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DOCUMENTATION · INSPECTION AND AUDIT READINESS
Key facts
- Governing regulation R638 of 2018, Gazette 41730, 22 June 2018
- Records named in law Certificate of Acceptability, reg 3(1); training records, reg 10(1)(d)
- Retention period in R638 none prescribed, you set it in a procedure
- Record format in R638 not prescribed, paper and digital both acceptable
- Health exclusion records driven by regulation 11(2)(b)
- Penalty basis section 18(1), Act 54 of 1972, a fine or imprisonment
- Scheme add-ons FSSC 22000 Version 7, BRCGS Issue 9, GLOBALG.A.P. IFA v6
- Document templates ASC Basic Food Safety Document Templates Toolkit, R699
If your name is on the Certificate of Acceptability, the records are your responsibility
Regulation 10(1) puts the duty on the person in charge, not on the food handlers. This course explains what you are signing for and what an inspector will ask you to produce.
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Which records does South African law actually require, and which does the auditor require?
R638 of 2018 names only two records outright: a valid Certificate of Acceptability under regulation 3(1), and training programmes and records under regulation 10(1)(d). Everything else is evidence that you meet an outcome duty in R638, or a requirement of a scheme you chose to join.
R638 is written as outcomes. Regulation 8 says food must be stored at temperatures that keep it safe, not that you fill in a fridge sheet twice a day. But when a practitioner asks how you know your cold room held 4 degrees Celsius last Tuesday, the sheet is your only answer.
a person may not handle food or permit food to be handled … on food premises in respect of which a valid certificate of acceptability, has not been issued or is not in force.Regulation 3(1), R638 of 2018, Government Gazette 41730
Auditors work the other way round. A scheme starts from documented information, so a missing record is a non-conformance in itself even when the food is safe. Most manufacturers run both sets at once, a legal minimum for the municipality and a larger one for the customer. The guide to the Certificate of Acceptability covers the licence.
Which food safety records must a food business keep?
The register below is the one I use when I set up a documentation system for a South African client. It lists what each record must show and who fills it in, how often, what drives it, and what an inspector or auditor looks at.
| Record | What it must show, and who completes it | How often | What drives it | What an inspector or auditor checks |
|---|---|---|---|---|
| Certificate of Acceptability | Valid CoA in the name of the current person in charge, for these premises. Local authority issues it, the person in charge files and displays it | Once, updated on change of person in charge | R638 reg 3(1), 3(7), 3(8), 3(9)(a) | That it is displayed conspicuously, matches the trading name and address, and names the person actually in charge today |
| Training programme and training records | Who was trained, in what, by whom, when, and the assessment outcome. Kept by the person in charge or HR | On induction, on role change, on a defined refresher cycle | R638 reg 10(1)(a) to (d) | That every name on the shift roster appears in the file, and that the file did not stop at induction |
| Training impact assessment | Evidence that training changed practice, not just that it happened. Completed by the supervisor or person in charge | After each training intervention | R638 reg 10(1)(c) | Observation records, knowledge checks, or supervision notes that link back to a named course |
| Food handler health declaration | Declaration of the conditions listed in regulation 11(2)(b), signed and dated by each food handler and countersigned by the person in charge | On engagement and on a defined review cycle | R638 reg 11(2)(b) | That handlers know what they must report, and that the declaration is not five years old |
| Return to work fitness records | Medical practitioner certificate of fitness before resuming food handling, held on the employee file by the person in charge | Every exclusion event | R638 reg 11(2)(b) | That an actual exclusion was recorded and closed out with a certificate, not just a verbal all clear |
| Fridge, freezer and cold room temperatures | Unit identity, reading, time, initials, action taken when out of limit. Completed by a named food handler or supervisor | A frequency you set and justify, commonly start and end of trading, more where risk requires | R638 reg 8, HACCP plan, scheme clauses | Variation in the readings, blank corrective action columns, and whether the sheet matches the data logger |
| Cooking, cooling, reheating and hot holding | Product, probe reading, time, the critical limit, pass or fail, action. Completed by the cook or line operator | Every batch at every CCP | HACCP plan, Codex CXC 1-1969 principle 4 | Whether the recorded limit matches the validated limit in the HACCP plan |
| Thermometer and scale calibration | Instrument ID, method, reference used, result, adjustment, next due date. Completed by quality assurance or a trained supervisor | Defined interval, plus after any drop or failure | HACCP verification, scheme clauses | That the probe used on the CCP sheet appears in the calibration register |
| Cleaning schedule | Every item, area and machine, the method, the chemical, the dilution, the frequency, the responsible role. Issued by the person in charge or quality assurance as a controlled document | Reviewed at least annually and after any layout change | R638 regs 5 to 7, prerequisite programmes | Whether the schedule covers what you actually have on site, including drains, overheads and the outside |
| Cleaning completion record | Task, date, time, who cleaned, who verified. Cleaner completes it, supervisor verifies it | Per the frequency in the schedule | Prerequisite programmes, scheme clauses | The verification signature, which is the column that is usually empty |
| Cleaning validation results | Swab, ATP or visual inspection results against a defined pass level, from quality assurance or an external laboratory | Defined interval, and after any method change | HACCP verification, scheme clauses | Whether a failed swab produced a documented change to the method, not just a re-clean |
| Chemical register and safety data sheets | Every chemical on site, use, dilution, food contact approval, current SDS. Kept by quality assurance or the storeman | Updated on every new chemical | R638 reg 6 and 7, prerequisite programmes | A chemical in the store cupboard that is not on the register |
| Pest control service reports | Date, technician, points serviced, activity found, recommendations. Contractor issues them, the person in charge files and signs | Per the service contract | R638 reg 5 and 6, scheme clauses | Open recommendations from three visits ago that nobody closed |
| Pest site plan and trend analysis | Numbered bait and monitor points on a plan, plus activity trended over time. Contractor and person in charge jointly | Plan on setup, trend at least quarterly | Prerequisite programmes, scheme clauses | Whether anyone has looked at the trend, or only at the last report |
| Approved supplier list | Supplier, product, approval basis, approval date, review date. Kept by quality assurance or procurement | Reviewed at least annually | HACCP, scheme supplier clauses | An invoice from a supplier who is not on the list |
| Supplier documents and certificates of analysis | Specification, CoA per batch or per agreed frequency, certification certificates and their expiry. Filed by quality assurance | Per delivery or per agreed frequency | HACCP, scheme supplier clauses | Whether the CoA batch number matches a batch you actually received |
| Goods received record | Date, supplier, product, batch or lot code, quantity, temperature on arrival, vehicle condition, accept or reject. Signed by the receiving clerk or storeman | Every delivery | R638 reg 8 and 13, HACCP | The batch code column, because that is where traceability starts or dies |
| Traceability records | Which incoming batch went into which outgoing batch, and to whom it was dispatched. Recorded by production and dispatch | Every production run and every dispatch | R146 of 2010 reg 11 batch identification, scheme traceability clauses | A live test: pick a code off the shelf and ask for the full chain |
| Mock recall and traceability test | Scenario, start time, finish time, quantity accounted for, gaps, actions. Compiled by the recall team leader | At least annually and after major change | Scheme recall clauses, own procedure | Elapsed time and the percentage reconciled, not whether the test was passed |
| Corrective action register | What failed, when, who found it, immediate action, cause, systemic action, verification, closed by. Owned by quality assurance or the person in charge | Every deviation | Codex CXC 1-1969 principle 5, scheme clauses | Whether root cause is stated, or whether every entry says re-trained the staff |
| Customer complaint register | Complaint, date, product and batch, investigation, response, trend. Kept by quality assurance or the owner | Every complaint | Scheme clauses, own procedure | Repeat complaints on the same defect with no systemic action |
| Water potability results | Sample point, date, laboratory, parameters, result against a defined standard. Issued by an external laboratory, filed by quality assurance | Defined interval, more often on borehole or tanked water | R638 reg 5, prerequisite programmes | Whether every sample point on the site plan has been sampled in rotation |
| Maintenance, glass and hard plastic register | Item, location, condition check, breakage incidents, product disposition. Recorded by maintenance and production | Defined interval, plus every breakage | Prerequisite programmes, scheme clauses | A breakage entry with no record of what happened to the product around it |
| Waste and refuse removal | Removal date, volume, contractor, waste type. Recorded by the storeman or the contractor | Every removal | R638 reg 10(4) to (6) | That refuse is actually leaving site at the frequency the procedure claims |
| Internal audit and management review | Audit plan, checklists, findings, corrective actions, review minutes, decisions. From a trained internal auditor and management | Per an annual programme | Scheme clauses, own system | Whether internal audits find anything, or always report full compliance |
| Visitor and contractor records | Name, company, date, induction acknowledged, health declaration where applicable. Taken at reception or by the person in charge | Every visit | R638 reg 9 and 11, prerequisite programmes | Whether contractors doing work over open product were inducted |
Do not write twenty-six templates from scratch
The Basic Food Safety Document Templates Toolkit gives you the forms behind most rows in that register, ready to brand and use.
Basic Food Safety Document Templates Toolkit, R699
Implementation of Good Manufacturing Practices, R1,950
The toolkit is sold at ascfoodsafety.com, the consulting side of ASC, and not on the training site. No VAT is charged, so R699 is the price you pay.
Which records does an environmental health practitioner ask for on a routine inspection?
On a routine visit to a retail, catering or small manufacturing site, the practitioner works through a short and predictable list: the Certificate of Acceptability, training records, temperature records, the cleaning schedule and its completion sheets, pest control reports, and evidence of how food handler health is managed.
Section 11 of Act 54 of 1972 lets an inspector enter, examine, demand information and copy documents, so assume the file will be read later by someone who was not there to explain it.
The fastest way to fail a routine inspection is to know where nothing is. On a site I audited, a hotel kitchen that was clean and well run, the manager spent close to an hour hunting for the pest file while the practitioner waited, and the visit turned from a check into an interrogation. Keep one folder with a contents page.
training programmes and records are kept and routinely updated, as applicable, and are made available to an inspector on request.Regulation 10(1)(d), R638 of 2018, Government Gazette 41730, 22 June 2018
What regulations 10(1)(d) and 11(2)(b) require for training and health records
Regulation 10(1)(d) requires training programmes and records to be kept, routinely updated as applicable, and made available to an inspector on request. Regulation 11(2)(b) drives a health declaration, an exclusion log and a medical practitioner’s certificate of fitness before a handler returns. Neither names a course, a provider or an interval.
Regulation 10(1) works as a set: (a) the person in charge is trained, accredited or by an inspector where applicable; (b) everyone else on the premises is trained by an inspector or another suitable person; (c) assessments determine the impact; (d) the records prove all three.
Routinely updated carries no interval, so you set one and state it: new starters in the matrix within a defined number of days, a written refresher cycle, and a dated impact assessment after each intervention. Per person, keep name, employee number, role, date, course, provider, result and certificate. The food handler training guide covers the programme.
Health records are thinner on most sites than training records. The version I see most often is a drawer of blank declaration forms, no exclusion log, and a manager who tells me people just say if they are sick. That shows nothing about whether the handler who had jaundice in March was cleared first.
A training file only proves competence if the training was real
If your file is thin because the training never happened, fix the training first. Food handlers take the six hour course, the person in charge the eight hour course.
Basic Food Safety Practices for Food Handlers, R899
Basic Food Safety Bundle, R2,360, saves R658
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Temperature, cleaning and pest control records that hold up
A defensible daily record identifies the unit or task, states the reading, carries the time and date, names the person who did it, states the limit it was judged against, and shows what was done when it failed. A sheet with no limit and no action column is a list of numbers.
Start with the limits. If the fridge sheet says 0 to 5 degrees Celsius, that number comes from the product specification, a shelf life study, your hazard analysis, or the supplier’s storage instruction under regulation 9(e) of R146 of 2010. An auditor who asks where 5 degrees came from and gets a shrug has found a validation gap.
Make the record contemporaneous, written where the check happens rather than in the office on Friday, and record the probe or logger identity so the reading links to the calibration register.
Cleaning generates three separate records, and most sites keep only one. The schedule is a controlled document listing every area, surface and machine with method, chemical, dilution and contact time. The completion record shows the task was done and verified by a supervisor who physically looked. Validation asks whether the method removes soil, and what matters there is what you changed when a site failed twice. Drains, the undersides of tables, extraction hoods and the yard are what schedules leave out, and regulations 5 to 7 of R638 make that a finding. Cleaning belongs to the wider set of prerequisite programmes and GMP.
A pest file needs the contract and its scope, a plan with numbered bait and monitoring points, every signed service report, activity trended by point and by month, and your written response to each recommendation. That last part is almost always missing. Recommendations are open non-conformances you own, and filing the report without acting turns the contractor’s finding into evidence against you. Activity is a deviation: record what was found, the disposition of product nearby, how the pest got in, and verification at the next service.
Correction and corrective action are not the same thing. Throwing away the out of temperature product is correction. Finding out why the cold room drifted, and fixing that, is corrective action. A register in which every entry reads discarded product and retrained staff tells an auditor nothing has been investigated. The root cause analysis guide works through it.
Supplier, goods received and traceability records, and the mock recall that tests them
Supplier records have to show that the raw material you accepted was safe and was what it claimed to be. The evidence sits in an approved supplier list carrying the basis and date of approval, a goods received record capturing the incoming batch code, and the supplier’s specifications and certificates of analysis.
Approval basis is the field most lists leave blank. Write down why each supplier is approved: a certificate to a GFSI recognised scheme with its expiry date, a questionnaire with a review date, a second party audit report, or a history of conforming deliveries for a low risk item. Then diarise the review. Check certificates of analysis rather than filing them: the batch number must match a batch you received, and the results must sit inside your specification. That skill is the core of Internal and Supplier Auditing Practices, R3,500.
Traceability begins at goods received, because if the incoming batch code is not captured there no downstream system can recover it. Regulation 13 of R638 covers the transport of food, and the condition of the delivery vehicle is a legitimate thing to reject on. One up, one down is not enough for a recall, because it does not link an incoming batch to an outgoing one.
On a site I audited, the paper system passed every desk check and then collapsed on a live batch code. Receiving had captured supplier and product but not lot codes. Rework from the previous shift had gone into the run with no entry. Dispatch showed the customer, not the batch. Four hours in, the team could account for half the run.
A mock recall you can run this week
- Pick a finished product batch code at random from stock or a recent delivery note. Note the start time and tell nobody in advance.
- Trace backwards: every raw material and packaging batch in it, including rework, and the supplier of each.
- Trace forwards: every customer, delivery date and quantity, and how much is still on site or in transit.
- Reconcile. Total produced should equal total dispatched plus stock on hand plus samples plus recorded waste.
- Draft the recall notification you would send, and confirm your customer and authority contact list is current.
- Record elapsed time, percentage reconciled and who is fixing each gap by when, then file the verified corrective actions.
How long to keep records, in what form, and whether digital records are acceptable
R638 of 2018 prescribes no retention period and no format, so there is no national South African number to quote, and paper and digital records are equally acceptable in principle. You set the period yourself in a written procedure and justify it, whatever medium the record sits on.
Set retention on three bases and record which you used for each record type: shelf life plus a margin, so a record still exists while the product could be in the market; the retention clause in whichever scheme you are audited against; and any period your customer imposes.
| Record type | Sensible retention basis | Where the actual period comes from |
|---|---|---|
| Production, CCP and temperature records | Shelf life of the product plus a defined margin | Your documented procedure, plus your scheme’s retention clause and customer contracts |
| Traceability and dispatch records | Shelf life plus a margin, at minimum long enough to run a recall on the oldest product still in market | Your recall procedure and your scheme’s traceability clause |
| Training records | Duration of employment, and normally a period after it ends | R638 reg 10(1)(d) requires them to be kept and available, but sets no period |
| Health declarations and fitness certificates | Duration of employment, stored securely | Your procedure and South African privacy obligations for personal information |
| Pest, cleaning and maintenance records | Long enough to trend, commonly several years | Your procedure and your scheme’s clause |
| Internal audit, management review, recall tests | Across multiple certification cycles so that history is visible | Your scheme’s clause and your own system |
For digital records the test is the qualities of the record, not the software. An inspector may arrive when the network is down, so more than one person on site must be able to open the system, and a spreadsheet on one laptop with no backup is weaker than paper.
Which records certification schemes add on top of the legal minimum
Certification schemes add a second and larger layer of documented information on top of R638. FSSC 22000 Version 7, published in May 2026, is ISO 22000:2018 plus a sector prerequisite programme standard from the ISO 22002 series plus the FSSC additional requirements. BRCGS Issue 9 and GLOBALG.A.P. IFA v6 do the same.
| Layer | What it adds to the file | Who it applies to |
|---|---|---|
| R638 of 2018 | Certificate of Acceptability, training programmes and records, plus the evidence behind hygiene, temperature, health and transport duties | Every food premises in South Africa that is not exempt under regulation 14(7) |
| Codex CXC 1-1969 HACCP | Hazard analysis, CCP determination, validated critical limits, monitoring records, corrective actions, verification and documentation under principle 7 | Anyone operating a HACCP system, by choice or by customer requirement |
| ISO 22000:2018 and ISO 22002 series | Documented information for the management system, prerequisite programme records under the relevant ISO 22002 part, and internal audit and management review records | ISO 22000 certified sites, and the base of FSSC 22000 |
| FSSC 22000 Version 7 | Records for the additional requirement themes, including food fraud and food defence, food safety culture and quality management, supplier and outsourcing management, traceability, sustainability including food loss and waste, and AI governance | FSSC 22000 certified manufacturers |
| BRCGS Food Safety Issue 9 | Records against the standard’s own clause structure, including site standards, product control, process control and personnel | BRCGS certified sites, usually driven by retailer requirements |
| GLOBALG.A.P. IFA v6 and Chain of Custody v6.1 | Farm level production and input records, and segregation and identity preservation records where certified product is handled but not farmed | Primary producers, and handlers, packers, traders and processors of certified product |
GFSI, hosted by The Consumer Goods Forum, benchmarks schemes and does not certify anyone, so there is no GFSI certificate. ISO 22000 alone is not GFSI recognised. The guide to FSSC 22000 Version 7 sets out the transition, and the Version 7 document templates toolkit gives you a document set.
Records are the output of a system, so learn the system
If your records are thin because the HACCP plan behind them is thin, start there. If nobody has been taught to audit them, start with auditing.
HACCP for Supervisors and HACCP Teams, R2,730
Internal and supplier auditing training
Written and taught by a registered Lead Auditor with Exemplar Global and IRCA who audits these systems for a living.
Seven ways record keeping actually fails in real businesses
None of these failures are about missing forms. Every business I visit has forms. They are failures of honesty, of verification and of habit, and an experienced auditor picks up all of them within the first hour on site.
1. Records completed in one pen at month end
Twenty-eight days of readings in identical handwriting, in the same ink, signed by someone who was on leave for a week of it. This is the most damaging of the seven, because it moves the conversation to falsified documents.
2. Temperatures that never deviate
A fridge sheet that reads 4, 4, 4, 4 for six months describes a machine that does not exist. Real refrigeration drifts during deliveries, defrost cycles and hot afternoons. Perfect data means nobody is reading the thermometer.
3. A corrective action column that is always blank
If nothing ever went wrong, either your process is beyond anything I have audited, or your monitoring detects nothing. A register with zero entries is a monitoring failure. The best files are full of small deviations, honestly recorded and closed out.
4. A pest report filed unread
The contractor writes seal the gap under the receiving door on three consecutive visits, all three reports are in the folder, and the gap is still there. You have a written record that you were told three times and did nothing.
5. A cleaning schedule with no verification
Cleaners sign that they cleaned. Nobody checks. The schedule was written for a layout you changed two years ago and does not cover the new packing line or the drains behind it.
6. A training file that stops at induction
Everyone was trained when they joined. Since then there has been no refresher, no assessment of impact under regulation 10(1)(c), and no entry for the staff who started this year. A static file fails on the wording of 10(1)(d).
7. Traceability that cannot survive a mock recall
The system works on paper and collapses on a real batch code. Incoming batch codes were never captured at receiving. Rework was added without being recorded. Dispatch shows the customer but not the batch. The test that would expose all three has never been scheduled.
Basic Food Safety Practices for Food Handlers, R899 · Food Safety Practices for Persons in Charge, R1,699 · Implementation of Good Manufacturing Practices, R1,950 · HACCP for Supervisors and HACCP Teams, R2,730 · Internal and Supplier Auditing Practices, R3,500
Related guides: GMP training in South Africa and the complete HACCP training guide. Browse all ASC courses.
Fix the file before someone else opens it
Get the templates from the consulting site so you stop inventing forms, and train the person who has to defend them.
Food Safety Practices for Persons in Charge, R1,699
Basic Food Safety Document Templates Toolkit, R699, at ascfoodsafety.com
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Frequently asked questions
Which food safety records does South African law require?
R638 of 2018 names two directly. Regulation 3(1) requires a valid Certificate of Acceptability for the premises, and regulation 10(1)(d) requires training programmes and records to be kept, routinely updated and made available to an inspector on request. Temperature, cleaning, pest control and traceability records are not listed by name, but they are the evidence that the rest of R638 is being met.
How long must I keep food safety records in South Africa?
R638 of 2018 does not prescribe a retention period, so there is no national number to quote. Set the period yourself in a written procedure and justify it. The usual basis is product shelf life plus a margin, the retention clause in whichever certification scheme you are audited against, and any customer contract. Records tied to training and to health exclusions are normally kept for the duration of employment.
Are digital or app based food safety records acceptable to an inspector?
R638 does not prescribe a format, so paper and digital records are equally acceptable in principle. What matters is whether the record is attributable to a named person, legible, contemporaneous, an original or a controlled true copy, accurate, and protected from unauthorised change. Make sure you can produce a readable copy on the spot when an environmental health practitioner asks, without depending on a signal or a password nobody present knows.
What does regulation 10(1)(d) mean by routinely updated?
The regulation sets no interval, so you set one and record it. In practice, routinely updated means new starters appear in the file within a defined period of starting, refresher training happens on a stated cycle, the training matrix reflects current job roles rather than last year’s, and regulation 10(1)(c) assessments of training impact are recorded. A file that stops at induction does not meet the wording.
What happens if an inspector finds no records at all?
Missing records are treated as non-compliance with the regulations they support, and regulation 10(1)(d) is breached directly if training records cannot be produced. An inspector may serve a notice, and a prohibition order under regulation 4(2) can suspend the Certificate of Acceptability. Offences under regulation 15 are punishable under section 18(1) of Act 54 of 1972 by a fine or imprisonment not exceeding six months on first conviction.
Can I complete a week of temperature records at the end of the week?
No. A record written after the event is not evidence that anything was checked, and auditors spot it immediately from uniform handwriting, one pen, and readings that never vary. If a check was missed, write missed and record what you did about the food. A gap with an honest corrective action is worth more than a full sheet nobody believes.
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