Traceability for Issue 8
There is now a new clause in the traceability section of the BRC issue 8 standard. Clause 3.9.1 now states that we need a documented procedure that details how the traceability system works and how the batch (or lot code) labelling is managed throughout the process. There’s also an addition to this section, which states that when a traceability test is carried out, a summary of the documents used during the test must be kept.
The traceability procedure
So, we don’t have to do anything new for traceability, it’s just how we document it and prove to the auditor that the system is robust. The procedure needs to detail the steps of the traceability process and how the lot or batch code system works at each step. Where a lot or batch code changes at a particular step, you need to make sure that it’s clear how this change is controlled. Then, the procedure needs to detail how the traceability system is recorded and how the materials are labelled.
To make this simple (as traceability systems can be complex) we would suggest that you:
- draw out the traceability process, giving each step a name
- for each point in the process, detail:
- where the lot or batch code comes from
- who is responsible for receiving and recording the lot or batch code
- how the material is labelled and who is responsible for it
- and then, how the lot or batch code is generated and who is responsible for generating it
Traceability step: Raw material intake
Batch code entering process step: Taken from the supplier’s delivery note
Traceability process: Intake store person is responsible for receiving and checking the delivery note
Traceability labelling: Intake store person applies a sequential number to the delivery note, this is the new batch code. The store person then applies a label onto the bottom of the pallet with the new batch code on it, so it’s present until all the material is exhausted.
Traceability link: Delivery note batch number links to the new batch code (sequential number) applied at intake
Batch code exiting the process step: Sequential batch number
To make this even clearer, you could show this in a table, so that the same information is provided for each step in the traceability process. This would make it a much easier procedure to write and read!
|Traceability Step||Batch Code||Traceability Process||Traceability Labelling||Traceability Link||Exit Batch Code|
|Raw Material Intake||Supplier delivery note batch code||Check the delivery note to ensure the batch code is clearly detailed||Apply the SAP Code to the delivery note. Apply traceability label to bottom of pallet.||Suppliers delivery note batch number links to the site SAP code.||SAP Code|
Traceability test summary
Now when you carry out your traceability tests, you need to document a summary of the test. This should include the documents used in the trace, the lot or batch codes and where they change the links between them. If you already keep a copy of all the documents you did the trace on, as part of your evidence of the test, then you’ve already got this covered.
However, if you only keep your summary and no copies of the paperwork, you now need to list references to the documents that you used. The reason for this, is so that your BRC auditor can find the same documents you looked at, look at them themselves and come to the same conclusions.
It’s also a good idea to have a set front cover for your summary, which prompts you fill in all the key pieces of information. Create this form, so that it flows in the same way your traceability system and where batch codes change, document these – providing the links between them.