Part II Appendices3.7.2Where a non-conformity places the safety, authenticity or legality of a product at risk, or
3.9 Traceability Fundamental
The site shall be able to trace all raw material product lots (including primary packaging) from its suppliers through all stages of processing and dispatch to its customers and vice versa.
Interpretation
As well as being a legislative requirement, traceability is a risk management tool, allowing food businesses and authorities to withdraw or recall products that have been identified as unsafe. It is therefore a fundamental requirement. A traceability system needs to be established at all stages of production, processing and distribution, identifying from whom raw materials have been obtained and to which customers finished product has been
supplied. Note that the Standard requires forward and backward traceability throughout the production process. This means that the site should know where the material has come from (i.e. the direct supplier) and to whom finished product is dispatched.
There is no requirement for the site to trace raw materials all the way back to the source (e.g. farm) unless the source is the direct supplier to the site.
Part II Appendic es
traceability. Traceability details need to be retained in a format that allows access in a timely manner.
BRCGS has published a traceability guideline which may be purchased from the BRCGS Store or viewed online at BRCGS Participate.
Clause Requirements
3.9.1 The site shall have a documented traceability procedure designed to maintain traceability throughout the site’s processes. At a minimum this shall include:
• how the traceability system works
• the labelling and records required.
Where applicable, the traceability system shall meet the legal requirements in the country of sale or intended use.
Interpretation Traceability procedure
Sites are free to utilise their own traceability systems; no specific tool or technique is required by the Standard. Nevertheless, it is imperative that the site documents its traceability procedure so that it can be used and understood by the relevant personnel. This is particularly important at times of stress, when it is likely that the procedure will be relied upon to ensure at-risk product is identified and recalled or withdrawn in a timely manner.
Some countries have specific legislation relating to traceability. The site will therefore need to ensure that any legislative traceability requirements in the country of sale or intended use are met.
3.9.2 Identification of raw materials (including primary packaging), intermediate/semi-processed products, part-used materials, finished products and materials pending investigation shall be adequate to ensure traceability.
Interpretation Identification of raw materials and finished product
Products and materials may be identified by physical labelling, by recording systems identifying the allocation of materials to production or mixing areas, or through the use of computerised bar-coding systems. The level of traceability may need to be agreed between the company and its customers, but the system used must be capable of linking all raw material lot codes to finished product codes. This will enable finished product to be identified if a particular batch of raw material needs to be recalled.
The limitations of any system must be recognised, as can be demonstrated by the problems associated with bulk storage. Products such as sugar may be delivered with clear batch identification; however, if they are emptied into a single storage tank that is mixed with earlier deliveries, the reduction in accurate traceability is compounded by the potential for product to be trapped in dead zones during filling and emptying. If a particular delivery is identified as being contaminated, the entire product in the storage tank would need to be disposed of, as well as several lot codes of finished product, as the company would not be able to identify the specific batch of finished product that contained the contaminated material. A similar limitation will exist if recyclable packaging is collected from several sources and combined to form a single batch.
Interpretation
continued The traceability system needs to include primary packaging (a full definition of primary packaging is available in the glossary, Appendix 1). Note that processing aids (i.e. substances that are used within the process but are not required to be declared as an ingredient, such as sodium alginate for the clarification of beer) are included in the definition of raw materials (see glossary, Appendix 1) and therefore need to be included in the traceability system.
All test results (clause 3.9.3) must be traceable to specific batches of product or ingredient.
Consider how the traceability system operates in practice (with the effective physical identification of ingredients and products). For example, if bulk containers are labelled, consider how the information is presented to ensure it is legible and accurate. Common non-conformities include the ineffective labelling of part-used packs in production, work in progress, and storage areas leading to potential errors.
Strict controls on material identification, traceability and segregation are also required to preserve the integrity of any claims made, such as organic status. Where logos are used that make specific claims about production systems (e.g. farm assurance), full traceability must be demonstrated (see also section 5.4).
Apart from batch or lot codes, traceability information will usually include date codes to ensure that only ingredients, intermediates and products within the appropriate shelf-life period are used. Particular care is needed for decanted ingredients, work in progress and products stored in bulk where the packaging has been removed.
3.9.3 The site shall test the traceability system across the range of product groups to ensure traceability can be determined from the supplier of raw material (including primary packaging) to the finished product and vice versa. For food raw materials and finished products (i.e. including printed packaging and labels with food safety and legal information), the test of the traceability system shall include a quantity check/mass balance.
The traceability test shall include a summary of the documents that should be referenced during the test, and clearly show the links between them. The test shall occur at a
predetermined frequency, at a minimum annually, and results shall be retained for inspection. Traceability should be achievable within 4 hours.
Interpretation Tests of the traceability system
Good practice is for the site to have a procedure or document that highlights the traceability system that is used at each step in the production process. It could include, for example, how incoming raw material batch numbers are captured, and how the outgoing product is traced and labelled. The process flow diagram developed as part of the HACCP plan (see clause 2.5.1) may be useful to ensure all steps are captured.
The site’s traceability system must be tested at least annually, or more frequently if required by a customer. (Note that the frequency of traceability tests relating to provenance and origin claims is covered separately in clause 5.4.5.)
Where traceability for all products manufactured by the site is the same or similar, then a minimum of one traceability test a year must be completed. However, if there are significant differences or specific traceability challenges relating to one product or group of products, additional tests specifically related to that product or group of products may be needed.
Traceability testing may be completed as part of a real product recall or withdrawal scenario if one has occurred, since the objective is to test the system and identify areas for
Part II Appendic es
Interpretation
continued The system must provide traceability forwards and backwards; therefore the system should be tested in both directions. For example, a raw material could be selected and traced forwards to show in which finished products it was used. A finished product should also be selected and traced backwards to show all the raw material batch codes (including primary packaging) that were used to produce it. The tests should include identifying which customers received the finished products and which suppliers provided the raw materials. The traceability test must also include the traceability of the primary packaging materials. Although there are many benefits to complete supply chain traceability (i.e. from the farm through all stages of processing, distribution and storage, through to the retailer or food service company), this clause does not require sites to complete full supply chain traceability tests. The scope of the traceability test required here is from the suppliers of the raw material, through the site’s processes, to the site’s customers.
The site is also expected to compile a summary of the documents that should be referenced during the test, and clearly show the links between them. This is of benefit to both the site and the auditor, as it ensures all relevant documents are retrieved, and explains the traceability system.
The test of traceability should be timed and full traceability would be expected to be achieved within 4 hours. This is to reflect the need for rapid traceability in the event of a recall. Where traceability takes longer than 4 hours, review the areas where the retrieval of information is slow in order to identify improvements.
For all food products, and printed packaging and labels which have product safety
information, the tests must also include a quantity check or mass balance exercise. It is not expected that the full mass balance exercise would always be achievable within 4 hours. The objective is to be able to account for the usage of a full batch of a raw material. This helps to ensure that the traceability systems are capable of operating effectively should a product recall be required based on the recall of an ingredient.
The mass balance exercise is usually undertaken as follows:
• Select a batch code of a particular specific raw material.
• Identify the quantity of the raw material supplied under that batch code.
• Identify the recipes in which the ingredient is used.
• Use production schedules and batch make-up sheets to calculate the quantities of the selected batch of ingredient used in each product.
• Calculate the quantity of any unused part of the batch in the warehouse.
• Reconcile the quantity delivered against the amounts used plus any residual unused stock.
In some instances quantity checks may take a great deal of time and resource to complete successfully.
It is unlikely that the mass balance exercise will be able to account for all materials to 100% accuracy. However, the company needs to justify any discrepancies and demonstrate understanding of the nature of the variance. This may be inherent in the product
characteristics (e.g. dehydration of fresh ingredients), or be ascribed to typical wastage on equipment or portion variances. Where the site adds subsequent deliveries to a bulk silo, the test should clearly show how this has been managed. The principle is to ensure that the traceability system is effective. Mass balance is a key measure of its workability and highlights areas for improvement.
Interpretation
continued During the BRCGS audit, the auditor will ask the site to complete at least one ‘vertical’ audit.
At a minimum this will include the traceability of a specific batch of product or ingredient through the site’s production, processing and distribution processes, and a review of the site records related to the product or ingredient. Records will include, for example, supplier approval, goods receipt, process records (such as temperature monitoring), metal detector checks and dispatch records.
However, the vertical audit is not expected to include records that would only be held at other points in the supply chain (e.g. the raw material supplier’s processing records). This vertical audit is in addition to the review of the site’s own traceability tests. The final audit report will include a summary of the vertical audit results.
The vertical audit will also include a mass balance exercise and a review of the systems relating to the accuracy of labelling (clause 5.2.1). Further information on the content of the audit, including the vertical audit, can be obtained from BRCGS’ auditing techniques document. This may be viewed online at BRCGS Participate.
BRCGS publishes a separate best-practice guideline on traceability, which may be purchased from the BRCGS Store or viewed online at BRCGS Participate.
3.9.4 Where rework or any reworking operation is performed, traceability shall be maintained.
Interpretation Rework
Many sites undertake rework or recycling activities, where raw materials, work in progress or final product that has left the normal production but is still safe, legal and of the appropriate quality, is reprocessed. There may be several reasons for completing rework, including to:
• reincorporate the material into a batch of the same product (either the batch currently being manufactured or to enable the materials to be stored for inclusion in a future production)
• incorporate the material into a batch of another product with similar ingredients
• process the material to meet the requirements of an alternative customer.
Where rework is undertaken, procedures must be in place to ensure that traceability is maintained.