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Templates and records · ISO 22000 · Clause 8.9.4

ISO 22000 potentially unsafe product record

What is done with the batch produced while a control point was outside its limit: hold it, evaluate it with evidence and decide whether it is released, reprocessed or destroyed.

In one sentence

The potentially unsafe product record identifies the product affected by a failure to meet a critical limit or action criterion, documents its holding, the evaluation that justifies releasing it and the decision on its disposition — reprocessing, other use or destruction — as required by clause 8.9.4 of ISO 22000.

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Where the standard requires it
ISO 22000 · Clause 8.9.4 Clauses are cited using the numbering of ISO 22000:2018, the current edition. ISO is preparing a third edition that may renumber them; when it is published it will have its own transition period.
Type of information
Mandatory record Documented information on evaluation and disposition (8.9.4)
Who fills it in
Whoever has authority to release Usually the food safety team leader or the quality manager, according to the plan
When
As soon as the deviation is detected The product stays on hold until the decision is made
How long it is kept
At least the shelf life of the product It is the only period the standard sets (8.3). For long-life products that period governs; for fresh products it is worth extending it to the certification cycle.

What the standard requires


What ISO 22000 demands and what it leaves to your judgement

The organisation must prevent potentially unsafe product from entering the food chain, unless it can show that the hazards have been reduced to their acceptable level, will be reduced before entering the food chain or that, despite the deviation, the product conforms.

Product leaving a CCP outside its critical limit cannot be released and must be dealt with: reprocessed within or outside the organisation to reduce the hazard, diverted to another use if safety is not compromised, or destroyed. For failed OPRPs, the available evidence is used to evaluate whether it can be released.

The evaluation and the decision are retained, identifying who authorises it. If the product has already left, withdrawal comes into play (8.9.5).

Structure


Fields the template should include

  • Product, batch, quantity and location
  • CCP or OPRP not met and description of the deviation
  • Production period affected
  • Holding and identification measures
  • Evaluation: data, testing or evidence used
  • Decision: release, reprocessing, other use or destruction
  • Who authorises the decision
  • Verification after reprocessing, if any
  • Link to the corrective action and, where applicable, to the withdrawal

Example


Example: soup trolleys outside the cooling criterion

Company, people and figures are fictitious: the example only shows what a properly completed record looks like.

Field Content
Product Pumpkin soup 500 g · batch L26-071 · 2 trolleys, 640 tubs
Deviation OPRP-1: trolleys 5 and 6 exceeded the maximum cooling time by 25 minutes
Holding Trolleys blocked in chiller 2 with a product-on-hold label
Evaluation Microbiological testing of six units by an external laboratory and review of the chiller temperature
Result Conforming to the product specification
Decision Release of both trolleys
Authorised by Food safety team leader · 14 March 2026
Corrective action CA-26-017: review the maximum blast chiller load

At the audit


Mistakes auditors commonly flag

  • Product from a CCP deviation is released after an evaluation instead of being dealt with.
  • The hold does not cover the whole period since the last conforming monitoring.
  • The decision to release does not identify who authorises it or what it is based on.
  • It is confused with the system nonconformity log and the specific batch is lost.

In Kimobox


How this record is kept in Kimobox

  1. 1A deviation recorded at a CCP or OPRP puts the affected batch on hold.
  2. 2The evaluation and test results are attached to the batch, and release requires the signature of whoever has authority.
  3. 3The corrective action, with a mandatory root cause, is opened from the batch on hold.
  4. 4If the batch has already left, traceability returns the customers who received it.

Frequently asked questions


What people ask us before getting started

Can a batch that failed at a CCP be released if the test results are good?

ISO 22000 does not allow it: product leaving a CCP outside its critical limit is not released and must be reprocessed, diverted to another use or destroyed. Evaluation for release on the basis of evidence applies to OPRPs.

When do you move to a withdrawal?

When the potentially unsafe product has already left the company's control. Clause 8.9.5 then applies and, in the European Union, Article 19 of Regulation (EC) 178/2002, which requires it to be withdrawn and the authorities informed.

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Sources


Where each figure comes from

References to the official text in force. If a standard is revised, this page is updated and the review date says so.

  1. ISO 22000:2018 — Food safety management systems. Requirements for any organization in the food chain ISO · 2018 ed., with Amd 1:2024
  2. Regulation (EC) No 178/2002, Articles 18 and 19 (traceability and withdrawal) EUR-Lex · 28 January 2002