
12. GMPs instructions, and forms used in the facility.
13. Allergen Program 7. Documents and records are protected from damage and are
14. Consumer Complaint Program
secure.
15. Recall & Traceability Program
16. Non-Conforming Products Procedures
The processor should also appoint someone to manage
17. Regulatory Inspection Program
18. Processing SOPs & Record Keeping the document-control program. This could be someone
19. Change Control Procedure from the quality group or it could be someone whose title
20. Process Deviation Procedures & Log is simply Document Control Manager. This person’s job is
21. Internal and External Audit/Inspection to manage the program. He or she need not be a technical
22. Product Testing person, unless part of their job description will be to review
23. Vendor Approval Program procedures, work instructions, and forms for content. If this
24. Glass & Brittle Plastic Program is the case, someone with a technical background should
25. Preventive Maintenance Program: Including Emergency Repairs be assigned to manage the program. If a company does not
26. Pest Control Program
have a document-control program, the Document Control
27. Sampling Procedures
Manager will be responsible for developing the program
28. Environmental Monitoring
29. Metal Detection Program incorporating the elements noted earlier. If the program
30. Foreign Material Detection is already established, their task will be to manage the pro-
31. Shipping and Distribution gram. He or she will also be responsible for developing a team
32. Receiving Programs to review and approve documents. Some companies assign
33. Calibration Procedures responsibility for creating documents to specific persons
34. Retain Samples Program in each operating group, whereas others allow anyone to do
35. Water Quality Program so provided they follow the procedures that have been
36. Warehousing and Storage established.
37. Food Defense: Security Assessment & Plan
Each company has their own format for creating docu-
38. Corrective and Preventive Actions (CAPA)
ments. There are, however, elements that are common to
39. Legal Requirements: File of Laws & Regulations
40. Education and Training most. These include
Other sections that may be included are a scope, key words, Procedures and Work Instructions
and references. Some companies like to refere other procedures,
supporting documents, or regulations in their procedures. Procedures and work instructions provide the road map for
The format is really up to each individual operation. plant operations. They should be written so they clearly in-
All of the procedures, work instructions, and forms should form management and staff how things should be done, when
be entered into a Master List, which is updated as required. things should be done, and how to document the work. These
Headers in the Master List might include the document title, documents also form the basic for training and for internal
the number, creation date, last revision date, document audits. Auditors, both internal and external, must watch dif-
number, department, and who created the document. All ferent operations to determine whether procedures are being
materials can be kept in one Master List, but for many com- followed as written. When an external auditor sees that one
panies, it is often easier to maintain separate lists for each procedure is not being followed, he or she will often dig much
department. deeper. They will assume that there are others that are
Another element that needs to be established is how to in doubt.
ensure security if the procedures and forms are maintained in As noted earlier, procedures often describe the expectations
electronic files. The Document Control Officer will need to of a program, whereas the work instructions define how the
work with the computer group to establish passwords, estab- tasks within the program shall be performed.
lish levels of access, and ensure that the system is backed up Table 2 shows a procedure for a glass and brittle plastic
and protected. program. This procedure includes all the elements expected
Objective: Minimize the potential for crosscontamination of foods and ingredients with glass or brittle plastic to ensure that foods and ingredients are
safe and will not result in injury to end users.
Procedure:
1. It is a company policy that there shall be no glass or ceramics carried into or used in the food processing area or warehouse at any time. Glass
and ceramic shall be confined to the offices and break area. Watches must be removed before entering the plant. Eye glass lenses shall be
manufactured from shatterproof materials.
2. Windows in production or warehouse areas must be shatterproof or coated/covered with plastic to contain breakage.
3. Inventory all glass and brittle plastics in areas where foods and ingredients are stored or handled. This includes the warehouse, production, and
packaging areas. When conducting the inventory, note location of glass or plastic, the type of glass or plastic (if possible) and whether it is
shielded or strengthened in any way. This inventory must also include the area or areas where glass is stored.
4. Transfer all information gathered in step #1 into a Master List.
5. Plant Management shall then examine the Master List for glass and brittle plastic and determine whether any of the situations existing within the
plant pose a realistic threat of contamination and potential injury.
6. The potential risk (high, medium, low) shall be noted in the Master List with the date(s) of review.
7. Situations that pose a realistic threat (high) shall be addressed as soon as possible and corrective actions noted in the Master List. Corrective
actions may include but need not be limited to the use of shields of covers, replacement with stronger or shatterproof plastics, or removal of the
situation from the production or holding area.
8. The company shall establish a regular audit program to examine all glass and brittle plastic noted on the Master List to determine its condition. If
any breakage is noted, it shall be noted on the Master List and repairs made immediately.
9. Employees shall be trained to report any broken glass or brittle plastic such as cracked gage covers or windows.
10. Whenever glass must be transported through the plant, it must be protected and contained in some way. For example, lights must be carried in
their original box when being moved for replacement.
Responsibility: Production supervisor
Corrective actions:
a. Glass and brittle plastic breakage and cleanup
If glass or brittle plastic breaks in the production area or warehouse, operations shall cease immediately.
b. All exposed product shall be segregated and placed on hold.
c. Workers in the area of the breakage shall not move throughout the plant so as not to spread the glass and brittle plastic through the plant.
Shoes shall be inspected before leaving the area and cleaned if needed.
d. Broken glass and brittle plastic shall be cleaned using designated tools and disposed of into designated containers.
e. Glass and plastic breakage shall be recorded in a Glass and Brittle Plastic Breakage Log. This shall note the type of breakage, the location,
whether any product was affected and the disposition of said product.
f. Plant Management shall meet to discuss all incidents, determine the cause and implement a corrective/preventive action plan to minimize the
potential for future incidents.
g. Discovery of damaged or broken glass or brittle plastic
If cracked, damaged, or broken glass or brittle plastic is observed during audits, internal inspections or routine examinations of operations, it must
be noted and evaluated immediately. Repairs shall be prioritized based on potential risk to the business.
h. These incidents shall be recorded in the Glass Breakage Log.
Food Safety Assurance Systems: Documentation and Record Keeping 271
from a glass and brittle plastic program. There are elements in • product information (including product type, package
this procedure that would require additional information. size, processing line, and product code where applicable),
Work instructions for how to develop the glass and brittle • area for actual observations or measurement,
plastic register, how to establish the degree of risk for each • critical limits,
item on the register, and how often internal inspections • area for operator’s signature or initials, and
should be done are not defined. These points need to be • space for reviewer’s signature or initials, and date of
established and documented in a separate work instruction. review.
There should also be procedures detailing how the glass
If a company has forms that they are using do not have a
breakage log should be establish and utilized.
space for reviewer’s signature and date, a stamp may be used
From a food safety perspective, it is especially important
with spaces for the entries.
that the work instructions that are developed for monitoring
critical control points (CCPs) are clearly written and that One thing that should never be done is to print forms
they reference the record-keeping forms. Those responsible for with preprinted information, such as time. The operator must
monitoring should: enter the time, and when the measurement, or reading was
made. It should not be on the form. In the reality of the
• be trained in CCP monitoring techniques, (company must production environment, record keeping is not done every
document training and competence), hour on hour.
• fully understand the importance of CCP monitoring,
• have ready access to the monitoring activity,
• accurately report each monitoring activity, Monitoring and Record Keeping
• immediately report critical limit infractions so that imme-
diate corrective actions can be taken, and Monitoring records are the heart of the HACCP program.
• understand the corrective and/or preventive actions that Monitoring records show the following:
must be taken.
1. that the system is in control,
The procedures for doing the work need to be clearly 2. that the system may be going out of control, and
written. Forms for monitoring should be simple to use, pro- 3. that the system has lost control.
vide a space for entering the information being monitored,
and an area where the operator can sign the form. It is a good As noted earlier, persons monitoring CCPs must be trained
idea to include the critical limits on the monitoring form so on the procedures and fully understand the importance of
that information is easily accessible. monitoring. This applies not only to persons doing moni-
Not all records are done manually. Even if the records are toring CCPs, but also to all responsible for monitoring pre-
continuously recorded on a chart or data are entered into an requisite programs, production operations, and any other
electronic system, there must be procedures for how the work element of the quality, safety, and sanitation program. They
is to be done. are all part of the food safety management system (FSMS).
One of the best tools that food processors can use One set of documents that each processor must maintain
when developing good, easy to use procedures is the digital are calibration records for all instruments or equipment used
camera. Incorporating pictures of instruments, equipment, to monitor CCPs, plus protocols for how these instruments or
or gages can help clarify procedures and minimize the pieces of equipment are to be calibrated. The procedures for
potential for them being misunderstood. Pictures can also be calibration must include how to do the work, who is re-
used to emphasize what are good practices and what is un- sponsible for doing the work, the acceptable tolerances and
acceptable. As an example, most food processors have basic corrective actions to be taken in the event if an instrument or
requirements for hair restraints, garments, eye protection, equipment is found to be out of calibration. The corrective
ear plugs, and other gear. Many facilities are seen that post actions must examine whether any food has been affected by
pictures in their locker rooms or at the entrance to the plant an instrument that is out-of-calibration and describe what
to show workers what is and what is not acceptable. But the should be done with any affected foods.
best use of photographs is with equipment operation. Many There are basic requirements for how records should be
operations utilize startup checklists that provide the operators kept. Many companies mandate that monitors use only blue
with step-by-step actions to follow and information that or black pens to record information and go so far as to define
must be recorded. Using photographs reinforces the protocol what kind of pen is safe to use in the processing area. They will
and is an invaluable tool when it comes to training new also define how corrections should be made.
operators. ‘‘If operators make an error on a form, the error shall be
As noted, forms should be considered controlled documents noted by lining out the incorrect entry, inserting the proper
and should be included in the document-control program. result and initialing and dating the change’’ (Figure 1).
There are a wide variety of forms that are used throughout the The procedures should state that corrections cannot be
industry. There are several elements that should be part of each. made by erasing an entry, the use of liquid paper, or tape. In
These are the eyes of the regulators, these would be falsified records
(Figures 2 and 3).
• form title, Monitors must also be taught that there are some things
• firm name and location, that they should never do. Many persons charged with
• area to enter the time and date, monitoring will use entries such as ditto marks or lines to
272 Food Safety Assurance Systems: Documentation and Record Keeping
indicate that the numbers are the same (Figures 4 and 5). This the corrective action would be captured on the original
is unacceptable. Records have to be recorded at the time they monitoring form.
were measured or observed. Ditto marks or lines drawn down Corrective actions and records of these actions are one
the page do not provide that information. This is why forms of the most common failings in food processing plants. All too
with preprinted data are unacceptable. often, the processor makes a correction but fails to document
that it was done. They fail to close the loop. Failures to con-
duct corrective actions are very common when evaluating
Corrective Action Records records of prerequisite programs. As an example, the pest
control operator observes that a door is broken and does not
If monitoring shows a deviation at a CCP, the product in fit tightly. He notes it on his report and the plant fixes it, but
question is deemed to be unsafe or potentially hazardous. The the plant fails to record that this issue was closed on the report
processor must now take corrective actions to bring the system or elsewhere.
back into control and make a disposition of the product that It is expected that all deficiencies on internal audits, rou-
was affected. Records of all actions to evaluate the deviation tine audits, and third-party audits will be addressed and there
and dispose of the product must be maintained. will be corrective action records of all actions taken to fix the
Corrective actions records must be maintained for all problem. The quality group should verify that the work was
quality and prerequisite monitoring activities. In many cases, completed properly by signing off on the corrective action
a corrective action may be noted on the record-keeping form. report or in the corrective and preventive action (CAPA)
As an example, if a processor was using adenosine tripho- logbook.
sphate (ATP) swabs to verify the efficacy of cleaning and a For routine corrective action issues, such as properly
swab indicated that an area was not clean, the sanitation cleaning a piece of equipment or making a repair, how these
supervisor could record the swab results and the results issues are addressed is quite simple. They are simply cleaned
from retesting after the suspect area was recleaned. In this case, or fixed. However, if there is a significant problem, such as a
Figure 1 Properly corrected record: cross out, date and initial. Figure 3 Improperly corrected record: Liquid Paper and tape.
Improper Record
Improper Record
major deviation at CCP or a serious quality issue, the cor- each record in the packet was not only present, but was also
rective action program and how it is documented becomes reviewed.
more complex. Again, how these issues are addressed must be There are other situations where documents and records
defined in the procedures. With complex issues, the processor are subject to review: third-party audits and regulatory in-
should define the problem, develop a written corrective action spections. Each and every third-party audit, whether it is a
plan, create a time line, and move forward on the activity. company-owned system or one of the six schemes approved
When the work is done, they will notify the quality team who by the Global Food Safety Initiative (GFSI), entail review of
will then review the records and the results and approve or procedures and records, plus evaluation of how the protocols
disapprove the work. Depending on the type of problem, they are actually implemented. With these audits, all procedures,
may recheck the issue at a later date to verify the actions were work instructions, and all kinds of records are subject to
successful. Again, this must all be documented. examination. The six schemes currently approved by are the
One tool used by many processors is a CAPA logbook. This British Retail Consortium (BRC), International Food Standard
may be retained as a hard copy or electronically. This log (IFS), Dutch HACCP, Safe Quality Foods (SQF), FSSC 22000,
serves as a reservoir for all issues that required corrective and Synergy 22000. The most stringent of all the food safety
actions and is used to track progress. Electronic logs seem to audits is that for International Organization for Standard-
be more popular as they allow the quality group to easily track ization (ISO) 22000. Companies who make the commitment
the status of corrective action activities. They can see what to meet the ISO 22000, FSMS are usually looking at 12–18
has been done and what is still pending. In addition, a well- months preparation at a minimum, plus an intensive audit by
designed electronic log allows problems to be sorted and high the certifying body of up to 5 days.
priority or regularly occurring issues can be addressed at Regulatory investigations also include review of records. The
greater length. The CAPA log is something that the HACCP records that are available for review depend on the type of in-
team should review each time they meet. vestigation and what the company is manufacturing. For ex-
ample, in the US, there will be many more records available for
review for a processor of low-acid foods than there would be for
Record Review a manufacturer of soft drinks. Food processors need to under-
stand which records the regulators are allowed to access and
One of the seven HACCP principles is verification and part of which are not. With the passage of the Food Safety Modern-
verification is ensuring that all CCPS have been properly ization Act of 2010, HACCP will become mandatory for food
monitored. Food processors must be sure that a member of processors in the US. These records and others will, therefore, be
the management team has been trained to review all records of accessible to regulators.
CCP monitoring. Ideally, this review should take place before Therefore, since documents and records are an integral part
the product is shipped. The reviewer must examine the of both third-party audits and regulatory investigations, it
monitoring records, be sure that the values are correct, and behooves a processor to properly develop, implement, and
that they have not only been filled out properly, but were also maintain these materials.
signed by the monitor.
All calibration records, especially those done on instru-
ments used to monitor CCPs, should also be reviewed on a Record Storage and Retention
regular schedule. Most companies will conduct such a review
at intervals ranging form a week to a month. An integral part of the document-control and record-keeping
The reviewer must sign and date the records following program is storage and record retention. All records must be
his/her review. If a space has not been provided for a signature stored in a secure (locked) area where they are protected from
and date, the stamp mentioned earlier may be used. It is also water damage, fire, pests, and theft. Some companies have
acceptable simply to sign and date the records. actually constructed what amounts to block houses for record
Procedures should be drafted that describe how records storage. These facilities are built in a warehouse of cinder
should be reviewed and what should be done if deviations are blocks and brick with a sturdy roof. They are air conditioned
observed. This is especially important when reviewing more and have fire abatement systems; systems that rely on chem-
complicated records such as those required for the production icals not water. The records themselves are filed in locked
of low-acid foods. There may be many CCPs for such records. cabinets in the area and the companies adopt checkout sys-
In addition, there may also be several different pieces that will tems if anything is taken out of the area. The document-
require review. As an example, there may be the operator retort storage areas are usually built with a reading room, so records
record, the recorder chart printout, and seam integrity records. can be viewed within the secure area. The storage facilities at
All need to be carefully examined and issues highlighted. most plants are nowhere near this elaborate.
Many companies bundle their daily production records There are also many companies that are turning to firms that
and require that their quality personnel review all the records will store documents for them off site. There are, however,
in the bundle, that is, food safety, quality records, and sani- regulations that mandate how long certain regulated products
tation records. Processors who utilize this kind of procedure must retain records on site. These operations have all the features
usually attach a cover sheet to the bundle listing all the re- noted earlier. They also manage their files so that they can access
quired records that must be in the packet and are subject to things quickly and easily. If the processor contacts them and asks
review. The absence of a record would then be considered a for specific records, they can usually be located and delivered
deviation. The completed packet should include evidence that within 2 h. The record storage companies will also notify the
Food Safety Assurance Systems: Documentation and Record Keeping 275
processor when the records are scheduled for destruction. When J Cleaning and sanitizing,
they get approval to move forward, they will destroy those re- J Hand sanitizers,
cords scheduled for destruction and provide the processor with J Any that have been determined to affect product safety
documentation that verifies which records were destroyed. in the company’s hazard analysis, and
This leads to another requirement for records. How long • Training.
should they be kept? The juice HACCP regulation in 21 CFR
There must also be procedures or work instructions that
Part 120. 12 (d) states the following:
describe how each and every one of these tasks must be done.
Without road maps provided in these protocols, it is simply
(d) Record retention. (1) All records required by this part shall be
not possible to ensure that the work is done properly nor is it
retained at the processing facility or at the importer’s place of
business in the United States for, in the case of perishable or re- possible to properly train new employees.
frigerated juices, at least 1 year after the date that such products Is this a great deal of work? Of course it is, but consider the
were prepared, and for, in the case of frozen, preserved, or shelf alternative: food, ingredient, or beverage that makes someone
stable products, 2 years or the shelf life of the product, whichever is sick or causes an injury. One such incident will cost more in
greater, after the date that the products were prepared.
terms of money, headaches, and loss of face than what went into
developing, implementing, and maintaining the program.
Records for low-acid canned foods must be retained for
3 years; one of which must be on-site.
For products that are not regulated, one rule of thumb is that
records should be maintained for the shelf-life of the product, See also: Food Safety Assurance Systems: Audits of Food Safety
plus 1 year. When determining how long to keep records, Management Systems; Essentials of Crisis Management; Hazard
companies need to talk to their clients and the legal department. Analysis and Critical Control Point System (HACCP): Principles and
Processors who do contract packing are often required by con- Practice; Investigation of Incidents in Industry; Labeling and
tract to keep process records for longer periods of time. Information for Consumers; Management of Allergens in Food
Electronic records must also be protected and should be Industry; Microbiological Testing, Sampling Plans, and
subject to the same storage requirements as hard copies. Microbiological Criteria; Recall Systems and Disposal of Food.
All these protocols that describe how records are stored must Institutions Involved in Food Safety: International Organization
be documented in a procedure. The basic procedure must de- for Standardization (ISO). Public Health Measures: Modern
scribe storage requirements, retention times, and mandate that Approach to Food Safety Management: An Overview
the records be destroyed at the end of the retention time, and
that records be maintained of this action. In addition, if a
company elects to store records off-site, there should be a pro-
Further Reading
cedure that describes the basic requirements for an outside
storage facility, how the storage firm is selected, and what is done Codex Alimentarius (2003) Recommended International Code of Practices, General
to monitor their performance. Principles of Food Hygiene, CAC/RCP-1–1969, Rev. 4 (2003).
International Organisation for Standardization (2005) ISO 22000: Food safety
Management systems – Requirements for any Organization in the Food Chain.
Geneva, Switzerland: ISO.
What is Required for Food Safety
Mortimore S and Wallace C (1994) HACCP: A Practical Approach. New York, NY:
Chapman Hall.
As this article has shown, there are many different records that United States Food & Drug Administration (1989a) Title 21, Code of Federal
make up the food safety management system. These include: Regulations, Part 113, Thermally Processed Low-Acid Foods in Hermetically
Sealed Containers. Washington, DC: U.S. Government Printing Office.
• HACCP plan and support documentation used in de- United States Food & Drug Administration (1989b) Title 21, Code of Federal
veloping the plan, Regulations, Part 114, Acidified Foods. Washington, DC: U.S. Government
Printing Office.
J Meeting minutes,
United States Food & Drug Administration (1995) Procedures for the safe and
J Technical references,
sanitary processing and importing of fish and fishery products, Code of Federal
• Records of CCP monitoring, Regulations, Title 21 Parts 123 and 1240, December 18.
• Records of corrective actions, United States Food & Drug Administration (1996) Current good manufacturing
practices in manufacturing, packing and holding human food, Code of Federal
• Records of verification activities,
Regulations, Title 21 Parts 110, December 18.
J Including validation data and internal audits,
United States Food & Drug Administration (2001) Hazard Analysis Critical Control
• Calibration records, Point: The safe and sanitary processing and importing of juice, Code of Federal
• Prerequisite programs, Regulations, 21 CFR Part 120. Federal Register 66(13): 6137–6202.