Record keeping in label and package printing

Continuing our series on navigating ink-related food safety standards

We’ve started a blog series that focuses on meeting the requirements of the Global Food Safety Initiative (GFSI). In our first post, we introduced the three main food safety management schemes for packaging printers and summarized eleven food safety standards related to ink.

Over eleven blogs, we explore these standards and their specific ink-related requirements in more detail. We’ll also explain how our ink management solutions can assist you in meeting these requirements.

After our blog about hazard analysis and risk management, we will explore the second standard, record keeping.

It can’t be stressed enough how fundamental record-keeping is to the functioning of your business. What is not recorded didn’t happen: as far as auditors are concerned, following the procedures isn’t enough. It’s proof of following procedures that matters. How will your colleagues know what procedures to follow if they are not ‘set in stone’? And with risks from fires to cyber attacks, if you are not backing up your data, you’re potentially gambling with your ability to operate as a business.
In this blog, you will learn about the standards that matter, what action you must take, and the software tools to use, in order to stay fully compliant.

We will include relevant hyperlinks to web pages and recommend additional reading on our InkConnection blog site, where applicable.

Requirements concerning record-keeping in the three food safety management schemes

The criteria regarding keeping records can be found in:

  • Section 3.3 of the BRC Global Standard (BRCGS) for Packaging Materials
  • Sections 1.7 and 1.12 of FSSC 22000 (Food Safety System Certification)
  • Section 2.3 and 2.4 of Safe Quality Food (SQF).

One notable aspect is the variation among the three schemes in describing record-keeping requirements. SQF goes into greatest detail, while FSSC’s guidelines are more generalized. However, FSSC does refer to general record-keeping requirements set by the food safety system (1.7) and HACCP (1.12), which are quite comprehensive. BRCGS has a dedicated section on record-keeping (3.3), whereas in other schemes, these requirements are described in multiple sections.

Overall, the requirements for record-keeping can be summarized as follows:

Establishment of a record retention system

It is crucial for companies to establish a structured and comprehensive system for maintaining food-safety records. This includes ensuring that all records are readily accessible to authorized personnel and available for review by regulatory authorities and customers upon request.

Measures must be implemented to protect records from damage, loss, or unauthorized access. Documentation should include dates, times, responsible personnel, and outcomes of each activity.

The site must also document the retention period for records related to the usable life of the packaging and its contents, both of which must comply with customer requirements. Any alterations made to records must be authorized, and the reasons for changes must be documented.

Qualifying ink suppliers and ink ingredients

Records of product design, specifications, process flows, shelf-life trials, and approvals for all new and existing products must be maintained.

Inks impact the safety of finished food products. Therefore, ink ingredients must be supplied by approved suppliers and meet agreed specifications.

Verification of the ink ingredients’ conformity to food safety specifications must include a letter of guarantee and a certificate of conformity, certificate of analysis, inspection, sampling, or testing.

Specifications for ink ingredients must be reviewed as changes occur that could affect product safety, and records of reviews and specifications must be maintained.

Package specifications

Finished product specifications must be documented and may include

  • Physical and chemical characteristics
  • Microbiological characteristics
  • Lists of raw materials, allergens, ingredients and identification codes.

Ink undergoes a more complex process in the print factory compared to other raw materials. Base inks are mixed into spot colors, and leftovers are returned from the press to be remixed for new jobs. Without specialized software, documenting the ingredients of these production batches, and consequently the produced packaging, is nearly impossible.

Samples for trials and tests, non-conforming materials and rework

Raw materials and finished products sampled for trials or inspection must be destroyed to prevent re-entry into production, or sale.

Non-conforming products must be quarantined, identified, handled, and disposed of properly. Records of these actions and disposal of non-conforming materials must be maintained.

Methods for reworking and recouping raw materials, like reworking press return inks, must be documented. Operations must be supervised by qualified personnel, ensuring products are clearly identified and traceable. Detailed records of reworking operations must also be maintained.

GSE’s software solutions for meeting record-keeping requirements

GSE provides a variety of software solutions designed to meet GFSI requirements regarding record-keeping.

Our GSE Ink manager software incorporates essential features aimed at safeguarding records from damage, loss, or unauthorized access. These include:

  • Advanced password protection
  • User management with customizable user groups to control access rights
  • Database backup covering up to ten generations
  • Automatic log-out timer for software users
  • Secondary database backup scheduling.

The standard software automatically logs every logistic event, such as the dispensing of each ingredient, or a batch disposal, along with the date, time, responsible personnel, and results (e.g., requested weight, dispensed weight, and batch codes) for that event. Standard lists that can be retrieved include the dispense history and the event history.

The database accepts customized references for base components (ingredients), such as conformity verification information. Similarly, formulas in the database can be marked as “inactive,” and any revisions to the formulas are tracked with details such as date, time, and personnel involved. With the optional GSE Article management software, revisions of package designs can also be tracked.

In our optional software module for the procurement and receipt of raw materials, you can manage qualified suppliers and ink ingredients.

Additionally, we offer optional software solutions to maintain records related to customer orders, manage ink batch traceability, and streamline the reworking of press return inks.

Further reading on the InkConnection blogsite

If you need guidance on complying with GFSI requirements, please don’t hesitate to reach out. For any other questions related to ink logistics, contact us at