HACCP Documentation and Records: Things You Should Know

Why are documents and Records Important?

Food business operators must establish documentation and record-keeping procedures to implement and maintain an effective system¹. This requirement is outlined in codex guidance and legislation (step 12/principle 7).

The HACCP plan and other supporting documentation can show if the principles of HACCP have been applied correctly or not. These documents and records help support validation and verification of the HACCP plan, maintain consistency in the application of procedures between staff performing the same task, facilitate trade between different food business operators, assist root cause analysis investigations and drive continuous improvement².

Document Versus Record

What is a document?

A document is a piece of information that serves as a reliable reference point and must be maintained to ensure validity of the HACCP plan and other supporting documentation. Documents should be reviewed periodically or when a modification occurs and if necessary revised to reflect any changes that supersede older versions.

The HACCP plan is overarching documentation that supports the development, implementation and maintenance of an effective HACCP system. Codex defines it as ‘documentation or set of documents, prepared in accordance with the principles of HACCP to ensure control of significant hazards in the food business’². Information with the HACCP plan can include the following:

HACCP team composition and responsibilites²
HACCP plan scope
A list of supporting prerequisite programmes
Product description and intended use
Process flow diagram(s)
List of hazards and details of hazard analysis²
CCP and critical limit determination
Details of supporting scientific and technical information
Details of verification and review activities².

What is a Record?

A record is document that permanently captures information about activity or observation that has occurred². Information recorded by designated and trained personnel must be accurate and legible. If necessary, any correction made to a record must not obscure previously recorded information². The person making the correction must draw a single line through inaccurate information and initial the amendment. Any alteration made must be authorised and a reason for the amendment recorded. Records generated by the HACCP system include the following:

CCP monitoring activities
Corrective actions associated with a deviation at a critical limit
Validation, verification and review activities
HACCP team meetings
Details of modifications made to the HACCP plan².

What are the legal requirements for documents and records?

Regulation (EC) No 852/2004 on the Hygiene on Foodstuffs (Article 5) outlines legal requirements for food business operators to establish documentation and record keeping procedures based on the application of HACCP principles³.

Upon request by a competent authority, a food business operator must provide documents and records that demonstrates evidence of their compliance with the principles of HACCP³.This information must be in the manner required by the competent authority, taking into account the nature and size of the food business³.These procedures should be reviewed and if necessary revised when any modification is made in the product, process or step in the process. Documents describing procedures developed in accordance with HACCP principles are required to be up to date at all times³ and any other documents and records must be retained for an appropriate period³.

The defence of due diligence is outlined under the Food Safety Act 1990 and Food Hygiene Regulations (England) 2013. To avoid prosecution, the food business operator must demonstrate all reasonable precautions were taken to avoid commission of the offence or it was the fault of another person not under the control of the organisation. This can be achieved with a validated HACCP plan, written procedures, PRP/CCP monitoring and supporting information.

It is also important to retain documents and records if a claim is pursued through a civil court. Under the Limitation Act 1980, a claimant has up to 3 years to file a claim for personal injury from the date of the incident.

Management of Documents and Records

The food business operator must have a system in place for the efficient management of HACCP documents and records. Written procedures may include guidance for accepted formats, identification, version control, authorisation, amendments and verification. It is important these procedures are clearly understood by those responsible for performing the tasks.

Documents and records held in an electronic format must be stored securely to protect against unauthorised access and backed-up to prevent loss. Cyber-attacks against food businesses operators are also a growing problem. Risks should be assessed, managed and communicated to those affected. Procedures should include testing resilience and a cyber-security response plan.

Records and documents must be retained for a defined period to support verification activities and if required prove due diligence in court. Factors to consider determining a defined period include the following:

Legal (criminal and civil), customer or certification scheme requirements
shelf-life of the product
shelf-life extension due to freezing by the customer or consumer (only if specified on the label).

Do you want to learn more?

Learn more about HACCP management by enrolling onto a Highfield accredited course in Food Safety or HACCP. We contextualise training help you put knowledge into practice. Our courses are competitively priced and offer great value for money. Accredited training courses include the following

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