2 replies to this topic

[Tech - QF]

"The company shall ensure that its suppliers of raw materials have an effective traceability system"

 

Can someone in possession of the interpretation guidelines advise whether certification of the raw material supplier to BRC or other GFSI-recognised scheme is sufficient to comply with this requirement?

 

Many thanks

[agnes]

Please see below interpretation guidelines:

 

The company shall ensure that its suppliers of raw materials have an effective traceability system. Where a supplier has been approved based on a questionnaire, instead of certification or audit, verification of the supplier’s traceability system shall be carried out on first approval and then at least every 3 years. This may be achieved by a traceability test. Where a raw material is received directly from a farm or fish farm, further verification of the farm’s traceability system is not mandatory.

Interpretation Supply chain traceability

It is important for the integrity of products that appropriate traceability systems operate throughout the supply chain. Therefore, sites must ensure that their raw material suppliers (excluding packaging suppliers) have suitable traceability systems in operation. This assurance can be obtained from certification, auditing or by directly testing traceability. Examples include:

•Where the raw material supplier is certificated to a GFSI-benchmarked standard – assessment of traceability systems forms part of these audits and therefore no additional action is required to comply with the requirements of this clause; however, a communication mechanism should be in place, such that if the raw material supplier was no longer certificated, the site is made aware of this change.

•If the raw material supplier is audited by the site and the audit includes an assessment of the traceability systems, this complies with the requirement of clause 3.9.3 as traceability has been assessed. The audit should be repeated at least every 3 years.

•If supplier approval is based solely on a questionnaire with no additional testing of the traceability system, additional traceability verification is required unless the raw material is a primary agricultural product purchased directly from a farm or fishery, where additional testing of the traceability systems is not mandatory. This verification could include, for example:

- A test of the raw material supplier’s traceability. For example, as part of the site’s traceability test (refer to clause 3.9.2) a relevant ingredient is highlighted. The ingredient and batch details for the material are forwarded to the supplier to enable them to complete the traceability test for the specific batch of raw materials and forward the relevant records back to the site.

- A worked example from the raw material supplier, which clearly shows how the traceability works.

- A detailed description of the traceability system, provided by the raw material supplier.

Information received during the traceability verification should be incorporated into the supplier approval process (clause 3.5.1.2).

Traceability verification is a requirement for each raw material supplier. Therefore, any traceability test (i.e. because the supplier approval is based solely on a questionnaire) should be designed to test the raw material supplier’s systems and not to trace every single material they produce. Where a site purchases multiple ingredients from the same raw material supplier, it is not a requirement to complete a traceability test for every single ingredient purchased, only to complete the traceability test for each supplier from which ingredients are purchased.

The frequency of the traceability verification should link to the supplier approval programme; that is, the traceability is verified on first approval of the supplier, and then at least every 3 years.

During the BRC audit, the auditor will not undertake a test of raw material suppliers’ traceability systems but will review the site’s processes and the information received from their raw material suppliers.

[Tech - QF]

that's great, thanks