How long do you keep HACCP records?
The law does not set a fixed number of months or years for HACCP records. Article 5(4) of Regulation 852/2004 says that you keep them for an appropriate period. The hygiene code for hospitality from KHN (Koninklijke Horeca Nederland, the Royal Dutch Hospitality Association) makes this concrete: at least six months, and at least one year for records of unchilled display of products that must normally be chilled. You record such a period in your HACCP plan or take it from your hygiene code. HACCP stands for Hazard Analysis and Critical Control Points. The NVWA (Netherlands Food and Consumer Product Safety Authority) can request the records during an inspection.
A retention period from another business or another sector does not necessarily apply to you. A bakery, a butcher and a restaurant follow different codes. Take the period from the code for your sector or from your own plan, and check the source.
What do you keep?
Think in three categories. The first are the daily records: temperatures, cleaning, goods-in and the allergen matrix. The second are the documents around the plan: the plan itself, its versions, the HACCP team and the change logs. The third are the proof of training and verification: staff instructions, internal checks and the outcome of an external audit.
| Category | Examples | Why keep them |
|---|---|---|
| Daily records | Temperature lists, goods-in checks, cleaning sign-off lists | Proof that you carried out your CCPs and basic conditions |
| Plan and versions | Plan, change log, hazard analysis | Proof of what you recorded, when and why |
| Training and verification | Staff instructions, internal checks, pest controller reports | Proof that the system worked and was checked |
| Deviations | Reports, corrective actions, complaints | Proof that you dealt with deviations |
This last category is often forgotten. A deviation that you have resolved is strong evidence of a working system. So do not throw it away when you clear out the lists.
Example of a retention period in the plan
A fictional bistro records its retention periods in its plan, as shown below. The bistro follows the hygiene code for hospitality and adopts the KHN periods, with its own margin for the plan and training.
| Item | Retention period | Basis | Where |
|---|---|---|---|
| Daily and weekly lists | At least 6 months | Minimum from the KHN hygiene code for hospitality | Digital, with a back-up |
| Records of unchilled display of chilled products | At least 1 year | Minimum from the same code | Digital, with a back-up |
| Plan and versions | As long as the plan is valid, plus 1 year after that (own choice) | Proof of what you recorded and when | Folder with the owner |
| Training | As long as the member of staff is employed, plus 1 year (own choice) | Proof of instruction | Personnel file |
| Verification and audits | At least 1 year (own choice) | Proof of checking | Folder with the person in charge |
Only the 6 months and the year for unchilled display come from the code. The rest are the bistro’s own choices. If you have a certificate or a customer who asks for more, for example ISO 22000, check what they require as well, and keep to the longest period. Have the owner sign off the periods.
How do you keep the records?
Good record keeping has three qualities. The data can be found within a short time. It cannot be changed quietly. And it stays available after a computer failure or a change of staff.
For paper lists, that means a fixed folder with an index and a place that never changes. For digital systems, it means a back-up and a log of changes. A spreadsheet that someone edits afterwards without a trace is the weakest point of the records.
What does the inspector want to see?
During an inspection, the NVWA asks for the records of the recent period and checks a selection. They look at completeness and traceability. If there is a deviation, can they find what was done and by whom?
Common mistakes:
- Throwing away lists within six months, or without the retention period being in the plan
- Records missing for the period in which a deviation occurred
- Completed lists that were copied afterwards and show the same values
- No place or no access for the inspector, for example because the administration sits with an external party
Link with the seventh principle
The seventh HACCP principle covers documentation and record keeping. That principle calls for a system you can check afterwards, and the retention period belongs to it (Article 5(2)(g) and Article 5(4) of Regulation 852/2004). Read the background on the 7 HACCP principles.
For what you must record per list, see HACCP lists for hospitality. For what the inspector asks exactly, see NVWA inspection of HACCP. For when you must update the plan and raise the version number, read when to update your HACCP plan.
Frequently asked questions about record keeping
May I keep records digitally?
Yes, as long as the data cannot be changed quietly, there is a back-up and the inspector can view it. Record the method in your plan.
What if a member of staff made a mistake on a list?
Correct the mistake with a single line through it, an initial, the date and the reason. Do not erase the original value. That way it stays visible what happened.
Must I keep rejected batches as well?
Record the rejection and the reason, even if the product has been thrown away. This proves that you use the system.
Sources
- NVWA: Working according to the HACCP system
- KHN: Hygiene code for hospitality , with the retention periods of six months and one year
- Regulation (EC) No 852/2004 on food hygiene , Article 5(4)
- Hygiene code and HACCP, for the retention agreements in the sector code