Good Importing Practices for Food
7.0 Records

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7.1 General Records

7.1.1 General Record Requirements

Information is recorded and an accurate history of the product is maintained. Records are retained for the required period of time.

Assessment Criteria

  • Records kept by the importer are legible, permanent and accurately reflect actual events, conditions or activities.
  • Errors or changes are identified so that the original record remains clear (e.g., strike out with a single stroke and initial the correction/change).
  • 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.
  • Critical records are signed by a qualified individual designated by management prior to distribution of the product. All other records are reviewed at an appropriate frequency to provide an early indication of potentially serious deficiencies.
  • Records are retained for at least one year after the expiry date on the label or container, or if there is no expiry date, for at least two years after the date of sale.
  • Records are maintained and are available upon request.
  • Importers are expected to have access to the foreign manufacturer's records, upon request, concerning critical control points in the manufacturing process.

7.2 Receiving Of Imported Product Records

7.2.1 Incoming Imported Product Control Records

The importer's records demonstrate the adequacy of incoming product control.

Rationale

Records are necessary to verify the importer's control over biological, physical or chemical hazards, representation, composition and quality.

Assessment Criteria

  • The minimum record requirements for the four monitoring and/or certification options (Periodic Evaluations, 100% Lot Inspection, Vendor Certification, and Non-Conforming Imported Product) are outlined below.

Periodic Evaluations

  • The importer has records to:
    • document the history of adherence to specifications (i.e., analytical results);
    • state the results of spot checks (i.e., analytical results).

100% Lot Inspection

  • The importer has analytical results for each incoming lot.

Vendor Certification

  • The importer has records which:
    • demonstrate knowledge of the supplier's process (e.g., process flow charts, critical control point identification, process specifications, critical limits, monitoring and verification reports, corrective action plans and reports, and on-site evaluation reports);
    • demonstrate the capability of supplier's process (e.g., capability studies), with statistical process control charts available upon request;
    • provide an historical data base (e.g., analytical results on consecutive lots);
    • record results of periodic monitoring (e.g., analytical results);
    • state the results of supplier audits (e.g., audit reports).

Non-Conforming Imported Product

  • The importer keeps records which:
    • identify the imported product;
    • identify the deficiency;
  • specify the preventative and corrective action taken.

7.2.2 Net Quantity Records

Records are available to demonstrate the adequacy of procedures and methods used in net quantity determination.

Rationale

Records are required to verify that the net quantity declarations are accurate.

Assessment Criteria

  • Records are available to verify that reliable procedures have been followed in determining the net quantity of pre-packaged products.
  • Records are available to demonstrate that the net quantity protocol is being followed.

7.2.3 Deviations and Corrective Action Records

Records are available to demonstrate the control of deviations and the effectiveness of corrective actions taken.

Rationale

Records are required to verify that the importer has control of deviations and that corrective action has been effective.

Assessment Criteria

  • The importer supplies records of deviations and corrective actions which contain the information specified below.

Deviation/Hold

  • Records contain the product/code, the date the product was held/released, the reason for the hold, the amount of product held (e.g., back to the point where the process was last in control), the results of the evaluation/sort (e.g., the amount analysed and an analysis report of the number and nature of defects).
  • The records further contain information about the disposition of the held product (e.g., the amount sorted, amounts destroyed, amounts reconditioned, amounts disposed of through employee sales, distress or salvage, and retail sales).
  • Records include the signature of personnel responsible for the hold and evaluation, and the signed authorization for disposition.

Corrective Action

  • Records identify the cause of deviation, the corrective action taken to correct the deficiency, and a follow-up/assessment to gauge the effectiveness of the corrective action.
  • Records include the date the corrective action was taken and verified and the signature of person responsible.
  • Records further include the preventative action plan that was developed as a result of the product deviation.

7.2.4 Verification Records

Records are available to demonstrate the adequacy of verification procedures.

Rationale

Records show the results of verification and confirm the effectiveness of control measures.

Assessment Criteria

  • Records of verification include the methods utilized, the date, the individuals/organizations responsible, the results/findings and the action taken.

7.3 Equipment

7.3.1 Equipment and Instrumentation Maintenance and Calibration Records

Records are available to demonstrate adherence to the maintenance program for critical equipment.

Rationale

Records permit verification of the effectiveness of the equipment maintenance and calibration program.

Assessment Criteria

  • In Maintenance Records for critical equipment, the importer typically includes an identification of the equipment, the maintenance activity, the date of maintenance, the person responsible, and the reason for the activity.
  • In Calibration Records for critical equipment, the importer typically includes an identification of equipment, the date of calibration, the person responsible, the calibration results, the reference standard and the materials used.

7.4 Premises

7.4.1 Water/Ice Quality Records

Written records that adequately reflect control of water quality and treatment are available upon request.

Assessment Criteria

  • The importer has records available to demonstrate the adequacy of the microbiological and/or chemical safety of the water supply, including Water Potability Records and Water Treatment Records.
  • Water Potability Records include identification of the water source and the sample site, the date the sample was taken, the analytical results, the name of the analyst and his/her certification/accreditation.
  • Water Treatment Records include identification of the method of treatment, the date of the treatment, the sample site, the analytical results, the name of the analyst and his/her certification/accreditation.

7.5 Sanitation and Pest Control

7.5.1 Sanitation Records

Records are available to demonstrate the effectiveness of the sanitation program.

Assessment Criteria

  • The records of sanitation activities include the date, the person responsible, the findings, the corrective action taken, and the microbiological test results where appropriate.

7.5.2 Pest Control Records

Records are available to demonstrate the effectiveness of the pest control program.

Assessment Criteria

  • Minimum pest control records include:
    • the results of the inspection programs and the corrective action taken (e.g., the findings in traps, the location of insect infestations);
    • a record of pest control activities (e.g., the pesticide used, the method and location of application, the dates of fumigation, etc.), including the date;
    • the person responsible and their qualifications.

7.6 Complaint Handling and Recalls

7.6.1 Complaint Records

Records of product complaints, investigation findings and action taken are available upon request.

Rationale

Records provide verification that the appropriate action was taken within a reasonable time frame.

Assessment Criteria

  • The establishment maintains detailed records of consumer complaints received and the investigation, including corrective action taken.

    Consumer Complaints

    • The importer's records contain, at a minimum:
      • the name, address and telephone number of the complainant, and the date the complaint was received;
      • details of complaint and/or illness;
      • the product's name, code and size;
      • the retail outlet where the product was purchased.

    Investigation

    • The importer's records contain, at a minimum:
      • the name of person responsible for the investigation;
      • the action taken (concerning the product and/or the process) as a result of the investigation;
      • the corrective action taken to prevent a recurrence;
      • a follow-up/assessment of the effectiveness of the corrective action

7.6.2 Distribution Records

Product distribution records are available to enable the importer to recall any lot of food in a timely fashion.

Assessment Criteria

  • Distribution records contain sufficient information to permit a product to be traced to a particular code or lot number. The importer has, at a minimum, distribution records containing:
    • the product identification (e.g., the product's common name, its code marks or lot numbers, the manufacturing establishment where it was produced, its date of production, its date of importation, its size).
  • Records further specify the purpose of the recall and the amount of recalled product(s), broken down as follows:
    • the total quantity of the recalled food originally in the importer's possession;
    • the total quantity distributed at the time of the recall;
    • the total quantity remaining in the company's possession.
  • Records further include the areas where the recalled food was distributed by regions, cities and provinces:
    • including retailers' and wholesalers' names and addresses;
    • including customer names, addresses and phone numbers to the initial level of product distribution.
  • Records also provide information on any other product which could be affected by the same hazard.
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