Traceability Challenge Testing During BRC Audit
Is everyone else being required to perform the test during the audit? Seems like we have enough to do during this time! Ours is a small facility and only two QA people are involved in the audit process.
Any suggestions?
I am a BRC auditor and it is one of our requirements that we are required toget the business to perform a traceability and mass balance activity during theaudit and within the time frame of 4 hours. It provides evidence that:
(1) You can trace your product adequately
(2) Your records are organised in such a manner that allows easy and efficientretrieval
(3) It shows the interaction for all of the staff rather than just the QArepresentative
(4) You can account for all stock, returns, WIP, Sales
(5) Your procedures are effective in doing what they are supposed to do.
Even if you have an ingredient that is not used often and may go over a greatnumber of products, if it was the real thing - you would still need to be ableto identify. From my experience, when I look at these activities and also atthe documents supporting that the business has done a mock recall - it alwaysseems to be easy scenarios or easy ingredients/finished product that forms the basisfor the activity.
As Classic said above, it needs to be a group effort from all parts of thebusiness including inventory, sales, production, packing, stores etc.
Hope this helps
Cheers
Amanda
Hi
I am a BRC auditor and it is one of our requirements that we are required toget the business to perform a traceability and mass balance activity during theaudit and within the time frame of 4 hours. It provides evidence that:
(1) You can trace your product adequately
(2) Your records are organised in such a manner that allows easy and efficientretrieval
(3) It shows the interaction for all of the staff rather than just the QArepresentative
(4) You can account for all stock, returns, WIP, Sales
(5) Your procedures are effective in doing what they are supposed to do.
Even if you have an ingredient that is not used often and may go over a greatnumber of products, if it was the real thing - you would still need to be ableto identify. From my experience, when I look at these activities and also atthe documents supporting that the business has done a mock recall - it alwaysseems to be easy scenarios or easy ingredients/finished product that forms the basisfor the activity.
As Classic said above, it needs to be a group effort from all parts of thebusiness including inventory, sales, production, packing, stores etc.
Hope this helps
Cheers
Amanda
Thanks for the clarification. Unfortunately, ours is a relatively small operation and production quantity oriented, so QA must perform all QA functions. There would be little input from other departments. This means pulling one member of our team to perform the trace test during the audit, or working on it after hours. Ugh!
Most companies seem to do their traceabilty tests and mock recalls on simple scenarios.
This is a box ticking exercise to comply with the Standard and get through the audit. It does not help you as a business.
Product recalls do not happen very often within a company and it precisely for that reason that the tests should be in challenging scenarios. If you can do it in extreme situations, you will be able to cope with the more likely, less complex situation.
At our previous BRC audit, I was required to perform the traceability test / mass balance exercise while the auditor was here, even though I had done one prior to the audit. I suspect this is to prove it can be done in a reasonable amount of time. I'm concerned that, depending on what raw material the auditor chooses next time, that this could become an overwhelming requirement to perform while the audit is going on. Some of our ingredients are used in such small amounts that we only purchase once or twice a year, so they are used in much, much product.
Is everyone else being required to perform the test during the audit? Seems like we have enough to do during this time! Ours is a small facility and only two QA people are involved in the audit process.
Any suggestions?
We finished our BRC v6 audit today, and we performed an traceability test with auditor present. He picked a random outgoing invoice(if that makes sense, english not my first language), and asked us to trace it back to the raw material (in this case, a catch of marine species). We have good software and process input for this, so it was a quick excercise for us. We had also, like you, performed a traceability exercise, from one production day. We traced out to back to raw material, processing aids and packaging, and then out to product brand and customers with pallet numbers and batch codes.
However, I see your concern, as this would also be a problem for us if we didn't have the tracing software available. One catch may be as much 400 metric tonnes, and around 40% of this would be finished product. 160 tonnes is a lot of finished product to trace (sales units are from 180g to 2,5 kg). I would think, without knowing, that the auditor would then ask you to trace a selection of the products which has the ingredient from that specific batch, to demonstrate that you are able to trace it given enough time. Any other thoughts?
During our FSSC audit, the auditors suggested that for the mass balance requirement, it would be helpful to also report the percent recovery of each material used to get a general idea of how effective the traceability systems.