BRC (Trace & Batch records) during audit
Hi guys
We are a indian food manufacturing company and are due our first BRC audit in december next month and are preparing for the traceability/ Recall challenge that will be presented during the audit in which we are given 4 hours to recall a product.
my QUESTION IS?
- How long back does the auditor go to ask for a Mass balance/ Trace on the products. we have records for 3 months and are not sure if we require any batch records or anything else after this?
in your guys experience how far back did the auditor go back to ask for a traceability/ Mass balance during your BRC audit?
thank you and i would love any answers you guys give in order to help us in this hurdle! thanks so much
IME it's typically been a batch produced within the last 3-6 months, but it may depend on shelf life - they'll want something that has been sold on to your customers so that you can also do a forwards element to the trace.
It's a while since I've been through a "first" BRC audit but again experience was that you can talk through with the auditor about how long your systems have been established as they want to see if these work. If it's a new site that's only been operating for three months then of course that also sets a fairly legitimate constraint!
If you physically don't have records prior to three months previously then they may ask questions about this - even without BRC in place you'd be expected to retain these for a sufficient period of time.
i think it's wise to have at least 1 full year of documentation available---unless of course you'e only been manufacturing for 4 months!
2-3 years is a normal span of time to keep records on hand
Hi Doug,
In our audit a couple of weeks ago the auditor chose something we manufactured in February of this year so about 9 months ago.
If you only have records for 3 months, make sure you also consider clause 3.4.1- the internal audit program where you need to show evidence of auditing your BRC program over the preceding 12 months- don't think that this dosen't apply if it is your first BRC audit; we did that last year and got a major non-conformance as a result, and the argument that we had nothing to audit as we weren't BRC accredited didn't wash.
Good luck with your audit!
Ben
Dear Doug,
In addition to the above, please note, that batch traceability is a also a legal requirement. This file needs to be in order to avoid problems.
Unless other customer requirements, you need to keep the records, and to be able to retrieve them, during the shelf life of the product + 12 months.
Kind regards,
Gerard Heerkens