3 replies to this topic

[D-D]

Bit confused here: Our obligations regarding this clause relate to Kosher and Halal (by the way, I am sure I have seen on here that these two are covered by this, correct?). Now then, how are we supposed to "undertake documented mass balance tests at least every six months"?

I can see how this relates to GMO i.e. account for all your GMO materials to ensure none have been used in non-GMO products but for Kosher/Halal I do not see the point of accounting for those as it does not matter if they end up in our non-Kosher/Halal products. By the way, we are talking ingredients here (nothing to do with animal products) so the assured status is based around limits of alcohol, which is sometimes used as a process solvent, traceability and validated cleaning methods. They are often the same as the non- products but with more paperwork in place...

Help please....?

[GMO]

Bit confused here: Our obligations regarding this clause relate to Kosher and Halal (by the way, I am sure I have seen on here that these two are covered by this, correct?). Now then, how are we supposed to "undertake documented mass balance tests at least every six months"?

I can see how this relates to GMO i.e. account for all your GMO materials to ensure none have been used in non-GMO products but for Kosher/Halal I do not see the point of accounting for those as it does not matter if they end up in our non-Kosher/Halal products. By the way, we are talking ingredients here (nothing to do with animal products) so the assured status is based around limits of alcohol, which is sometimes used as a process solvent, traceability and validated cleaning methods. They are often the same as the non- products but with more paperwork in place...

Help please....?

But it does matter if your non Halal / Kosher ingredients ended up in the Halal or Kosher product right? That's the reason why. So by doing a traceability / mass balance check on Kosher salt say, you are checking that you are only using a maximum of 100% of the recipe in that product. What sometimes happens when traceability is lost is you actually account for 110% (for example) which is obviously impossible. That means that 10% minimum was from another source which might not have been Kosher.

Note that mass balance will be needed for your traceability in the BRC audit whether there is a declaration or not so you might as well practice it regularly.

[D-D]

But it does matter if your non Halal / Kosher ingredients ended up in the Halal or Kosher product right?

Yes, but then the implication is to do a mass balance of everything that isn't Halal/Kosher. Hundreds, if not thousands of raw materials and products... We do a stock check once a year that takes a week; there is no way I will convince it needs to be done twice a year. It is the "mass balance" idea that I struggle with as it makes little sense in our situation and as long as we have hygeine and traceability in place there is nothing that can be said to doubt we meet requirements.

I have just dug out the F0 FAQs Issue 6 V2 and see they have written quite a bit about this, which I think reflects it was badly worded and is causing confusion. Anyway, it seems to imply it just needs to be an audit test sample "for a batch of incoming raw material" so if I roll that into our traceability schedule (we do a test once a month on a raw material, product, process aid or packaging item), hopefully that will do. However, I will do the trace on a product rather than a raw material and have to argue the toss that this makes most sense for us i.e. to show every ingredient in the product is correct.

[GMO]

Yes, but then the implication is to do a mass balance of everything that isn't Halal/Kosher. Hundreds, if not thousands of raw materials and products... We do a stock check once a year that takes a week; there is no way I will convince it needs to be done twice a year. It is the "mass balance" idea that I struggle with as it makes little sense in our situation and as long as we have hygeine and traceability in place there is nothing that can be said to doubt we meet requirements.

I have just dug out the F0 FAQs Issue 6 V2 and see they have written quite a bit about this, which I think reflects it was badly worded and is causing confusion. Anyway, it seems to imply it just needs to be an audit test sample "for a batch of incoming raw material" so if I roll that into our traceability schedule (we do a test once a month on a raw material, product, process aid or packaging item), hopefully that will do. However, I will do the trace on a product rather than a raw material and have to argue the toss that this makes most sense for us i.e. to show every ingredient in the product is correct.

No I disagree. That's not the implication at all. If you have a product which is organic, you need to do traceability on the organic product including mass balance not all of the non organic ones (although you should do traceability on those too just not perhaps as often.) It's exactly the situation I was indicating so that you know you're not getting them mixed up, i.e. you have not used more than 100%.

Honestly, calm down. Auditing is a sample not a 100% monitoring exercise. By doing traceability and mass balance you are testing the system not checking everything.

Also as I said, mass balance is required for every product traceability not just ones with assured status. In practice IME they tend to chose one ingredient to test during the audit. You can chose to do every ingredient of a product every 6 months if you like so you go over and above (we do every ingredient of one product every month here.)