Traceability

The requirements

Procedure

A procedure must define the traceability system, including:

• The scope of the system.
• How the system works.
• Define a batch, including rules for bulk materials.
• Define process loss for mass balance purposes.
• The labelling requirements at each step (as a minimum, the traceability codes of incoming materials must be linked to the traceability code of finished products).
• How traceability will be recorded and the links at each step.
• The references of the records which provide the traceability information.

The traceability system, including process records, must:

• Be legible.
• Trace all materials, including primary packaging, back to suppliers, through the operation to and forwards onto the next step (e.g. dispatch).
• Include recording of the supplier incoming traceability code.
• Meet customer requirements.
• Ensure that records are retrievable in a timely manner.

Records must include, as a minimum:

• Incoming materials.
• Volumes of stock at all points.
• Processing records relating to product safety, authenticity, legality and quality.
• Dispatch records.

The scope of the system must cover:

• Materials; ingredients including all edible parts, packaging*, decanted, part used, work in progress materials, rework, processing aids and finished products.
• Subcontracted processes.
• The integrity of claims.
• Wasted materials.
• Samples.
• Traceability of test results.
• Surplus products.
• Non-conforming product, quarantined products or materials pending investigation.
• Distribution including vehicles information.
• Damages and returns.
• Cross docked product, including vehicle information.

*Note BRCGS state that you only have to trace primary packaging, however they have a strange definition for ‘primary packaging’.

BRCGS Food Safety Issue 9, Glossary definition:

“The packaging that constitutes the unit of sale to the consumer or customer (e.g. bottle, closure, label and tamper-evident seal of a retail pack or a raw material bulk container). As a general rule, the Standard would not expect transit materials to be classified as primary packaging (e.g. pallets, pallet wrap, shrink wrap, pallet sheets, labels or cable ties applied on the outside of the pallet wrap, recyclable and re-usable travel containers, and plastic crates used to hold glass bottles).”

BRCGS Food Safety Issue 9

Clause 3.9.1 has been updated to ensure that the traceability system meets any relevant legislation, for both the country in which it’s processed and the country of sale. This ensures that the requirements of FSMA’s Traceability Rule are met, see the legislation/FDA page for more information.

9.6.1 – this clause has been expanded to clarify that the procedure must include how traceability of traded products is maintained.

Clause 9.5.3 is new, which requires the traceability of materials of animal origin, which is going to be used for human or animal consumption.

Customer standards

Materials must be labelled at all times, the general rule is that you must be able to put your hand on something and know there and then, exactly what it is and its traceability. This includes bulk held materials in vessels.