Know: Record Retention

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Record Retention

Introduction

Record retention is an important facet of food manufacturing operations, ensuring that necessary documentation is maintained, stored, and accessible for the required period as stipulated by regulatory agencies, internal policies, and industry best practices. Effective record retention supports compliance with food safety regulations, quality standards, and traceability requirements, while also providing a basis for continuous improvement.

Key Components of Record Retention

1. Types of Records in Food Manufacturing
• Quality Assurance (QA) and Quality Control (QC) Records: These include inspection reports, testing results (e.g., microbiological testing, chemical testing), and compliance with specifications for raw materials, intermediate, and finished products.
• Production Records: Includes batch production records, process control logs, equipment maintenance logs, and operator shift records that document the manufacturing process.
• Food Safety Records: Documentation related to Hazard Analysis Critical Control Points (HACCP), food defence actions (e.g. seal checks), allergen management (e.g. cleaning verification swab results), cleaning and sanitation records, and corrective actions taken for non-compliance or deviations.
• Supplier and Raw Material Records: This includes records of incoming raw materials, supplier certifications, COAs/COCs, and traceability data.
• Regulatory Compliance Records: Records showing compliance with local and international food safety regulations.
• Employee Training and Certification Records: Documentation of employee training on food safety, hygiene practices, and other essential skills.
• Audit and Inspection Records: Internal and external audits, inspections by regulatory bodies, and third-party certifications.
2. Record Retention Requirements
• Legal and Regulatory Requirements: Many countries and regions have laws that dictate the minimum retention periods for certain types of records. For example:
• In the U.S., the FDA’s Food Safety Modernization Act (FSMA) may require records related to food safety to be kept for two years or longer.
• European Union regulations may require records for certain food safety and quality controls to be retained for at least 5 years for certain types of records.
• Industry Standards: Certain standards, such as those set by GFSI (Global Food Safety Initiative) or BRC (British Retail Consortium), may specify record retention periods for audits, certifications, and quality control data. This is typically a function of the shelf life of products manufactured, plus an additional 12 months.
3. Retention Periods
• The length of time to retain records depends on the type of record and its purpose. Some typical retention periods include:
• Production and Process Records: Often required to be kept for 2-5 years.
• Food Safety Records: Usually retained for 2-5 years, depending on the specific regulatory body.
• Audit Records: Retained for at least 3 years for external audits and inspections.
• Employee Training Records: Typically retained for the duration of employment plus an additional 2-3 years.
• Regulatory Compliance Records: Must be kept for 5 years or more to demonstrate compliance with regulations and certifications.
4. Digital and Physical Records
• Physical Records: Physical records (such as handwritten production logs or paper-based certificates) need to be properly filed and stored in a secure, organised manner to prevent loss, damage, or unauthorised access.
• Digital Records: Many companies are transitioning to digital record-keeping systems for easier storage, retrieval, and backup. Electronic records should comply with regulatory requirements for authenticity, security, and data integrity.
• Digital systems can automate record generation, logging, storage, and retrieval, making the process more efficient and ensuring compliance with regulatory requirements.
5. Record Retention Policy
• Creation of a Record Retention Policy: Companies should develop and implement a formal record retention policy to specify:
• Which records are to be retained and for how long.
• The process for securely storing and disposing of records once they reach the end of their retention period.
• A clear protocol for accessing and retrieving records when required for audits, inspections, or investigations.
• Training: Employees should be trained on record retention procedures, including how to maintain, handle, and dispose of records, and how to use digital systems for record management.

Best Practices for Effective Record Retention

1. Clearly Define Record Categories and Retention Periods
• Establish categories for all types of records (e.g., quality control, food safety, employee training) and define clear retention periods based on legal and regulatory requirements.
2. Implement a Secure Filing System
• For physical records, use filing cabinets or storage systems that are secure, organised, and easy to navigate.
• For digital records, use encrypted, password-protected storage with automatic backup and disaster recovery plans.
3. Leverage Digital Technologies
• Use digital tools such as Document Management Systems (DMS) to streamline record management. These tools can automatically tag, organise, and manage records, making it easier to retrieve them when needed.
4. Regularly Review Retention Schedules
• Regularly review and update the record retention policy to ensure it aligns with changing regulations, industry standards, and internal processes.
5. Dispose of Records Securely
• When records reach the end of their retention period, ensure they are securely destroyed to prevent unauthorised access or misuse. For digital records, ensure proper deletion methods (e.g., formatting of hard drives, secure deletion of files).
6. Train Employees on Record Retention Protocols
• Provide ongoing training to employees involved in record-keeping on proper procedures for retention, retrieval, and disposal. This helps to maintain consistency and compliance.
7. Maintain Traceability and Accessibility
• Ensure that records are easy to access and track. This includes maintaining records in a manner that allows for traceability (e.g., batch numbers, product identifiers) and ensuring that records are readily accessible in case of audits or recalls.

The Importance of Record Retention in Food Manufacturing

1. Compliance with Regulations: Retaining records as required by food safety regulations ensures that the company meets the legal standards set by local, national, and international authorities. Failure to comply can lead to fines, legal issues, and loss of certifications.
2. Product Traceability: Effective record retention enables traceability, which is crucial in the event of a product recall, contamination, or safety issue. It allows manufacturers to track the source of raw materials, monitor production processes, and ensure that affected products are removed from the market.
3. Quality Control: Records provide a detailed history of quality assurance and control activities, ensuring that products meet the required standards. This is critical for maintaining consumer trust and product safety.
4. Continuous Improvement: By retaining records, manufacturers can identify patterns, trends, and areas for improvement in their processes. Historical records provide data that can be analysed to drive continuous improvement in food safety, quality, and operational efficiency.
5. Audits and Inspections: Records serve as proof of compliance during internal and external audits. Regulators and third-party auditors often request access to records to verify that food manufacturers are adhering to standards and regulations.

Conclusion

Record retention is a fundamental aspect of food manufacturing, ensuring that companies comply with regulatory requirements, maintain food safety standards, and support continuous improvement. By developing robust record retention policies and leveraging technology, food manufacturers can ensure that essential documents are accessible, secure, and compliant with industry regulations.

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