10 replies to this topic

[carine]

Hi all, 

 

Im in the midst of updating my record control list, i was wondering if HACCP worksheet and hazard Plan Summary deemed as record and should set the retention period of it? ? 

[GMO]

When you state "HACCP worksheet" what exactly do you mean? Do you mean the formatting of the hazard analysis document before it's completed? No I'd document control the completed version which is what I assume you mean by the "hazard plan summary" if I was working at an individual site. In the UK we would call this the "hazard analysis". Methods vary but it's not a summary, it's the entire hazard analysis assessed against the physical, chemical, biological and allergen hazards with the risk assessment, control measures and CCP determination all on one document. Also referencing any applicable PRPs and oPRPs if they are being used. Is that what you mean?

 

If you work for an organisation where there are multiple HACCP plans and you're defining the format for them all, e.g. you're in a group function, then that's different, I'd document control the format at a group level if I was asking someone to use that format at their plant. I'd then expect the plant to document control the completed version at their level.

 

Retention time will depend on the certification scheme you have and of course you need that in your procedures but nowadays I wonder why anyone practically considers deletion. Data storage is cheap nowadays. Just retain in at least a PDF version ad Infinium.

[carine]

Hi GMO. 

 

Would you consider this complete HACCP analysis & summary as RECORD? I'm considering whether want to include these in record control list. 

When you state "HACCP worksheet" what exactly do you mean? Do you mean the formatting of the hazard analysis document before it's completed? No I'd document control the completed version which is what I assume you mean by the "hazard plan summary" if I was working at an individual site. In the UK we would call this the "hazard analysis". Methods vary but it's not a summary, it's the entire hazard analysis assessed against the physical, chemical, biological and allergen hazards with the risk assessment, control measures and CCP determination all on one document. Also referencing any applicable PRPs and oPRPs if they are being used. Is that what you mean?

 

If you work for an organisation where there are multiple HACCP plans and you're defining the format for them all, e.g. you're in a group function, then that's different, I'd document control the format at a group level if I was asking someone to use that format at their plant. I'd then expect the plant to document control the completed version at their level.

 

Retention time will depend on the certification scheme you have and of course you need that in your procedures but nowadays I wonder why anyone practically considers deletion. Data storage is cheap nowadays. Just retain in at least a PDF version ad Infinium.

[EvenKeel]

In my experience, HACCP worksheets and the HACCP / Hazard Analysis summary are considered records, not just reference documents, so I include them in the record control list with a defined retention period. They provide evidence that the hazard analysis was performed and maintained, and auditors usually expect them to be controlled and retained at least until the next HACCP review, plus an additional period if required by the audit cycle or legal needs.

[carine]

Dear EvenKeel, 

 

What retention period u put on record control list? Can i put 1 year or next update? or any others official term to put? 

In my experience, HACCP worksheets and the HACCP / Hazard Analysis summary are considered records, not just reference documents, so I include them in the record control list with a defined retention period. They provide evidence that the hazard analysis was performed and maintained, and auditors usually expect them to be controlled and retained at least until the next HACCP review, plus an additional period if required by the audit cycle or legal needs.

[GMO]

What standard are you working to? What does that say?

[EvenKeel]

Dear EvenKeel, 

 

What retention period u put on record control list? Can i put 1 year or next update? or any others official term to put? 

In practice, I usually set the retention period as until next HACCP review/revision + X years rather than a fixed 1 year. One year can be risky if your HACCP review cycle is longer or if an auditor asks to see previous versions. A common approach is to keep them for the duration of the HACCP plan validity plus 2-3 years, aligned with audit cycles and any legal or customer requirements.

[SHQuality]

Dear EvenKeel, 

 

What retention period u put on record control list? Can i put 1 year or next update? or any others official term to put? 

If you store a document for just one year or until the next update, how are you ever going to document the changes a document went through over time? I mean, a change log can only record so much. Can you really not save 1-2 previous versions?

 

Besides, we don't know the shelf life for the products you produce. At the very least you need to have a copy of the documents that were in use when your oldest product currently within shelf life was produced, just in case any question come up. 1 year doesn't sound like it would be enough for anything with any sort of extended shelf life.

 

I agree with GMO. What is stopping you from storing documents for a longer period of time?

[Tony-C]

Hi all, 

 

Im in the midst of updating my record control list, i was wondering if HACCP worksheet and hazard Plan Summary deemed as record and should set the retention period of it? ? 

 

Hi Carine,

 

They are working documents and should be controlled on a document or record register/list. As they are relevant they do not have a retention period because they are relevant to your process and current until reviewed and changed.

 

When you change them I would retain copies of the old obsolete ones for a period that would reflect the shelf life of the product and applicable legislation, so for at least a couple of years, probably 3 years plus for long life products.

 

Kind regards,

 

Tony

[EvenKeel]

If you store a document for just one year or until the next update, how are you ever going to document the changes a document went through over time? I mean, a change log can only record so much. Can you really not save 1-2 previous versions?

 

Besides, we don't know the shelf life for the products you produce. At the very least you need to have a copy of the documents that were in use when your oldest product currently within shelf life was produced, just in case any question come up. 1 year doesn't sound like it would be enough for anything with any sort of extended shelf life.

 

I agree with GMO. What is stopping you from storing documents for a longer period of time?

From my experience, a fixed 1-year retention is usually too short. I’ve always treated document retention as risk-based rather than calendar-based. At a minimum, you need to keep the versions that were in use when any product still within shelf life was produced. On top of that, keeping previous versions for a few years helps with audits, investigations, and trend analysis. In practice, current version + previous versions for X years (often 2-3) has worked well and has never been questioned by auditors, as long as it’s justified and consistently applied.

[GMO]

From my experience, a fixed 1-year retention is usually too short. I’ve always treated document retention as risk-based rather than calendar-based. At a minimum, you need to keep the versions that were in use when any product still within shelf life was produced. On top of that, keeping previous versions for a few years helps with audits, investigations, and trend analysis. In practice, current version + previous versions for X years (often 2-3) has worked well and has never been questioned by auditors, as long as it’s justified and consistently applied.

 

I agree with HACCP particularly you will want to see what changed in the previous review. With some sites only reviewing HACCP once per year then that could mean the previous document is not available.

 

As I said before, I'd keep them indefinitely anyway but the usual rule of thumb is shelf life of the product plus one year minimum (but some retailer standards particularly say longer so check whatever you are certified to) but with HACCP I'd keep it longer still because of the potential low rate of change and impact on your whole FSQMS.

 

With WGS becoming a more used "thing" and with the potential to go back to historical cases, I see no benefit in deleting any electronic documents IMO as storage is cheap especially for items kept as PDFs. I may put into an archive file but I would still have them accessible.