5 replies to this topic

[KTD]

Hi all -

 

Point of confusion in BRC v7 clause 5.4.4.

 

I have a single program/procedure that covers the handling of any and all 'claim-labeled' product - non-GMO, Halal, process verified (USDA AMS), No Antibiotics Ever (ANE), etc. Supporting documentation for each claim is maintained elsewhere. Am I required to conduct and document a traceability/mass balance exercise for EACH specific type of claim, or just at the frequencies as required to demonstrate the viablity of the overall traceability system? At a minimum of 2X per year per claim, I could be looking at +20 traceability exercises a year...

 

Please tell me you can save me from unnecessary redundancy!

 

KTD

[Dr.Khan]

Hi KTD

 

The problem is that an auditor can ask you to conduct the traceability exercise for any of the claim in any of your products. so it is advisable to conduct the traceability exercise for each claim, in each product once and then do repeat the process if the formulation of any product is changed. This will keep you ready from the audit point of view. The you need to do the traceability exercise as per BRC v7 clause 5.4.4 of one or two products at the nominated frequency.

 

Kind regards

Humaid Khan

MD Halal international services

Beverly hills Australia

[Michelle Grace Astorga]

Is traceability per claim required? We normally perform traceability per product and that already includes any claim that we have on it.

[GMO]

It is always a risk that you could get a very black and white auditor on this kind of issue.  I'd have a look first at the interpretation guideline but if you are testing the same systems to test the same claim can you lot do an audit which tests multiple claims at once?  I can't see how an auditor could object to that?  A semi related example, when I do recall audits, I make sure the product which is chosen covers every department of multiple sites (fortunately I have products which are processed in multiple locations), it then means I don't have to repeat the study.  I've never had an auditor say this is wrong.

[Leila Burin]

Hello, this is from the interpretation Guide:

The objective is to test the systems and, where necessary, make improvements to information recording, to allow claims to be substantiated should they be challenged by a customer or legal authority. It follows that, where very different traceability systems are used within, for instance, a complex or multi-product site, more than one mass balance traceability exercise may be required every 6 months to ensure that all systems are working effectively. However, where a site has multiple claims, it is not intended that every claim be mass balance tested every 6 months but that a representative selection of claims are chosen. In this situation, good practice would be to choose different claims or products each time the test is conducted.

 

best regards,

Leila

[KTD]

Leila -

 

Thanks for the info! That is just what I was looking and hoping for!!

 

KTD