Traceability in a timely manner

BRC defines a timely manner for completing a traceability test as within 4 hours. That's fine but......does this really mean that every traceability we do has to be achieved in that time frame?

I work in the meat industry so as you can imagine the number of traceability requests I have had this year has been huge. Each request is always accompanied with a "this is urgent, I have an auditor on site". And of course in many cases its a BRC auditor who is expecting the results of the trace within 4 hours. 

Most of the time this is fine but on a couple of occasions we have come unstuck. If the request comes in after 12pm, the 4 hour period falls out of working hours. Our slaughterhouses close at 3pm UK time. And occasionally the requests are made on continental public holidays so no-one is working.

If we had an emergency, a trained member of staff would come in and do the trace. But surely its unrealistic to expect that for every trace we get asked for - I had 20 last week alone!

What are your experiences?

thanks

Hi Nomio,

You should have the systems and resources in place so that you are capable of full traceability in an emergency situation within 4 hours.

This does not mean you need to do this 20 times a week and you should look to manage your customer and non-emergency requests for traceability as such.

Regards,

Tony

You now what I would do, I'd send an email out to all of my customers saying the following

Due to an increase in requests in traceability exercises, the following procedure has been implemented

• Please let us know in advance that you have an audit coming up, as traceability exercises will take priority for those who have pre-warned us.
• Please let us know as soon as you have your traceability information so that we can begin our exercise
• Please be aware that there will be nobody on site to carry out a traceability exercise after 3pm. We do have a plan in place in the event of a "product recall / withdrawal" traceability exercise but this will only be implemented during a genuine issue.
• Please be aware than obtain information during a European public holiday may be difficult if for an exercise traceability

You'll need management buy in, doubt it would work though, but you can try it.

Cazx

Thank you Caz that's pretty much what I had decided to do and thankfully I have my senior management buy in for this. It was given after a customer recently gave us 1 hour during lunchtime in which to complete a trace (I stongly suspect they forgot to email us when their auditor set the trace!)

As I say I know it can be done quickly and efficiently, we have great systems. I'm just getting a little fed up of every "urgent" request. I just wanted to be sure that I wasn't breaking some BRC rules by politely tellling customers they wouldn't necessarily get them on time.

There is something i don't understand...

When I run traceability tests during BRC audit, the auditor ask me to find the supplier's shipping documents, our shiping documents and all the data between those papers.

None of the auditors have ever asked for contacting the suppliers or the clients for their traceability.

If you run a company with centralized traceability for many sites, you have to consider the possibility of auditing the central service once a year and use it for all sites.

There is something i don't understand...

 

When I run traceability tests during BRC audit, the auditor ask me to find the supplier's shipping documents, our shiping documents and all the data between those papers.

None of the auditors have ever asked for contacting the suppliers or the clients for their traceability.

 

If you run a company with centralized traceability for many sites, you have to consider the possibility of auditing the central service once a year and use it for all sites.

I think where we are coming from is if we have a component in our finished product that is manufactured elsewhere.

It may be that we have CoA's or COC for these components, but not full traceability documents, and if this component is in the product that is part of the traceability, then it to should be traced.

It maybe that Nomio is producing a BBQ pack with a dip or marinade component that is manufactured elsewhere.

Caz x

I agree with VeilleAlim - a Company is only required to go backwards one step and forwards one step for traceability, and as far as I am aware the (BRC) Company cannot be expected to test their suppliers' traceability procedures within that 4 hour requirement?

Otherwise, God help us.....!!