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!