Record keeping for your preventive control plan
Requirements for the Safe Food for Canadians Regulations
Although the Safe Food for Canadians Regulations (SFCR) came into force on January 15, 2019, certain requirements may apply in 2020 and 2021 based on food commodity, type of activity and business size. For more information, refer to the SFCR timelines.
What is a record?
A record is a type of document that permanently captures information demonstrating that an action was taken. It can be in either hard copy (printed) or electronic (digital) format. The information can take various forms such as text, figures, graphics, data pictures and videos.
In a In a Preventive Control Plan (PCP), systematic record keeping simplifies the retrieval of records when they are needed. Record keeping is the seventh principle of a Hazard Analysis Critical Control Point (HACCP) system.
Records are documents that provide an accurate history of the food and its manufacturing process. They provide evidence that the PCP is implemented and working effectively.
The SFCR requires preventive control plan records to be kept for 2 years (3 years for records related to the processing of shelf stable low-acids foods in hermetically sealed containers).
The Canadian Food Inspection Agency (CFIA) created this document as guidance to help food businesses comply with the requirements of the Safe Food for Canadians Regulations.
You may use other guidance documents that have been developed by provincial governments, industry associations, international partners or academia. Always ensure that the record keeping guidance document you choose is relevant for your particular business, product or products, and market requirements.
What is included
This document outlines generic best practices for keeping records. It also outlines:
- what records are
- what records are intended to do
- how to ensure the integrity of electronically recorded data
- what a record keeping procedure should include
Refer to the Tell me more! section for additional sources of information that may help you establish your record keeping procedures.
What is not included
The examples provided are not exhaustive. The records retained vary for each business. For this reason the document does not specify the manner in which the information is recorded. For example, for a particular critical control point or other control measure, one business may choose to capture monitoring activities on one record and verification activities on another, while another business may choose to capture both activities on the same record.
Roles and responsibilities
Food businesses are responsible for complying with the law. They demonstrate compliance by ensuring that the commodities and processes for which they are responsible meet regulatory requirements. If a written PCP is required, the food business develops a PCP with supporting documents, monitors and maintains evidence of its implementation, and verifies that all control measures are effective.
The CFIA verifies the compliance of a food business by conducting activities that include inspection, and surveillance. When non-compliance is identified, the CFIA takes appropriate compliance and enforcement actions.
The purpose of records
Accurate record keeping is essential to the application of a preventive control plan. Records enable you to confirm easily and with confidence that your preventive control plan is implemented and working effectively. Records can also help you improve your preventive control plan by providing a means for you to, for example:
- identify the root cause of an issue
- analyse and improve a process or procedure
- identify gaps in training and in training needs
The records you keep will be unique to your food business depending on the size of your operation, the food you produce or import, and the design of your PCP. Following are some examples of records.
- observations or measurements taken to monitor a critical control point in relation to its critical limit (such as time and temperature readings) and other processing-related records
- ingredient, finished product, and food contact surface test results
- equipment calibration logs
- personnel training records
- records of injured, disabled or sick animals (slaughter establishments)
- incident reports (such as for broken glass, chemical spills)
- deviation and associated corrective action records
- verification activity records
The Codex HACCP guideline states that, "a simple record-keeping system can be effective and easily communicated to employees. It may be integrated into existing operations and may use existing paperwork, such as delivery invoices and checklists to record, for example, product temperatures."
Integrity of records
The following practices help ensure hard copy and electronic records are complete, useful and accurate:
- the recorded information is legible, permanent and accurately reflects the actual event, condition or activity
- each entry on a record is made by the responsible person at the time that the specific event occurred
- the completed records are signed and dated by the responsible person
- for numerical recordings, the unit of measure is indicated
In order to ensure the integrity and authenticity of electronically-generated monitoring data, an electronic recording and data storage system should:
- be validated to ensure its accuracy, reliability and consistency
- detect invalid or altered records
- generate copies of records in a readable format
- protect records for accurate and timely retrieval throughout their retention period
- This may include systems to maintain appropriate backup records
Note: A backup record could be a copy of the electronic record kept in another location
- This may include systems to maintain appropriate backup records
- create an audit trail by independently recording the date and time of operator entries and actions that create, modify, or delete electronic records
- record changes should not obscure previously recorded information
- limit system access to authorized and trained individuals
- have a frequency of recording data at a rate that ensures any process deviations will be captured
- if the memory storage fails or is removed or reaches its maximum storage capacity, the electronic recorder should automatically recognize this event, log it, and trigger the necessary actions to preclude unsafe/unmonitored operations
- have up-to-date technical documentation for the operation and maintenance of the recording system
- be power protected to minimize the risk of data loss in the case of a power outage
- transfer data to another system (if applicable) without modifying the information
An electronic signature is a secure electronic means of indicating the specific person who created the record. It may consist of a combination of letters, characters, numbers or other symbols that are unique to the person making the signature.
Good practices for electronic signatures include the following:
- the electronic signature contains a unique identifier for the signer and is not re-used or re-assigned
- the process used to make the signature is under the sole control of the person making the signature
- an electronic signature is clearly linked with the electronic record
- controls are in place to ensure that electronic signatures and their links to records cannot be removed, copied or otherwise manipulated
- the identity of persons authorized to use electronic signatures is documented
Record keeping procedures
Record keeping procedures are considered a best practice to help you manage your records.
Record keeping procedures:
- identify the current record version to be used and its location
- provide instructions on how to fill out the record (who, what, how, when)
- identify where completed records are kept
- specify how long records must be kept
- include measures to protect the integrity and authenticity of records during the retention period
Record keeping procedures can be standalone, or you can incorporate them into other procedures, such as in a monitoring procedure.
Tell me more! Further reading
The following references contain information that helps explain food safety controls, demonstrates how to develop them, and provides examples. The CFIA is not responsible for the content of documents that are created by other government agencies or international sources.
- Preventive control plan templates – For domestic food businesses and exporters
- Preventive control plan (PCP) templates – for importers
- Codex Alimentarius Commission, General Principles of Food Hygiene, CXC 1-1969, 2020
- Institute for Thermal Processing Specialists, Guidelines for validating electronic chart recorders, 2018
- U.S. Food and Drug Administration, Grade "A" Pasteurized Milk Ordinance 2017, Appendix H, Part V – Criteria for the evaluation of electronic data collection, storage and reporting
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