Trying to Interpret Clause 3.9.1 Traceability
I am trying to interpret clause:
3.9.1: Identification of raw materials, including primary and any other relevant packaging, processing aids, intermediate/semi-processed product, part-used materials, finished products and materials pending investigation shall be adequate to ensure traceability.
The interpretation guide says, "The traceability system needs to include primary packaging (in direct contact with food), other relevant packaging materials (such as printed outer packaging) and processing aids..."
The part I'm stuck on is "other relevant packaging." What is considered relevant packaging? If I have a box that is lined with a poly bag and the product goes in the bag, is the box relevant packaging? We cook some products in sleeves. These sleeves are crimped with metal clips. The clips do not come in contact with product. Are these clips relevant packaging? We use some pre-printed consumer boxes. Are these considered relevant packaging?
As far as processing aids go, we use liquid nitrogen to freeze product. We have bulk tanks for this and obtain certificates of food grade suitability. However, we cannot lot track the liquid nitrogen. If a risk assessment is completed and I show there are no recalls for food safety issues surrounding liquid nitrogen, is that enough to not lot track this?
Any help interpreting this clause would be helpful.
Ebutera,
I am going to try my best and again this is my opinion and experience.
1) Packaging- We mfg starch in drums/bags/boxes, drums & boxes have a poly liner (sound similar to your issue) we record both the drum AND liner lot codes. Let me ask it this way, if your box vendor called you and said "we accidently sprayed (insert dangerous chemical here) on your lot of boxes" would you be able to get that effected product back? Now for the clips I am not sure, because we use a zip tie to seal our liners and those are not tracked. If your product bag goes in a box and several boxes go inside a large box (I am thinking butter quarters go in a 1lb box then those boxes go into a case) generally the case is no, but I could be mistaken.
2) Now in the Nitrogen case...that is a good one. Do you ever completely empty the holding vessel? Do you still get lot codes and manufacture info for this? Maybe reach out to them and ask if they have a suggestion
G
I am trying to interpret clause:
3.9.1: Identification of raw materials, including primary and any other relevant packaging, processing aids, intermediate/semi-processed product, part-used materials, finished products and materials pending investigation shall be adequate to ensure traceability.
The interpretation guide says, "The traceability system needs to include primary packaging (in direct contact with food), other relevant packaging materials (such as printed outer packaging) and processing aids..."
The part I'm stuck on is "other relevant packaging." What is considered relevant packaging? If I have a box that is lined with a poly bag and the product goes in the bag, is the box relevant packaging? We cook some products in sleeves. These sleeves are crimped with metal clips. The clips do not come in contact with product. Are these clips relevant packaging? We use some pre-printed consumer boxes. Are these considered relevant packaging?
As far as processing aids go, we use liquid nitrogen to freeze product. We have bulk tanks for this and obtain certificates of food grade suitability. However, we cannot lot track the liquid nitrogen. If a risk assessment is completed and I show there are no recalls for food safety issues surrounding liquid nitrogen, is that enough to not lot track this?
Any help interpreting this clause would be helpful.
I think that saying that a packaging item poses no risk to your food is saying that it is not relevant packaging. No risk = not relevant, IMHO.
The LN2 traceability could be solved by tracking by delivery date. The manufacturer might have a lot number or batch number, but if you get your tank automatically filled, you may not get that information, or it may only be on the invoice.
Martha
Silly question.. is the food packaged into the bags before it is frozen or after? Because if its packaged before, then the nitrogen is not coming into direct food contact and you may therefore be able to argue that it is not relevant to food safety and therefore does not need to be fully traceable.
Trace everything as best you can and then you can't be nobbled. Almost everything will have some sort of lot number on it. get it recorded. Most of my clients use liners and cartons, both lot numbers are recorded. Both liners and cartons are metal detected. It leaves nothing to chance, and can also be used as stock control if you get your stock controller on board!!
Hi guys,
I also have a question, how about this "finished products and materials pending investigation shall be adequate to ensure traceability."
What is the meaning of this? Could external laboratory testing be qualified in this section?
I'm trying to find the right section for procedure i'm making which focuses mainly on monitoring the batch of every product we sent for third party analysis. According to the auditor, we should note the batch code and sadly we didn't have that kind of procedure, so i'm making one right now.
Thanks.
Joan
My understanding is that all material should have adequate identification which allows traceability.
We use Julian coding on finished products (Today example: 365 07:57 L2) that will tell us day 31/12 on line 2 at 07:57.
So if we need to check for example a product complaint for a chicken with a label saying 365 08:10 L2 we find the sheet prior to that (we check and record every 30 mins)
On label check sheets/production sheets for that line all material being used record batch numbers
Chicken load number (follows all the way through raw material process)
Label batch ID
Tray type and batch ID
Film type and batch ID.
We can then check goods delivered sheets to see when trays, labels and film were delivered (although with batch info we can already start the ball rolling with supply companies for their part of any trace).
Very simple system that works well. My introduction of recording label, trays and film info on label check sheets over the last 2 months caused world war 3 at the time, but has saved a lot of educated guess work. My point being was despite many change overs where they might change products after only a 10 box run (don't ask!), if they have to fill out a new label check sheet, adding a few more numbers wasn't really more than a few seconds to the check/recording of info.
So long story short, ensure everything has batch/lot code/order number (or whatever you use). Record any relevant info at time of production and it makes life sooooooo much easier.