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Recordkeeping system review

Whether your records prove what the system claims, can be completed accurately on the floor, and can be found when someone asks.

What is a recordkeeping system review?

A recordkeeping system review assesses whether the records a food business keeps prove what the food safety system claims, whether they can be completed accurately in the conditions people work in, and whether they can be found when someone asks. Records are where certification audits are won and lost, because they are the only evidence that the system operated.

Most record failures are design failures. A blank asking for six entries at a step that allows time for two guarantees shortcuts, and the shortcut becomes the finding while the form that caused it goes unexamined.

Summary

Inventory, coverage, blank design, conventions, retention and retrieval assessed together, with redesigned forms delivered. On site, in any language, quoted on scope.

Recordkeeping review at a glance

Assesses
Whether records prove what the system claims
Standards
BRCGS, IFS, FSSC 22000, ISO 22000, SQF, customer codes
Covers
Paper and electronic records
Includes
A timed cold retrieval test
Delivery
On site, since conditions are the subject
Output
Redesigned blanks, conventions, retention schedule
Coverage
Worldwide
Languages
Any language, including English, Spanish, French, German, Italian and Portuguese

What a record has to be

Eight qualities, each assessed against your records as they are completed on the day.

QualityWhat it meansCommon failure
CompletableThe blank can be filled in accurately at the moment the task happens, in the conditions it happens in.A form requiring six entries at a step that allows time for two.
ContemporaneousCompleted at the time, by the person who did the work.A shift of readings entered at the end, visible in handwriting, ink and spacing.
CompleteEvery field filled, with a defined convention for fields that do not apply.Blanks left empty, so nobody can tell whether the check failed or was skipped.
AttributableClear who recorded it and who checked it, with legible identification.Initials nobody can match to a person, or a signature used by a whole shift.
MeaningfulRecords the value, not a tick. A number can be trended, a tick cannot.A checklist of ticks where the actual reading is what mattered.
Corrected properlyErrors struck through, initialled and dated, with the original still readable.Overwritten figures and correction fluid, which read as concealment.
RetrievableFound within the time a trace or an audit allows, by someone other than the author.A record that exists and takes twenty minutes to locate.
RetainedHeld for the period the standard and the shelf life require.Records disposed of while the product they cover is still on the market.

Where recordkeeping fails

Eight failures, and the first is the most serious finding available in any audit.

What you receive

Blanks are redesigned around the conditions they will be completed in.

ElementWhat it covers
Record inventoryEvery record the system relies on, with what it proves and who completes it.
Coverage gapsControls with no record behind them, and records nothing relies on.
Blank redesignForms rebuilt so they can be completed accurately in the conditions they are used.
Convention setHow to handle not applicable, corrections, and out of limit entries.
AttributionIdentification and countersigning arrangements that hold up at audit.
Retention schedulePeriods set against shelf life, standard requirements and legal duty.
Retrieval structureIndexing so any record can be found quickly by someone other than the author.
Review designRecord review that states what was found instead of that it happened.

Who a recordkeeping system review is for

Food manufacturers, processors, packers, storage operations and catering businesses. It suits sites where records are the recurring audit finding despite the work being done properly.

Record findings keep recurring despite the work being done.

Blanks cannot be completed accurately in the conditions.

Checklists are used where readings would allow trending.

Empty fields have no defined convention.

Corrections are made by overwriting.

Record review is a signature with no findings recorded.

Retention is shorter than shelf life.

Records take too long to find during an audit.

How the review is carried out

  • 1

    Inventory

    Every record the system relies on is listed with what it proves and who completes it.

  • 2

    Coverage check

    Controls with no record behind them are identified, alongside records nothing relies on.

  • 3

    Floor observation

    Blanks are watched being completed, because a form that fails does so in the conditions and not at a desk.

  • 4

    Sampling

    Completed records are sampled for completeness, attribution, corrections and signs of retrospective entry.

  • 5

    Retrieval test

    A record is requested cold and timed, by someone other than the person who keeps it.

  • 6

    Redesign

    Blanks, conventions, retention and review design are delivered, with an index for retrieval.

Not included

Completing your records. The review designs the system and your team operates it.

Electronic system selection or configuration. No commission or referral arrangement exists with any software supplier.

Where sampling suggests records have been completed retrospectively, you are told directly. That is a serious matter and it is not softened.

What a recordkeeping system review costs

Every review is quoted against its own scope. A single line with a dozen record types and a three site operation on mixed paper and electronic systems are very different pieces of work. These factors set the price.

Number of record types

Paper or digital

Standard in scope

What this service is assessed against

These are the primary sources this work is built on. Where a market you sell into has its own requirement, that takes precedence and we assess against it.

Regulation (EC) No 852/2004 on the hygiene of foodstuffs
The general hygiene requirements and the duty to operate procedures based on HACCP principles. EUR-Lex
21 CFR Part 117, preventive controls for human food
The FSMA hazard analysis and risk based preventive controls requirements, including validation and verification. eCFR
Regulation (EC) No 178/2002, general food law
Traceability duties, the withdrawal and recall obligation, and the duty to notify the competent authority. EUR-Lex
BRCGS, IFS Food, FSSC 22000 and SQF published requirements
The clause your certification body audits against, which differs between schemes and between issues. BRCGS

Recordkeeping terms

Contemporaneous record
A record completed at the time the activity took place, by the person who performed it.
Attributability
The ability to identify who made a record entry and who checked it.
Retention period
The time a record must be kept, normally driven by shelf life, the standard and legal requirements.
Record blank
The form or template used to capture what a procedure requires to be recorded.
Countersignature
A second signature confirming a record has been reviewed, which should state what the review found.
Data integrity
The completeness, accuracy and reliability of records across their life.
Falsification
Creating or altering a record to show something that did not happen, treated as a critical failure by every scheme.
Trend analysis
Examining recorded values over time to detect drift before a limit is breached.

Recordkeeping questions

It has to be completable in the conditions the task happens, completed at the time by the person who did the work, complete with a convention for fields that do not apply, attributable to a named person, meaningful enough to be trended, corrected properly where errors occur, retrievable quickly and retained for the required period.

It is visible to an experienced auditor through handwriting, ink and spacing, and it is treated as falsification. That carries far more serious consequences than the gap it was meant to hide, including loss of certification. Where a record was not kept, the honest entry is that it was not kept, with the corrective action recorded.

Values, wherever a value exists. A tick confirms a check happened. A number can be trended, which shows drift towards a limit before it is breached. Checklists have their place for presence and absence checks and should not replace readings.

A single strike through, initialled and dated, with the original entry still readable. Overwriting, correction fluid and rewriting a page cleanly all read as concealment even when nothing was concealed.

Use a defined convention, recorded in the procedure, such as a dash or the letters NA. An empty space is ambiguous between not applicable, not done and not checked, and auditors take the least favourable reading.

Long enough to cover product still on the market, which means at least shelf life plus a margin, and longer where your standard or local law requires. Records destroyed while covered product is still out there make a trace impossible.

Yes, and the same requirements apply. Entries need to be attributable, the time of entry needs to be captured, changes need an audit trail showing the original value, and access needs controlling. A spreadsheet anyone can edit with no history satisfies none of that.

A statement of what the review found. A countersignature confirming records were checked evidences that someone looked. A note that two out of limit readings were found, investigated and closed evidences a system working.

The person doing the work, at the time. Records completed by a supervisor from what they were told lose attributability and accuracy, and they are frequently the ones that turn out to be retrospective.

Usually because the blanks were designed by someone who does not perform the task. A form asking for six entries at a step that allows time for two guarantees shortcuts, and the design causes the failure while the operator receives the finding.

Fast enough for a trace within the time your standard sets, and fast enough that an audit request does not stall. Twenty minutes of searching reads as a system nobody operates, whatever the record eventually shows.

A record inventory, coverage gaps in both directions, redesigned blanks that can be completed in real conditions, a convention set for not applicable and corrections, attribution arrangements, a retention schedule, a retrieval structure and a record review design.

Who carries out this work

Confi Food assigns work by subject. HACCP, labelling, certification standards, regulatory compliance, supplier assurance and monitoring are separate disciplines, and each piece goes to someone who works in that area. Every deliverable is reviewed internally by a second specialist before it reaches you.

Our technical positions are built from primary sources, meaning the legislation, the competent authority, Codex Alimentarius, the certification scheme owner or the relevant standards body. We set out how that works in our technical review and editorial policy, and what happens at each stage of an engagement in how Confi Food works.

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Tell us the site, the record types and how they are kept, and receive a written quote covering the scope, the deliverable and the price.