Document Control & Record-Keeping

Aligned with FSSC 22000 – ISO 22000:2018 Clauses 7.5 & 7.5.3

Also relevant: ISO/TS 22002-1:2009 Clause 2.5 – Documentation and Records

Requirement Overview

FSSC 22000 requires that all documents forming part of the Food Safety Management System (FSMS) be controlled, reviewed regularly, and readily available at point-of-use. Records must be legible, authentic, retrievable, and maintained to demonstrate system performance and compliance.

Key Standard References:

• ISO 22000:2018 Clause 7.5 – Documented information

•Clause 7.5.3 – Control of documented information

• ISO/TS 22002-1:2009 Clause 2.5 – Record-keeping and document control

Document control ensures that only the most current and approved procedures are in use. Strong record-keeping provides proof of implementation, traceability, and continuous improvement.

Step-by-Step Compliance Implementation

1. Establish Document Control Procedures

  • Include Controls For:

    • Approval by designated authorities

      Unique document identification (name, code, version)

      Version and revision history tracking

      Regular review intervals

    Evidence to Maintain:

    • Documented SOP for document control

      Master list of controlled documents

      Document approval forms and revision logs

2. Manage Access and Distribution

  • Control Measures:

    • Define access levels (e.g., read-only vs editable)

      Ensure availability of current versions at point-of-use

      Label and archive obsolete versions as “Superseded”

    Evidence to Maintain:

    • Access control logs (digital or physical)

      Training records showing staff know where to find documents

      Archived obsolete versions with version control records

3. Implement Effective Record-Keeping

  • Requirements for Records:

    • Timely and complete

      Legible, traceable, and secure

      Authenticated by date and signature or digital equivalent

    Evidence to Maintain:

    • Record retention policy and retention schedule

      Completed logs, forms, inspection sheets, etc.

      Secure storage system (physical or electronic)

4. Review and Verify Regularly

  • Verification Activities:

    • Internal audits on document and record control

      Spot checks of records for legibility and completeness

      Review of documents following system or process changes

    Evidence to Maintain:

    • Internal audit checklists and reports

      Review logs and change control forms

      Updated documents following non-conformities or feedback

Common Audit Findings & Recommended Fixes

Audit Finding Recommended Action
Obsolete or uncontrolled documents Enforce document approval and version control before distribution
Incomplete or altered records Train staff and implement standardized, validated forms
Illegible or missing signatures Mandate clear handwriting or digital authentication
No formal record retention policy Develop and implement an FSMS-aligned retention and disposal procedure

Auditor Verification Checklist

During an FSSC 22000 audit, be prepared to provide:

  • Your document control and record-keeping procedure

    A master register of current documents with version control

    Sample records demonstrating legibility, completeness, and authentication

    Archived records retained according to your documented retention schedule

    Records of document reviews, updates, and change approvals

Implementation Roadmap

Build the System

  • Draft and approve a Document Control & Record Retention SOP

    Create a master document list and assign roles for control

Train and Roll Out

  • Train all teams on document and record expectations

    Ensure old versions are removed or clearly marked

Monitor and Audit

  • Include documentation in internal audit plans

    Randomly inspect records for completeness and compliance

Improve Continuously

  • Update forms and procedures based on findings or system changes

    Review document control effectiveness annually

Why This Matters?

  • Ensures that only accurate, approved procedures are followed

    Enables effective traceability and issue investigation

    Demonstrates a structured and compliant FSMS to auditors

    Protects data integrity and reduces audit non-conformities

Support Tools Available

Food Safety Systems provides:

  • Document control and record retention SOP templates

    Master tracking tools for documents and forms

    Internal audit checklists for document verification

    Staff training materials on documentation and record expectations