Recordkeeping: Linking the Chain

Departments - Practical QA Solutions

August 7, 2019

OLE DOSLAND, QA & Food Safety Consultant, Certified Instructional Designer/Professional Instructor

Where is the document? I know we did the job. How can I prove it without that record? Quality assurance and food safety professionals are becoming overwhelmed with documentation and recordkeeping. “No job is done until the paperwork is finished” is an old axiom. “No job is done until the paperwork can be quickly retrieved” might be a new axiom. The Global Food Safety Initiative (GFSI), Food Safety Modernization Act (FSMA), Hazard Analysis Critical Control Points (HACCP), and other quality assurance and food safety schemes require documentation to prove a job was done and done right. What is a practical solution?

A practical solution is challenging. The internet is awash with information readily available via global fingertips; all from devices connected almost anywhere. The food industry’s documentation and recordkeeping should be similar. Data could be transferred automatically from digital processing, measurement, and tracking equipment into electronic devices connected from almost anywhere, then repurposed into a customized document, with the record readily accessible via our fingertips.

The complexities of compliance with the GFSI, FSMA, HACCP, and other standards and regulations are a challenge for food companies and those in the supply chain. Each food manufacturing facility must be without flaws in their documentation and recordkeeping actions. Each facility must maintain records related to the manufacture, processing, packing, distribution, receipt, holding, and/or importation of their food products. But the four basic rules of documentation have not changed:

  1. Do it legibly.
  2. Do it now.
  3. Do it right.
  4. Do the organizing.

Basic questions of who, what, when, where, why, and how also have not changed. This may seem like a lot of documentation but six months later, after hundreds of jobs, you may be asked to bring a specific record to court that is vital to your defense. Words are not enough. Because this record will be subject to examination by attorneys, expert witnesses, judges, and juries, it could be used to prove liability and build jury sympathy for a punitive damage case and settlement. The documents also could become an important tool in securing a fair and reasonable compensation for an injured food consumer.

This information might be important later — which makes it very important now. We are judged by how well we do the documentation and recordkeeping. There may be times when someone covers up their actions, due to undesired consequences. Be alert for these actions. Good documentation, with proper checks, balances, and timely backup, can allow one to defend oneself anytime from anywhere.

Food Attorney Bill Marler stated: “Find a smoking gun by identifying the improper procedure that led to the contamination of the food consumed by your client.” Is your documentation and recordkeeping ready for such examination? Perhaps not. Many manufacturers are failing the HACCP requirement of documentation and recordkeeping (Principle #7).

A solution is within electronic documentation of desktop, laptop, and tablet computers, smart phones, smart watches, smart TVs, smart cameras, smart vehicles, smart drones, etc. But the transition from paper-based documentation to electronic documentation is still underway. Outdated documentation processes make it difficult to improve food safety conditions and properly manage escalating data.

The complexity of managing multiple processing lines with an impressive array of digital measurement devices from multiple manufacturing facilities — while tracking the holding and distribution of food products — is creating a digital technology crossroads. In-line real-time testing provides a means to make timely adjustments assuring process control, but these devices should be directly connected to the documentation program. The rekeying of data is not efficient, and now is not a good time to be inefficient.

Moving into total electronic documentation by linking food manufacturing throughout the supply chain to the farm and throughout the food distribution system to consumption, including testing results from many measurement devices, will have its challenges — and will not be a cure-all.

As Dell Technologies CEO  and  Founder Michael Dell said, “Technology doesn’t solve the world’s problems, people do. We should use technology better to help ourselves.”