My company is currently a manufacturer of paperboard folding carton food packaging. We are moving towards certification to BRC issue 6 for Packaging Materials. Most of the product we produce is indirect food contact. One debate we are having regards traceability. The standard says the following in 3.11:
The site shall be able to trace and follow all raw materials through processing (including subcontracted processes) to the distribution of the finished product (packaging material) to the customer and vice versa.
Most of our product consists of 4 types of raw material: paper, ink, coating, and glue. Currently we only have full traceability of paper from receipt of rolls and their Serial Numbers to consumption on individual jobs. For ink, coating, and glue, we have record of when the products were received and their corresponding batch numbers, but we do not trace the consumption of these batches to each job. So were there to be an issue with one of these raw materials, we would have to judge based on the timing when it was likely consumed, but we wouldn't know 100% exactly which jobs. Theoretically that would mean if there was a recall we would have to cast a wider net of returned product than if we traced to each job. But that is a risk we might be willing to accept.
My question is, do you think if we have a documented risk assessment of our raw material traceability (and the likelihood/severity of harmful issues with coating, glue and ink), that an auditor would accept this? Or will they expect that everything is traced to the same level as our paper?