Processors need to keep daily records that document the implementation and monitoring of the Sanitation SOPs (standard operating procedures) and any corrective actions taken, says Ann Wells, director of scientific and regulatory affairs for the North American Meat Processors Association. In addition, they need the following HACCP documentation: the written hazard analysis with supporting documentation; the written HACCP plan and decision-making documents associated with the selection and developments of CCPs, critical limits and monitoring and verification procedures; records documenting the monitoring of CCPs and their critical limits, calibration of the process-monitoring instruments, corrective actions, verification procedures and results; and product codes, product name or identity, or slaughter production lot.
“In addition, prior to shipping product, the establishment shall complete a pre-shipment review, which is to review the records associated with the production of that product to ensure that all critical limits were met,” she adds.
The SSOPs should be kept for six months, Wells says. HACCP records should be kept for slaughter activities for at least one year, for refrigerated products for at least one year and for frozen, preserved or shelf stable products for at least two years.
“SSOP records should be kept on-site for at least 48 hours,” Wells says. “HACCP records should be maintained on-site for at least six months. After that, off-site storage of records is permitted, if such records can me retrieved and provided, on-site, within 24 hours of an FSIS employee’s request.”
Attention to detailSome of the most common errors are ones that can be easily avoided. “Law states that SSOP records must be initialed and dated by the person responsible for the procedures,” explains Kaleigh Frazier, public information officer for the Ohio Department of Agriculture. “Further, HACCP records require that and entry on a record must be initialed, dated and state the time the entry was made. The majority of errors found deal with facilities forgetting to include the date or time or the initials.”
Another common mistake, Frazier notes is that facilities do not note the frequency of monitoring and verification procedures in the HACCP plans.
“These errors can be avoided if time is taken to properly cover everything that must be included, and then double-checking,” she says.
Wells says that plants should review their records in order to prevent any lapses in details.
“Missed entries, a missed signature or a missed date are small problems that can cause big headaches if they are not caught,” she says. “When mistakes are found, the records should indicate that as well.”
When it comes to including decision-making documents in its records, Wells notes that they do not have to be scientific journal papers.
“Plants often forget that documenting decisions with experts, thought processes, plant history and internal data can support decisions as well,” she says.
In the event of a recall, there will be several records that the inspectors will need to see, says Frazier.
“We would need to see records to identify all affected product; HACCP records to determine what is wrong with the product and how much product may be involved; SSOP records to examine cleaning records; and microbiological testing. Facilities are required to make available any food safety testing results that they have.”
Wells says that companies will need to show their distribution records to help determine where the recalled products are.
“All establishments should have a system of product coding sufficient to identify recalled products,” she says.