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BRCGS Information on FSMA Final Rule on Requirements for Additional Traceability Records for Certain Foods

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Tony-C

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Posted 21 March 2023 - 04:56 AM

BRCGS have published advice on FSMA Final Rule on Requirements for Additional Traceability Records for Certain Foods

 

Impact on BRCGS product categories

 

Based on the product categories outlined in BRCGS Global Standard Food Safety Issue 9, the following categories may be impacted by this Rule:

 

2 - Raw poultry

3 - Raw prepared products (meat and vegetarian)

4 - Raw fish products

5 - Fruit, vegetables and nuts

6 - Prepared fruit, vegetables and nuts

7 - Dairy, liquid egg

8 - Cooked meat/fish products

9 - Raw cured and/or fermented meat and fish

 

If any products contain listed foods as ingredients, category 10 - Ready meals and sandwiches, ready-to-eat desserts may also be affected.

 

Traceability Plan

 

If you are subject to the requirements of the Food Traceability Final Rule, you must establish and maintain a traceability plan. This traceability plan is to outline how your business will comply with the rule. Other requirements include:

 

A description of the procedures you use to maintain the records you are required to keep under this rule, including the format and location of these records.

A description of the procedures you use to identify foods on the Food Traceability List that you manufacture, process, pack, or hold;

A description of how you assign traceability lot codes to foods on the Food Traceability List, if applicable;

A statement identifying a point of contact for questions regarding your traceability plan and records; and

If you grow or raise a food on the Food Traceability List (other than eggs), a farm map showing the areas in which you grow or raise such foods.

 

You must update your traceability plan as needed to ensure that the information reflects your current practices and to ensure you are in compliance with the rule. You must also retain your previous traceability plan for two years after you update the plan.

 

See Information Paper: FSMA Final Rule on Requirements for Additional Traceability Records for Certain Foods for more details

 

If you are unsure if your business is subject to the final rule, the FDA has published an easy-to-follow decision tree calculator to help: Exemptions to the Food Traceability Rule

 

All BRCGS certified sites are encouraged to use the FDA decision calculator to help determine if the Rule specifically applies or not.

 

Kind regards,

 

Tony



SHQuality

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Posted 21 March 2023 - 07:23 AM

All BRCGS certified sites are encouraged to use the FDA decision calculator to help determine if the Rule specifically applies or not.

If this is a FSMA rule, then surely this doesn't apply to anyone who doesn't have a FSMA module added to their BRC certification...



Tony-C

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Posted 21 March 2023 - 10:31 AM

If this is a FSMA rule, then surely this doesn't apply to anyone who doesn't have a FSMA module added to their BRC certification...

 

I see your point but not quite right, from the linked information: 

Impact for BRCGS certificated sites

If your business is currently certificated by BRCGS and you are located within the USA, we highly recommend that you use the decision tree calculator to determine if you are subject to the rule. While the Food Traceability Final Rule applies to US importers of food, importers may request traceability information from BRCGS certified sites that export to the USA. BRCGS also encourages exporters to work with their importers to ensure they are keeping records of information that may be required by their importers. 

Kind Regards,

Tony


Edited by Tony-C, 21 March 2023 - 10:35 AM.


SHQuality

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Posted 21 March 2023 - 10:42 AM

Yes, it pays to read carefully, which I didn't. I'm not located in the USA.





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