Food Plant Traceability: HACCP, BRCGS and FSMA 204 Records

Traceability in a food plant means being able to answer, for any lot, where what came in originated, what happened to it inside and who it was shipped to, with records that an outside party can review. HACCP, BRCGS and the US FSMA 204 rule ask for the same thing with different levels of detail: data with date, time and the person responsible, stored so it can be searched quickly.

This guide separates what each standard requires, what can be recorded without human intervention and what is still a person's decision.

What is traceability in a food plant? #

The Codex Alimentarius defines it as the ability to follow the movement of a food through specified stages of production, processing and distribution. In practice it has three legs:

• Backward: which supplier and which raw material lot went into each product.
• Internal: which lines, cold rooms and processes each lot went through, at what temperature and at what time.
• Forward: which customer or destination each shipped lot went to.

The backward and forward legs usually live in the ERP. The internal leg is the one most often recorded by hand, and it is where an audit finds the gaps.

What do HACCP, BRCGS and FSMA 204 require? #

Standard	What it asks for in records	Who it applies to
HACCP (Codex; in Chile, guidance from ACHIPIA, the Chilean food safety agency)	Monitor each critical control point against its critical limit, record corrective actions and verify that the system works.	Every plant that adopts it; it is the basis of almost every certification.
BRCGS Food Safety	Records with date, time and result, reviewed by someone with authority; temperature recording equipment with alarms or recorded manual checks; a traceability exercise that can be completed within a few hours.	Plants selling to retailers that require it, especially in Europe.
FSMA 204 (FDA, US)	Key data elements (lot, quantity, date, location) for each critical tracking event in the chain, deliverable to the FDA in a sortable electronic spreadsheet within 24 hours.	Anyone who produces, processes or ships foods on the Food Traceability List to the US, including foreign suppliers. Enforced from July 20, 2028.

None of the three requires any particular software. All three require the record to exist, be complete and be found quickly. Paper can do the job; the hard part is doing it every shift without gaps.

If the plant is in Mexico, what NOM-251-SSA1-2009 requires, when HACCP is mandatory and what COFEPRIS and SENASICA review is covered in the guide to HACCP in Mexico.

Which records fail most when kept on paper? #

1. Temperature. One reading every two or four hours does not show what happened in between. If the cold room warmed up during a long defrost, paper does not see it.
2. Quantities per lot. How many units or kilos went into and out of each stage. When counting is manual, the gap with the ERP shows up at month-end close, not during the shift. We explain it in why the production count does not match the ERP.
3. Times. What time each lot started and finished, when the line stopped and how long the product was out of refrigeration.

All three have something in common: they are physical measurements that a sensor or a camera can take without anyone writing anything down.

What can be automated and what cannot? #

Can be recorded without intervention	Is still a person's decision
Continuous temperature of cold rooms, tunnels and processes	The hazard analysis and the definition of critical control points
Unit count per lot and per shift	What to do with a lot that went outside the limit
Line start, end and stop times	Product release
Alarms when something goes out of range	Reviewing and signing the records

A system that promises the standard takes care of itself is promising the right-hand column, and that cannot be automated: the quality team answers for it. What does change is that the person decides with complete data instead of with a sheet filled in at the end of the shift.

Paper, spreadsheet or automatic recording? #

	Paper	Excel spreadsheet	Automatic recording
Actual frequency	Whatever the operator manages	Whatever the operator manages	Whatever is configured, regardless of the shift
Gaps	Frequent and hard to spot	Frequent, but visible	Detected automatically: a sensor that stops reporting triggers an alarm
Search for an audit	Hours or days	Minutes, if the file is organized	Minutes, by lot, date or equipment
Who wrote the data	A signature	Anyone with the file	The sensor, with date and time

How to start without changing everything #

1. Pick a single critical control point or a single line, the one that drew the most observations at the last audit.
2. Write down which record exists today, who fills it in and how often.
3. Install automatic measurement in parallel and compare it with paper for two to four weeks.
4. Run a traceability exercise with a real lot: how long it takes to gather everything with paper and how long with the new record.
5. Only then decide whether to extend it to other cold rooms or lines.

What does iGromi do in traceability? #

iGromi measures inside the plant the physical variables that feed internal traceability, on equipment the plant already has:

• Calibrated temperature. At Ditzler, the IQF tunnel temperature is measured and checked against a reference standard, with a 0.05 °C difference. More detail in the guide to cold room temperature monitoring.
• Production counting. At Grupo PROA, 19 security cameras that were already installed count the production of six farms, with 99 % accuracy measured against manual counting, and the data reaches SAP.
• Times and stops for each machine, read from the PLC or from a sensor.

What we do not do: the hazard analysis, certification or the audit. Nor do we currently build the full genealogy of a lot from raw material to shipment; that stays in the plant's ERP.

For the definition of traceability, its three types and what a traceability system should record, see traceability system.

Frequently asked questions #

What is a traceability system?

It is the set of records and tools that lets you follow a product from raw material to the customer. It can be paper, spreadsheets, the ERP or sensors that record on their own; usually it is a mix.

Does the FSMA 204 rule apply to a Chilean plant?

It applies if the plant produces, processes or ships to the United States foods that are on the FDA's Food Traceability List, or products that contain them. The enforcement date is July 20, 2028.

Is an Excel spreadsheet good enough for HACCP?

It is if it is filled in completely, on time, and someone reviews it. The problem is not the format but the frequency and the gaps: a spreadsheet does not warn you when a reading is missing. If you start there, the HACCP temperature log comes with the formulas already in place: status of each reading, corrective action, product disposition, review and calibration.

Does automatic recording replace the quality manager's signature?

No. The system takes the measurement; review, corrective action and product release remain the responsibility of a person, and the audit is going to ask about it.