HACCP Principle 7: Establish Record-Keeping & Documentation Procedures

Bureaucracy is not the point here, understanding and not repeating mistakes is

The final principle in the HACCP process is to establish record-keeping and documentation procedures. While all principles are important, one could argue this is the most important. After all, without complete and accurate records there is no way to tell whether or the HACCP process is working. More importantly, without complete and accurate records there is no way to confirm data when something goes wrong and unsafe food products are shipped. As the Spanish philosopher, poet, novelist George Santayana wrote in his book on moral philosophy titled The Life of Reason, “Those who cannot remember the past are condemned to repeat it.” (Many substitute history for the past when it is incorrectly quoted.)

I would argue the HACCP Team’s most important job is to make the HACCP process easy to use and implement and to make the “bureaucratic” pieces both complete and manageable, not an easy balancing act. As was noted before, HACCP principles and procedures are in many cases being applied to existing businesses, businesses that have been operating safely for quite some time. Adding to the workload of production, quality and distribution personnel will need to be done with recognition that the additional work will require workers to perform additional duties, duties that in many cases add more time to identified CCP steps. The HACCP Team will need to work with management and workers to insure the additional workload is acknowledged and adequate time is built into the schedule to perform it to expectation.

Two admissions I’m sure many can relate to:

1. I hate meetings for the sake of meetings, especially ones that don’t start and end on time.

2. I hate paperwork, especially filling out forms.

That being said, making record-keeping and documentation as robust and easy as possible should be the goal of the HACCP Team. First, automate monitoring and data collection wherever possible. This may not be possible due to physical or financial limitations, however the HACCP Team will want to automate as much as possible and to request a budget for additional automation in the near future.

Examples of automation can include:

• Temperature monitoring devices for food preparation areas, refrigerators and freezers. Preferably the devices automatically record the temperature data. With today’s digital world this is relatively easy and inexpensive.
• Temperature and critical parameter sensors (e.g. humidity, pressure, weight, etc.) and control devices on food processing equipment, especially where high volume production lines are in place.
• pH sensors especially where the acidity of a process or product is critical to the safety of the product.
• Flow, volume, and weight sensors and control devices.
• The ability to download or automatically collect data into a computer to generate reports and control charts.
• Automated alarm and alerting capabilities to allow correction where possible and identify misprocessing or failure of equipment when it occurs.

Automation in high volume production plants has become a way of life, helping insure the safety of food products for millions. Each year new technologies are adapted to the production, processing, packaging and distribution chain that makes up the large scale food service industry modern, industrialized countries take for granted.

Metal cans have been replaced by aseptic pouches and boxes, glass bottles by HDPE, LDPE, and Polypropylene, and paper products by foamed plastics such as styrofoam. While there are plusses and minuses to these changes, convenience has been made normal. Food service operations do not always have the luxury to automate everything since their menus are often wide and varied ranging from hot cooked foods to cold salads and ice cream, for example. In these establishments automating temperature monitoring in chilled food preparation counters, refrigerators, and freezers can generally improve both the frequency and completeness of the data. Combined with software and a connection to the internet or cell tower these devices can not only automate reporting but alert staff when problems occur, a power outage or refrigerator compressor failure for example, allowing quick action to prevent both product loss and potential exposure of food to unsafe temperatures.

Data collection whether automatic or manual is entered into documents developed by the HACCP team for review and archiving. When and how to record the data and other pertinent notations is determined by the type of recording process developed by the team. Computerized may be best for some, manual for others, and a mixed model for still others. Depending on the HACCP implementation budget and the organization’s abilities, the team will need to develop procedures, forms, etc. to match these factors. In the end more may not always be better. The key is to focus on those characteristics that the team identified as contributing to food hazards. Once that is accomplished insuring the organization is dedicated to using the process will lead to success.