Traceability required for product being shipped to biogas company

We are SQF level 3 certified, my question is one of our facilities in an effort to reduce landfill waste is in the process of beginning a trial of sending our full cans (full of product) to a biogas company  instead of sending that product to the landfill.

My understanding is this company is using the contents of the can to feed bacteria to produce gas.

My concern is do I have to be able to trace the product and ingredients of the containers we are sending to this biogas company?

Thanks,

Susan

Regardless of the certification, I would venture, yes you need to trace these cans as well. If you performed a mock recall, how would you account for a gross of your product being absent? I would also imagine from an accounting perspective that your employer would like to know how much product is not being "sold"

Hi Susan,

It is good practice to record waste disposal and ensure you have full traceability and can account for all your finished products.

This something BRC in particular are a bit sharper on as products have been known to have been 'intercepted' on route to disposal and sold on:

'4.12.3 If unsafe products or substandard trademarked materials are transferred to a third party for destruction or disposal, that third party shall be a specialist in secure product or waste disposal and shall provide records which include the quantity of waste collected for destruction or disposal.'

SQF 11.9.1 Implementation Guidance
The procedures for storage and disposal of all types of waste – dry and liquid – must be documented and implemented. The procedure will include how waste is contained in appropriate, covered and labeled containers; the frequency of disposal; how it is disposed of; and who is responsible for it. Local regulations and community expectations concerning recycling and waste disposal and transport must also be considered.

11.9.1 Auditing Guidance
Waste handling, storage and disposal procedures shall be reviewed as part of the initial desk audit. Subsequently, waste storage and removal will be audited as part of each facility audit through observation, review of records and interviews with operating personnel. Evidence may include:
• Waste handling, storage and disposal procedures are documented;
• Waste handling, storage and disposal procedures include how waste is contained in appropriate, covered and labeled containers; frequency of disposal; how it is disposed of; and who is responsible for waste handling and disposal;
• Waste handling, storage and disposal procedures are fully implemented;
• Records are maintained of waste disposal;

Regards,

Tony