As far as the traceability part, this is from the Guidance for BRC 7 Food:
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.
Marshall