Here’s why your records matter and what’s required by R638

Imagine if we could just get on with the business of making macaroons without spoiling the fun by having to complete records? I bet you think that having to keep documents, records and files just sucks the passion out of your creativity. However, when you approach the need for documents and record keeping with a mindset of understanding the importance of food safety, you will learn that other than the fact that it is a legal requirement, you will benefit from a culture of disciplined routine that will bring peace of mind and confidence to your business.  

Getting your documents and records in place right from the start will anchor your business, provide structure, and consistency of product quality and allow your business to grow and expand without the chaos that sometimes undermines small businesses. 

What is Regulation R638? 

Regulation 638 is the regulation governing General Hygiene Requirements for Food Premises, The Transport of Food and Related Matters. Every food business that handles and transports food has to comply with this regulation. 

What are the minimum documents and records that are required by the R638? 

Subregulation 10.2 of R638  requires that there has to be appropriate evidence that a food business complies with the requirements as stipulated in the regulations. This means that the type and extent of documents and records differ from food business to food business depending on the nature, risk and complexity of the business. So for example, the documents and records required for a meat, milk or vegetable processing business would be more than for a business that only stores and distributes packed food products.  

We have identified a list of documents and records that should form part of the basic food safety system for your business: 

• Certificate of Acceptability for the food premises 

• Training curriculum for the Person in Charge training – 10.1(d) 

• Training curriculum for the Food Handlers  – 10.1(d) 

• Training records (Person in Charge training and food handler training)  – 10.1(d) 

• Assessment records (Food Handlers)  – 10.1(c) 

• Illumination – light intensity testing records for compliance against the National Building Regulations and Buildings Standards Act,1977 (Act No 103 of 1977) which  permits a light intensity of at least 200 lux – 5.3.b (i) (bb) 

• Liquid waste and refuse company Certificate of approval by local Health Authority – 5(c)(iv) 

• Cleaning inspection records – 6(4)(a), 10 (8) 

• Cleaning efficacy testing records – 6. (4)(b)(i) 

• Temperature monitoring records – 6(5)(c)  

• Milk heat treatment monitoring records – 6(6) 

• Milk bulk storage time and temperature monitoring records – 6 (7)i),j),k) 

• Butchery cleaning equipment procedures and records – 6(8)& 6(9) Annexure F 

• Canned / hermetically sealed goods inspection forms – 7(1)& 7(2) 

• Food grade certificates for packaging materials – 7(3) 

• Hygiene inspections for Storage and Display of food – 8(1), 8(2). 8(3) 

• Temperature monitoring records for storage, transport and display of food – 8(4)(a)(i) & (ii) 

• Frozen food, frozen fish and seafood temperature monitoring records – 8(5)(a)(b) & (6) 

• Personal Protective Clothing Inspections – 9(1) – 9(3) 

• Pest Control Prevention and Monitoring records – 10(3) 

• Waste removal inspection and refuse bin cleaning inspections – 10(4) – (6) 

• Personal hygiene and jewellery inspection records – 10(9), 10 (10) & 10(12) 

• Sickness or illness reports of food handlers suspected of suffering from or being or disease or condition such as jaundice, diarrhoea, vomiting, fever, sore throat with fever, discharges from the ear, eye or nose – 11.2.b(i), 10.(15) 

• Product labelling verification records – 10(17) 

• Vehicle Hygiene inspections for transport of meat and meat products -12(4) 

• Vehicle hygiene inspections for transport of food products -13(1) – (3) 

• Traceability records including Processing, Production and Distribution records (must be kept for at least 6 months after the shelf-life of the product) – 10(16), 10(18) 

• Recall Procedure and Recall Indecent Report (for reporting any recall incidents to the local inspector and the National Directorate: Food Control) – 10(18) 

The above list is just the start of your food safety system. As you progress from R638 compliance to a Food Safety Management System aligned with the GFSI (Global Food Safety Initiative) requirements there will be more records and documents that you will need to include in your food safety system. 

How can Entecom help you?  

Contact info@entecom.co.za to hear how we can help you with your food safety compliance. With our digital compliance solutions and food safety support services, we are ready to help your business succeed.  

For more information on Food Safety Certification requirements visit our guidance hub.