Paperwork Precision Prevents Problems
As the company involved in the most recent widely publicised meat incident (Russell Hume) have discovered, having robust paperwork in place is essential for all food businesses.
We currently do not know what the Food Standards Agency considered to be an issue at the site visited earlier in January 2018, but Russell Hume have stated that “The product recall was a precautionary measure because of mislabelling.” (Guardian, 26th January 2018 ) However a customer (Wetherspoons) has cancelled its contract after finding that Russell Hume was “unable to demonstrate compliance with food hygiene rules at its locations”.
There is no indication that anyone was made ill by the failure to demonstrate compliance with food hygiene regulations. If it is a mislabelling issue, it is potentially a food fraud issue. The previous company to be investigated by the FSA was Two Sisters which was potentially committing food fraud by allegedly mislabelling chicken destined for the retail market.
What should be happening?
In order to be able to demonstrate adherence to legal, customer or internal requirements a robust paperwork trail must be in place. The paperwork must be completed in a timely and accurate manner.
If you were asked to record a measurement every hour, on the hour, would you do it exactly on the hour? Most people wouldn’t. They may record the measurement at 9:57 or 10:02, and most would perform the activity at about hourly intervals, but not precisely. In my experience, times that are recorded accurately (at 9:57 or 10:02) rather than at precise intervals are more believable. These lead any auditor to feel that any process is in control and understood. It also leads credibility to the remaining information that has been recorded. I have on many occasions seen paperwork that has had the times of the proposed check completed at the beginning of the day. The information being recorded was completed later in the day. All of the information may in the correct columns or boxes, but which is more believable? The precise, on the hour timed records or the ones which show approximate intervals in an accurate manner?