HACCP to include traded goods?

I'm hoping someone can help.  We are a high risk food packaging manufacturer, in addition to this we also buy and sell ready made packaging.  Our BRC covers this with the voluntary traded goods module. 

Should the scope of my HACCP plan include the traded goods or is it just the manufactured goods?  There is nothing in the traded goods part of the standard that mentions hazard and risk managment.

Thanks for any advice. 

Good morning welshbox! The best practice would be to do a risk assessment of your the "Traded Goods" that are introduced into your firm. Based of the results you can determine the level of risk these items may create, and if there needs to be monitoring in the form of a CP or a CCP. Remember, as an add on to the BRC Global Standard for Food Safety Issue 7 Module 8 Traded Goods is "Pass/Fail". Any non-conformities against the requirement will not be included in the assesment for ISSUE 7. Good Luck and I hope this helps. 

MK

Thanks very much for replying MK.  The traded goods are subject to the exact same prerequisites as the manufactured goods, they just miss out the big manufacturing step in the middle so I know there are no CCPs, I'm just unsure whether or not to write them into the scope. 

Hi welshbox,

Just in case nobody knows, IMO this question is an ideal one to throw at yr (prospective) auditing Company since the"scope" is typically an auditors first evaluation requirement prior advising further audit details.

IMEX (BRC Food) auditors will be delighted to reply for free.

Generally, when it comes to HACCP my rule of thumb is that if there is any doubt put it in.Sooner or later an auditor is going to say "Where have you looked at the risks of your traded goods handling" or one of your traded goods customers will ask for your HACCP plan for their products

It doesn't need to be extensive - a few boxes on a flow diagram (don't forget customer returns) and some fairly simple likelihood and severity assessments.

Look also at any cross linked risks between them ie are you buying in anything which may impact on your own manufacturing

Depends on what you do with the traded goods - repack, relabel, inspection for damage, etc.

If there is no chance of contamination (shipped goods and returned) goods.  Then the risk analysis in your HACCP plan should justify why no chance of contamination.  If no chance, then no control program needed.

However, if a chance of contamination, then your risk analysis should explain the severity and frequency of the risks and how you control them.