FSMA 204 Record Retention: Test Retrieval, Not Just Backups

Establish applicable retention and response obligations from current FDA requirements. FDA describes making required records available within 24 hours, or another reasonable time it agrees to. That does not prove any export your system produces is sufficient.

Inventory record types, formats, locations, and owners. Include external references and explanations needed to understand identifiers and units. Specify how a replacement operator locates each record.

Preserve original evidence and corrections with distinct physical-event, upload, and correction times. An overwritten value cannot explain what was known when the business acted.

Archive specifications and location details used for historical events. Current catalogs may not describe discontinued foods, closed warehouses, or former suppliers.

Run retrieval with an old lot and an operator who did not create its records. Require readable fields, relevant joins, evidence, and interpretation notes.

Include a broken external link and a missing permission. Recover from an approved copy rather than counting a matching filename as success.

FoodChainAPI suggests candidate Food Traceability List categories from product descriptions. Save the reviewed result beside the product specification; a category match does not establish exemptions, complete operational records, or certify compliance.