The Legal Basis for HACCP Record Keeping
HACCP record keeping is a legal requirement under Regulation (EC) No 852/2004, Article 5, which requires food business operators to establish, implement, and maintain a permanent procedure based on HACCP principles. The regulation specifically states that documentation and records must be commensurate with the nature and size of the food business. The Codex Alimentarius Commission — the international body that established the HACCP framework — identifies documentation and record keeping as the seventh HACCP principle.
In practice, this means every food business must keep records that demonstrate their HACCP system is being followed. EHOs will ask to see these records during inspections, and the quality and completeness of your documentation directly affects your confidence in management score. For a full overview of HACCP principles, see our guide to the 7 principles of HACCP.
Essential Records You Must Keep
HACCP Plan Documentation
Your written HACCP plan must include the hazard analysis, identified CCPs, critical limits, monitoring procedures, corrective actions, and verification procedures. This is the foundation document that everything else builds upon. Our HACCP plan service creates comprehensive, EHO-ready documentation tailored to your operations.
Temperature Monitoring Logs
Daily records of fridge and freezer temperatures (checked at least twice daily), cooking core temperatures, cooling records showing time and temperature, hot holding temperatures, and delivery acceptance temperatures. Each entry should include the date, time, temperature reading, and the name or initials of the person who took the measurement.
Cleaning Records
Documented cleaning schedules showing what was cleaned, when, by whom, and with what products. Include both routine daily cleaning and periodic deep cleaning tasks. Cleaning records demonstrate to EHOs that you have a systematic approach to maintaining hygiene standards.
Corrective Action Records
When a CCP deviation is identified (for example, a fridge found above temperature), you must record what happened, what corrective action was taken, who was responsible, and when the issue was resolved. These records show EHOs that your system does not just identify problems but actively addresses them.
Training Records
Records of all food safety training, including the staff member’s name, course title, level achieved, date completed, certificate number, and next refresh date. Keep copies of certificates alongside a training matrix that shows at a glance which staff hold which qualifications.
Supplier Records
Approved supplier lists with contact details, food safety certifications, and evidence of due diligence checks. Delivery records showing that incoming goods were checked for temperature, condition, and date markings.
Pest Control Records
Reports from your pest control contractor, including visit dates, findings, treatments applied, and recommendations. If you manage pest control internally, keep records of inspections, bait station checks, and any pest sightings.
Record Retention Periods
UK law does not specify exact retention periods for all HACCP records. However, best practice guidelines recommend:
- Temperature logs, cleaning records, and corrective actions: retain for at least 12 months
- Training records: retain for the duration of employment plus at least 12 months
- HACCP plan and reviews: retain indefinitely, keeping previous versions for reference
- Supplier records and pest control reports: retain for at least 2 years
Paper vs Digital Record Keeping
Both paper and digital records are accepted by EHOs. Paper systems are simple and low-cost but can be difficult to organise, prone to damage, and hard to analyse. Digital systems offer advantages including automated reminders, easier data analysis, secure backups, and the ability to demonstrate compliance trends over time. Many businesses are moving to digital solutions, and EHOs increasingly expect to see professional, well-organised record-keeping systems. Our consulting service can advise on the best system for your business.
Common Record-Keeping Mistakes
- Gaps in daily records — missing days or incomplete entries suggest the system is not being followed consistently
- Identical entries every day — fridge temperatures that are exactly the same every single day look fabricated and will raise EHO suspicion
- No corrective actions recorded — if your records show a fridge above temperature but no corrective action, EHOs will question whether the system is effective
- Outdated HACCP plan — a plan that does not reflect your current menu, suppliers, or processes is effectively useless
- Records stored in disorganised piles — if you cannot quickly find the information an EHO requests, it undermines confidence in your management systems
Download our free HACCP template for restaurants to establish a professional record-keeping system from day one.
Frequently Asked Questions
Can I keep HACCP records on my phone?
Yes, digital records kept on a phone or tablet are acceptable, provided they are backed up securely and can be presented to an EHO during an inspection. Several food safety apps are available that make mobile record keeping straightforward. The key is that records must be accessible, legible, and complete.
What happens if I cannot produce records during an inspection?
If you cannot produce records, the EHO will likely score your confidence in management area poorly, which can significantly reduce your food hygiene rating. In serious cases, the absence of records may be considered evidence that you do not have an effective food safety management system, which could lead to enforcement action.
Do I need to keep records if I use Safer Food, Better Business?
Yes. Safer Food, Better Business includes a diary section for recording daily checks, but you must actually complete it. An SFBB pack that is blank or incomplete is worse than not having one at all, as it shows you have the tools but are not using them. EHOs will check that the diary section is completed consistently.
Written by Carren Amoli, BSc (Hons), RSPH Registered
