Question on BRC Clause 5.3.2

Hello,

I have a question about BRC Clause 5.3.2 listed below.

5.3.2 Clause: Where a claim is made relating to the provenance, assured or identity preserved status of a product or ingredient, the facility shall maintain purchasing records, traceability of raw material usage and final product packing records to substantiate claims. The company shall undertake

documented mass balance tests at least every six months and at a frequency to meet the particular scheme requirements.

 

All of these records are located in our SAP system, and when we do our mock recalls a mass balance test is performed. We do mock recalls at a minimum of two times per year or more. Do I need a separate procedure for this or can I reference our mock recall procedure?  Let me know what you think :helpplease:

 

Thanks,

Breann

Hi Breann,

 

I recently undergone BRC implementation course & as per my understanding no separate procedure but you have to maintain 2 mock recalls once year means every six monthly for the same.

Hello,

I have a question about BRC Clause 5.3.2 listed below.

5.3.2 Clause: Where a claim is made relating to the provenance, assured or identity preserved status of a product or ingredient, the facility shall maintain purchasing records, traceability of raw material usage and final product packing records to substantiate claims. The company shall undertake

documented mass balance tests at least every six months and at a frequency to meet the particular scheme requirements.

 

All of these records are located in our SAP system, and when we do our mock recalls a mass balance test is performed. We do mock recalls at a minimum of two times per year or more. Do I need a separate procedure for this or can I reference our mock recall procedure?  Let me know what you think :helpplease:

 

Thanks,

Breann

This would be fine refecerenced in your company's mock recall procedure, as long as you can prove that you have full traceability in your mock recall through a mass balance.

Make sure that you test you recall from both raw materials/batches and fnished product, I know thats an easy citation as some companies only perform a moch recall on finished goods.

Dear Bre,

 

I was unable to find any  specific reference to “mock recall” in brc6.

 

It does use the  term “product recall” with minimum annual testing as per 3.11.3  and  glossary def. – Any measures aimed at achieving the return of an unfit product from customers and final consumers.

This def. IMO does not explicitly require a mass balance although I can see the side-benefit. ( I stand willing to be corrected by current brc6 user :smile: ).

 

Nonetheless, I cannot see any objection to yr cross-referencing an appropriate mass balance procedure embedded within yr mock recall test. Although seems to necessitate an over-kill of mock recalls perhaps ? :smile:

 

Rgds / Charles.C

Dear Bre,

 

I was unable to find any  specific reference to “mock recall” in brc6.

 

It does use the  term “product recall” with minimum annual testing as per 3.11.3  and  glossary def. – Any measures aimed at achieving the return of an unfit product from customers and final consumers.

This def. IMO does not explicitly require a mass balance although I can see the side-benefit. ( I stand willing to be corrected by current brc6 user :smile: ).

 

Nonetheless, I cannot see any objection to yr cross-referencing an appropriate mass balance procedure embedded within yr mock recall test. Although seems to necessitate an over-kill of mock recalls perhaps ? :smile:

 

Rgds / Charles.C

Here in the states, if you are testing your prdocut recall procedures and in essence not really pulling product back, then it is known a "mock recall". Clause 5.3.2 references anything that needs an identity claim, at our facility we sometimes use Angus and Sirloin beef. Because of that we need to perform mock recalls on an items that contains these raw materials to statify 5.3.2 by proving that the amount of raw material recieved worked out to what was made into finished product.

 

Also, how do you know your recall program is effective if you do not perfrom a mass balance?

Dear David Pham,

 

This topic has an extensive  history on this forum.  AFAI can see  there are  various interpretations / philosophies / scopes of the numerous interlinked terminologies in use, both within and between countries / organisations. It's a bit like "validation". :smile:

 

For example(s) see this thread which also cross-links to earlier threads –

 

http://www.ifsqn.com...y-requirements/

 

At least in this case, for this standard, I guess the question in the OP has achieved a consensus answer ?

 

Rgds / Charles.C

It is mass balance, not mock recall. All claims shall be done at every six months so that means if you have 2 schemes, one for GLOBALG.A.P. certification and another for Assured Produces, you have to do each of them at twice a year.

 

NY

This section (5.3.2) is nothing to do with recall, it is a traceability exercise relating to provenance of a product. Product Recall is section 3.11

I have a similar product. I carry out a traceability of the product (and I'm saying that it is a WELSH product) to prove that all of my ingredients are WELSH. This means going back to the supplier and doing a mass balance of what product has come in, and what product has left. We use a 5% production loss in our calculations.

I also do the same for an organic product.

Caz x

Does gluten free fall under 5.3 Provenance, assured status, IP? Would this product need a 6 monthly mass balance?