Packaging Traceability

I would like some advice on an issue. Let’s say I have a food contact box liner. I received 200 cases @ 500 bags per case = 100,000 bags on Jan 1, 2013. During every production run (we run about 8-15 product a day) a few bags are torn or fall on the floor and get dumped in the trash. When the production supervisor fills out the product report they know for sure how many bags they used because they know the finished cases count. The also always list the lot number on the production report. What they don't know is how many bags went to the trash.

Also our sanitation team members like the size of the box liners because they cover electrical boxes so they don't get wet during wash down. Sanitation doesn't keep track of how many box liners they use.

On Feb 20, 2014 all the box liners are gone. Every product that used the box liners has the amount of box liners they used for the item listed in the inventory report. However there are still 10 cases (5,000 box liners) still on inventory report. Our inventory department does a physical and there are no more box liners. Because of this they make a neg. adjustment so the inventory report is correct.

We know when the box liners came in.

We know how man box liners where used in each production run.

We know the last date we had this lot of box liners in our facility

Now will a BRC auditor look at this. If I can show how many box liners of lot 12345 went into each production run is that the end. Do I need to show where those 5,000 box liners went to or is a neg adjustment going to be ok. Do I need to keep track and document on the inventory report how many bags went to the trash?  Thanks for the help. 

Basically what you are asking is about a packaging mass balance.

In short terms, I would say the answer is "yes, it's ok" because you know there is a certain level of wastage on these bags and a 5% loss on packaging does not seem unreasonable. 

In my experience, BRC auditors don't generally delve into quite this much detail so you would probably be fine anyway but, that said, it is still worth reviewing why the cleaners are using them?  Is there not a cheaper bag they could use?  If not or if it makes sense to order these in bulk, would it also be sensible to issue a certain stock to 'cleaning' on your system; they then store the bags for their use and don't use the production stock.  You then have full trace of where all the bags go, short of one or two which are lost as part of the production process (which you could build into wastage figures in the BOM) and then you should be able to balance with more certainty and at least more ability to demonstrate it.

As far as the BRC auditor is concerned all he needs to know is if you follow 3.9.1 of the Standard. 'The company shall have a system which has the ability to trace and follow all raw materials from the supplier through all stages of processing & distribution of the finished product and vice versa,'

In one audit, the auditor raised an NCR as we weren't capturing the liner information on the production paperwork, so along as you can trace a liner to the supplier, IMO, that's all the info he'll be concerned with, not how many have been 'lost' in the company. 

Dear all,

@ S Maddux

I will be accept this traceability/mass balance, as long as the 'lost' is always circa 5% and not 15% for one batch and 2% for the other. I even think that you do the traceability very thoroughly. And most of all I like that you can explain the difference.

However, I agree with GMO  that there is room for some improvements regarding the cleaning team.

I, myself as a BRC-auditor, does not check packaging traceability that thoroughly. I will check if the organisation has a system, I would like to see that the organisation included traceability of packaging materials in their own traceability and recall tests and I will take a product sample from retailer from which you also have to trace the packaging material to supplier, codes, day of reception and period of use. I also will check during audit tour if there are (small) stock of packaging materials in different places. e.g. in different packing rooms. I will challenge that, if I see it.

rosemary4, I do not agree with your statement that the BRC auditor is only concerned in tracing the packaging materials back to the supplier.  The requirement clearly states that the materials should be traced and followed 'through all stages of the processing and distributin process'. A mass balance check is needed to check the correct working of the traceability system.

In one audit, the auditor raised an NCR as we weren't capturing the liner information on the production paperwork, so along as you can trace a liner to the supplier, IMO, that's all the info he'll be concerned with, not how many have been 'lost' in the company. 

I understand and agree with your explanation here i.e. it is necessary to capture on document the "specific batch or batches" of liner(s) (primary packaging) as a trace of the source (from a supplier) that were used. 

"Tracing throughout all stages of the process and distribution" - basically refers to traceability capture of secondary and tertiary materials which are applied at later stages to be documented as well.