Record keeping for Control Point - not a CCP

Hello,

I am working on a HACCP plan and there are some Control Points (CP), in addition to a CCP. For example, the CPs are "magnetic grids" in the line, whereas the CCP is a metal detector.

This may be a basic question, but for the CPs (not CCP), are we required to maintain records of inspections (for example)?

Thanks!

Is the efficacy of your metal detector dependent in any way on the magnet grids upstream? If so, I would think you would need documentation on the function of the grids to support the claim that your CCP is working as intended.

Had a similar setup in a spice milling plant.  Magnets were documented in our HACCP plan as a control device complimenting the metal detector CCP.  We covered them on a separate form for checks every two hours.  Basically, they're doing a job in your system, your company sees a need for them to be in the system, so now you should be monitoring them.

Hi rdquality,

Yes, you should have records, requirements from the SQF Food Safety Code:

11.7.3 Control of Foreign Matter Contamination

11.7.3.1 The responsibility and methods used to prevent foreign matter contamination of the product shall be documented, implemented, and communicated to all staff.

11.7.4 Detection of Foreign Objects

11.7.4.1 The responsibility, methods, and frequency for monitoring, maintaining, calibrating, and using screens, sieves, filters, or other technologies to remove or detect foreign matter shall be documented and implemented.

11.7.4.4 Records shall be maintained of the inspection of foreign object detection devices, of any products rejected or removed by them, and of corrective and preventative actions resulting from the inspections.

2.5.2 Verification Activities (Mandatory)

2.5.2.1 The methods, responsibility, and criteria for verifying monitoring of Good Manufacturing Practices, critical control points, and other food safety controls, and the legality of certified products shall be documented and implemented.

2.5.2.2 A verification schedule outlining the verification activities, their frequency of completion, and the person responsible for each activity shall be prepared and implemented.

Records of verification of activities shall be maintained.

Kind regards,

Tony

If you're going to make an observation, it is in your best interest to document it and get "credit" for doing it.  If there are any problems, complaints, or system failures the documented control point can reduce liability, provide customers with additional assurance, or provide you with evidence to support less drastic remediation.

I've heard more than one inspector or auditor say something to the effect of "If it's not documented, it didn't happen."