The most-discussed subject in a cold chain is what the temperature was. An inspection asks something else: how do we know the device that produced that number was measuring correctly. The recorder is the witness.
What the regulation says. Article 18 of Turkey's regulation on special equipment for the carriage of perishable foodstuffs is plain: temperature recorders fitted to ATP-certified equipment and meeting the criteria set out in the agreement must be verified annually. The criteria live in Annex 2, Appendix 1 of ATP.
The work itself does not require an expert from the approval body to be present; authorised staff of the inspection centre may carry out the verification. The data goes into the approval body's system, the report is printed in two copies and signed. One copy goes to the equipment owner, the other stays at the inspection centre for three years.
Why three years matters
A complaint or an audit arrives months after the event. If your own copy has gone missing, a second record showing that verification took place is still sitting at the inspection centre. That is the sort of detail that closes a file quickly.
The record chain is the part of a pharmaceutical cold chain that comes before any choice of equipment.
The food-side counterpart
Turkey's Food Hygiene Regulation requires the cold chain to be both maintained and recorded. Where there is a duty to record, the reliability of the device producing the record becomes part of that duty. A chart from an unverified recorder is weak evidence in an inspection.
The bar is higher on the pharmaceutical side
The good distribution practice guideline of the Turkish Medicines and Medical Devices Agency requires monitoring equipment to be calibrated at least once a year. It also asks for temperature mapping under representative conditions with seasonal differences taken into account. Reading correctly is not enough; where the device sits has to be justified too.
What verification does not cover
| Verified | Not verified |
|---|---|
| That the device reads correctly at given points | That the probe sits at the warmest point of the load |
| The device's own recording interval | Local swings while the door is open |
| That measurement error stays within limits | Product temperature inside the packaging |
A recorder measures air. The gap between core product temperature and air temperature depends on packaging and on how full the space is. A verification report does not close that gap; it only says the measured number can be trusted.
Four lines to check on the report
- Date of verification and the date of the next one
- Device serial number, matched against the plate or serial number of the equipment
- Which temperature points the measurement was taken at
- Name and signature of the centre that performed it
