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BRC clause 3.9.3 - is traceability for different product groups needed?

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Bansal

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Posted 29 December 2021 - 10:29 PM

Hi Everyone,

I have a question regarding traceability.. We are a bakery and doing manual traceability.

Our ingredients have been grouped in 6 categories as below and doing 6 traceability tests/year.

The recall team has identified 6 traceability groups as follows: 1)  refrigerated ingredients, 2) liquid ingredients, 3)flour, 4) seeds, 5) food chemicals, 6) processing aid materials, 

Yearly, the recall team must choose one material from each traceability group 

Which according to me does not  make any sense as per BRC clause 3.9.3

 

So i have changed the procedure as below

·Now 3.9.3:The recall team has identified 6 traceability groups as follows: 1) flour, 2) liquid ingredients, 3) refrigerated ingredients, 4) seeds, 5) food chemicals, 6) processing aid materials,  Since,  traceability process for all the products manufactured at ... is similar (inventory log, receiving log and recipe sheet is used for all the groups for doing traceability), that’s why minimum one traceability test per year must be completed/conducted.

Yearly, the recall team must choose one material from any traceability group .

 

However, my manager doesn't agree to this and saying that  the clause  (BRC 3.9.3,quoted above) says that if process is same/similar then only one traceability is sufficient, but what is different process for  which BRC has mentioned different groups and separate traceability.

 

Please advise if as per clause i am right or wrong.

and if i right , how i can answer her query?

 

Thank you!



mgourley

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Posted 30 December 2021 - 12:10 AM

IMO you are complicating things.

All the groups you have identified are actually in the group of "raw materials". 

The Standard calls out groups of products if they are fundamentally different. For example, you make raw vegetable salads and hamburger buns.

 

Since you are a bakery, that's probably not the case.

 

The Standard specifically states that a forward/backward traceability be conducted for raw materials, finished product and primary packaging.

 

"For example, a raw material could be selected and traced forwards to show in which
finished products it was used. A finished product should also be selected and traced backwards to show all
the raw material batch codes (including primary packaging) that were used to produce it. The tests should
include identifying which customers received the finished products and which suppliers provided the raw
materials. The traceability test must also include the traceability of the primary packaging materials."

 

Marshall
 



Bansal

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Posted 30 December 2021 - 02:44 PM

Thank you so much mgourley!!!!

 

You made it very easy.. thanks again :)!!

 

Just for my knowledge, i am just curious to how traceability is different in raw vegetable salads and hamburger buns? could you please explain :helpplease: .



beersafety

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Posted 04 January 2022 - 07:55 PM

when it says, "you have to test traceability across a range to product groups"  i believe it is referring to your portfolio of products you produce.  

so, if you are bakery, you'd group your finished products, like "sourdoughs, regular bread, breads with allergens, etc, as they have different process steps, shelf life, and hazards. 

from there you'd do a forward and a backwards for each group per year.

 

this was my interpretation and auditors so far are ok with it.

 

cheers!

Liz 



Bansal

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Posted 12 January 2022 - 04:37 PM

Hi Liz,

Thanks for your inputs, but i got confused that how grouping is applicable to  finished products, like "sourdoughs, regular bread, breads with allergens, etc?

 

Because at the end when we do traceability, we don't consider individual steps. Main concern is what you receive at receiving is being traced at using in the recipe and finally matching with used in  finished product + Inventory.

 

How  allergen, shelf life and  HACCP is involved?

 

Could you please help in understanding this.

 

Thanks



Lorem Ipsum

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Posted 12 January 2022 - 06:56 PM

Hi, BRC specifies it in their BRCGS FAQ: The Standard requires the site to test traceability ‘across the range of products’ each year. Where the traceability for all products manufactured by the site is the same or similar, then a minimum of one traceability test a year must be completed. However, if there are
significant differences or specific traceability challenges relating to one product or a group of products, this may necessitate additional tests specifically related to that product or group of products.

 

We as a bakery do 2 annual traces for bagged/boxed ingredients (berries/chocolate/concentrate/etc) and bulk/silo (flour/sugar/oil)





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