Food law asks for effective monitoring but does not say where the probes go. BRCGS does: under Storage and Distribution the temperature distribution in a controlled store must be established, validated and verified at a risk-based frequency, and Food Safety asks the same of cold stores and freezers, which in practice means a mapping study. The probes then go where the map shows the extremes.
Why it matters
A probe by the door tells you about the door
A large chill or frozen warehouse is not one temperature. Dock doors, evaporator positions, racking height, defrost cycles and summer sun all make some locations warmer or colder than others. If the monitoring probe sits where the cable reached, the record shows that spot and nothing else, and the warmest pallet in the building may never be measured.
The FSA's Practice Guidance tells officers that air records 'are an indication of temperature history', and that product testing should start 'with items from the warmest part of the unit'. Knowing where that is, and having a probe there, is what mapping is for.
What the rules say
Law and standards on monitoring and mapping
Food law does not require mapping. Regulation 852/2004 asks for 'effective monitoring procedures' at critical control points; Regulation 37/2005 asks for EN 12830 recorders in quick-frozen stores, monitoring air 'at frequent and regular intervals'. Neither says where the sensors go.
BRCGS Storage and Distribution Issue 4 does (paraphrased). Clause 7.3.7 requires the uniformity of temperature in controlled stores to be 'established, validated and verified at a frequency based on risk', or restrictions on where product can be placed; 7.3.8 asks for performance to be re-established after equipment changes; 7.3.2 asks for recording with suitable alarms on all storage facilities, or manual checks typically every 4 hours. BRCGS Food Safety Issue 9 4.15.3 has the same monitoring rule, and its process-control clause 6.1.5 asks for temperature distribution in freezers and cold stores to be validated and verified at a frequency based on risk and performance.
What good looks like
Map, then place the probes where the map says
A mapping study puts calibrated loggers across the store in three dimensions, near doors, evaporators, the top and bottom of racking and the middle of the load, and runs long enough to see the real pattern: defrost cycles, busy loading shifts and a quiet period. The report shows the warmest and coldest locations and whether the whole store holds its limits. The permanent monitoring probes then go at those extremes, or as close as practical, and the rationale is written down.
Alarms need a person on the end. Decide who receives each alarm in and out of hours, how long before it escalates, and test the whole path, not just the sounder. For calibration, BRCGS 6.4 and Storage and Distribution 6.3 ask for a risk-based frequency traceable to a national standard; FSAI Guidance Note 20 gives the clearest published benchmark: working thermometers 'at least annual', reference thermometers at least every three years.
- PlanLogger positions across doors, evaporators, racking and load.
- RunLoaded store, through defrosts, busy and quiet periods.
- ReportWarmest and coldest locations, and whether limits held.
- Place probesPermanent monitoring at the extremes, with the rationale.
- RepeatAfter changes, and on a risk-based cycle.
Our sequence, drawn from BRCGS Storage and Distribution 7.3.7 and 7.3.8 (paraphrased). JTF runs mapping studies as a managed service.
How long to keep the records
Only quick-frozen food has a fixed period in UK law: at least one year, or longer for the shelf life. Ireland fixes HACCP record periods in law for HSE-supervised businesses (S.I. 369/2006); DAFM, SFPA and local-authority sites under S.I. 22/2020 have none. Everywhere else the period comes from your standard and your customers. The table below sets them out; where one store holds products under different rules, keep its records for the longest period that applies.
Worked example
A mapping study that moves a probe
This is an illustrative example; readings are invented. A distributor's 2,000-pallet chill store works to 0 to 5 °C, with one monitoring probe on a column near the office door that has always read about 3 °C.
A summer mapping study with loggers across the store shows the top racking level beside dock door 4 reaching 6.2 °C during the afternoon loading shift, while the existing probe stays at 3.1 °C. The coldest point, low beside the evaporators, reaches −0.4 °C during pull-down.
What the site does: adds probes at the top of the racking by door 4 and low by the evaporators, keeps the original probe as a general reading, and records why each is where it is. It restricts the top level by door 4 to products with a wider tolerance until an air curtain is fitted, then re-maps that zone. What the auditor sees: a map, a rationale and probes that would have caught the problem.
Where it is unclear
No figure for frequency, duration or density
No source we checked sets a mapping frequency for food stores. The nearest is FSAI Guidance Note 20, which asks for heating and chilling chambers to be re-mapped at least every three years or after any change; our three-year default follows it. No food source sets a study length or a number of loggers, and none says how far from the warmest point a monitoring probe may be. Food Safety Issue 9 does not mention mapping at all. Whether monitoring the air or the product is expected is also open: the FSA says the law is about 'the temperature of the food', while 37/2005 requires air recording. See air or food.
Inspection findings
How an officer uses your records
The Practice Guidance sets a staged check: air records first, then between-pack readings with a +2.8 °C total tolerance, then destructive testing for enforcement. If there is no monitoring system or the officer doubts it, they move straight to stage 2. A mapped store with calibrated probes at the extremes is the strongest stage 1 evidence you can offer.
In summary
The short version
- Food law does not require mapping; BRCGS does, at a risk-based frequency (Storage and Distribution 7.3.7, Food Safety 6.1.5).
- Map loaded, through defrosts and busy shifts, and in both seasons where the outside gets in.
- Put permanent probes at the warmest and coldest locations and write down why.
- Alarms need named people, escalation and end-to-end tests.
- Calibrate to a national standard; FSAI's benchmark is at least annually.
- Keep records for the longest period that applies to anything in the store.