1 reply to this topic

[neilmac]

Hi all,

 

Wonder if anyone can answer this query.

 

As mentioned before this is the first BRC AUDIT for the business I am currently in.

 

we are a co packer and do manufacture direct to market.

 

In event of a food safety issue our customers would do the Recall/Withdrawal.

 

We have tight traceability/mass balance being in the spirit industry it has to be for HMRC.

 

Do you think our traceability mass/balance evidence would cover these clauses?

 

All thoughts and advice welcome 

 

Thanks

NMD

[pHruit]

Hi,

You haven't specified which particular clauses you're interested in, so it's a bit difficult to say

IMEX the HMRC side of things is more interested in following the money trail with regard to who has/hasn't paid duty and when, so whilst this will almost certainly suffice as a solid backbone for your traceability, you may need to augment it with further details. Having said that, it's going to very much depend on exactly what you have set up at present for this element.

I can't see this sufficing for recall purposes though - the requirements of section 3.11 are broader than "just" tracing the stock, so I'd definitely ensure that you have procedures in place to cover everything in this section, and that you test these as a full exercise.