Compliance Officer Discovers Sourdough Starter's 437 Feedings Lack Regulatory Chain-of-Custody Documentation; Begins Retroactive Notarization

The retroactive compliance initiative began, as most audits do, with a spreadsheet. At 9:17 p.m. on March 11, Constance Weir — eight years as a Regulatory Affairs Manager at a Class II medical device firm in Marlborough, Massachusetts, and current holder of a Certified Compliance & Ethics Professional designation that had not, until that evening, found application outside her professional context — opened a fresh workbook and typed "SUBJECT: Gregor (T. aestivum/rye blend, est. October 2023)" into cell A1. The gap, she explained to her husband across the kitchen island, was structural. Gregor's 437 documented feedings — conducted over seventeen months at hydration ratios ranging from 83% to 91%, with bulk fermentation windows logged between four and six hours at a controlled 76°F — constituted an unbroken series of regulated transfer events. Each 50g addition of King Arthur bread flour and 45g of 70.1°F filtered water was, by any reasonable application of FDA 21 CFR Part 11 electronic records standards, an evidence-generating activity. None of it carried chain-of-custody signatures. None had been notarized. "The entire feeding history," she said, sliding a printed 19-page gap analysis across the island, "is legally a rumor." Her husband asked whether dinner was ready. Gregor's pH at peak activity currently registers 3.8, placing him squarely in the ideal range for acetic acid development and a pronounced open crumb. His oven spring has been consistent to within 4mm across twelve consecutive bakes. The loaves produced under his governance are, by any disinterested assessment, genuinely excellent. The documentation gap does not affect this. The documentation gap is nonetheless catastrophic. Weir spent the following Thursday at a UPS Store in Natick, where a notary public named Dale witnessed the retroactive attestation of Feeding Events 1 through 47 — the earliest period for which her handwritten notes were recoverable. Dale, who had notarized a boat title and a durable power of attorney earlier that afternoon, confirmed the documents were signed and sworn. He asked what the "subject matter" column referencing "T. aestivum starter culture" meant. Weir handed him a one-page explainer she had prepared for exactly this contingency. Feedings 48 through 219 present a complication. The log for that period was maintained in a Notes app on a phone she no longer owns. Weir has formally characterized this as a "system migration event with incomplete data transfer" and is pursuing backup recovery through her carrier. Feedings 220 through 437 are fully documented with timestamps, ambient temperature readings from her Inkbird IBS-TH2 Pro humidity sensor, and a photograph of Gregor at peak rise — though none of these photographs were taken in the presence of a third-party witness, which she acknowledges creates what she is calling a "single-party attestation vulnerability." The corrective action plan, running to eleven pages, proposes a SOC-2-adjacent control framework for all future feedings, a witness rotation schedule involving three neighbors (two of whom have agreed, conditionally), and a formal deviation report covering seventeen feedings during which Gregor was maintained at 77°F rather than the target 76°F due to HVAC variability last February. Weir is also evaluating whether her high-hydration miche levain builds — conducted at a 1:5:5 ratio over eight hours before each Saturday bake — should be classified as separate regulated events or as subordinate activities within the primary chain-of-custody record. Her husband, who ate leftover pasta, asked if this seemed like a lot. "The chain of custody either exists or it doesn't," Weir said. She was addressing Gregor at the time. The Baker's Bulletin contacted the National Notary Association regarding whether a sourdough starter maintained across 437 unwitnessed transfer events constitutes a compliance exposure. The NNA did not respond. Weir said this was consistent with her experience of the regulatory space. Gregor, measured at 74.8°F this morning and exhibiting vigorous peak rise at 87% hydration with characteristic domed surface tension and a CO₂ bubble distribution Weir rated as "within spec," has been designated the subject of an ongoing corrective action. He is thriving. The situation remains open.