An Introduction to Traceability
BRC Global Standards. Trust in Quality
Introduction to Traceability
Introduction to Traceability
Traceability refers to your ability to identify and follow raw materials, components and products through all stages of receipt, production,
processing and distribution.
It should operate one up (identifying who the raw materials have been bought from) and one down (which customers have received the
finished product) and throughout the production process.
To be effective, your traceability system must be capable of identifying and tracing individual batches or lots of material at each step of the
process.
1.0 Requirements of the BRC Global Standard for Food Safety
The BRC Global Standard for Food Safety (Statement of Intent for section 3.9) states:
The company shall be able to trace all raw material product lots (including packaging) from their supplier through all stages of processing
and despatch to their customer and vice versa.
In addition Requirement 3.9.1 states:
Identification of raw material, including primary and any other relevant packaging and processing aids, intermediate/semi-processed
products, part-used materials, finished products and materials pending investigation, shall be adequate to ensure traceability.
And Requirement 3.9.2 states:
The company shall test the traceability system across the range of product groups to ensure traceability can be determined from raw
material to finished product and vice versa, including quantity check/mass balance. This shall occur at a predetermined frequency and
results shall be retained for inspection. The test shall take place at least annually. Full traceability should be achievable within four hours.
2.0 The importance of traceability
The traceability system should enable your site to:
• Meet the legal requirements for tracing products and ingredients. (Consideration should be given to any requirements in the country of
manufacture and the country of sale.)
• Effectively and efficiently withdraw or recall products if they are identified as unsafe or out of specification
3.0 What does good a traceability system look like?
3.1 Designing a system
Your traceability system needs to:
• Be effective at all stages of production, processing and distribution by ensuring all batch/lot codes are recorded in a systematic way on
all products, containers and production paperwork
• Include all raw materials, intermediates and final products including additives, processing aids and primary packaging
• Identify who each batch of raw materials has come from. For example, at goods-in record:
- the date of delivery
- supplier’s name
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- ingredient name
- supplier’s batch code
- quantity delivered
- expiry date
• Consider how bulk materials, such as flour, will be traced if fresh deliveries are added to a silo that already contains stock
• Clearly document the link between raw material and the final product. For example, there needs to be clear documentation showing
the individual batches of raw materials used in the production of the specific batches of final product. So there should be a record of
the batch code for each material used in each mix. The mix should then be given its own batch code, which can accompany it through
the manufacturing process
• Identify any materials that are disposed to waste
• Identify the use of rework and maintain its traceability
• Identify which customer(s) have received each batch of finished products
• Ensure products supplied to customers are adequately labelled or identified to help traceability, for example, in the event of a customer
or consumer complaint
• Be able to provide details to customers or regulatory authorities on demand, in a timely manner
The most common failure of a traceability system is where all the materials used in production including packaging, rework and
additives and processing aids, are not accounted for.
Traceability details must to be retained in a format that allows for easy and timely access of information. Generally all traceability
information should available within four hours.
3.2 Labelling
Traceability is easily confused if labels relating to the current batch of materials are removed or if old labels relating to previous products
or materials are not taken off before containers are reused.
When implementing a traceability system, you need to think about alternative systems of marking containers to ensure they’re suitable
for your site’s processes e.g. indelible pens, computer database or visually distinct, temperature proof, tags. Consideration must also be
given to the information that needs to be recorded on containers, for example, product or ingredient title, ingredient batch code and expiry
date.
The system must also ensure that products supplied to customers are adequately labelled or identified to help traceability. For instance,
in the event of a customer complaint, the company can use the information on the consumer’s packet to effectively identify the implicated
batch and trace the product to the specific batches of any implicated raw materials.
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4.0 Traceability Testing
4.1 Why test the traceability system?
The aims of testing the traceability system on a regular basis (at least annually or more frequently if there are product claims) is to:
• Demonstrate whether the system does or doesn’t work
• Highlight any gaps in the system which would make the company vulnerable in the event of a genuine issue, therefore giving you an
opportunity to improve the system
• Ensure the required information can be collated quickly (i.e. less than four hours)
• Ensure that the system works in both directions i.e. from raw material supplier to customer and from customer to raw material supplier
4.2 How to test the traceability system
To carry out a traceability check, you should select a specific batch of product. For example, select a product from a customer’s store by
choosing a product with a provenance claim from the warehouse or from historical production records. Company records should then be
used to follow the specific batch of product backwards starting with dispatch to customers, through each step of production to receipt of
raw materials.
Copies of all documents should be collated during the test and kept as evidence of completion, along with an action plan for carrying out
any changes that the test identifies.
The traceability test should be completed in both directions. So your site should also select a batch of raw material and follow its use from
receipt through manufacture, to the delivery in final products to customers.
You will also need to complete a quantity or mass balance check. This is basically a traceability test but assessing the quantities of
material i.e. assessing how much finished product was manufactured and ensuring this matches the amount of raw material used.
During the BRC audit, the auditor will complete a full vertical audit which will include a test of the traceability system and associated
production paperwork such as weigh-up records, CCP records or metal detector checks. Where the site has a provenance or assured
product claim, a mass balance audit.
The BRC has produced a full length Best Practice Guideline to Traceability, which is available from The BRC Bookshop at www.brcbookshop.com.
Quick Tips
• Ensure everything is adequately (fully) labelled at all stages of the process
• Complete routine tests of the traceability system and ensure any corrective action is captured and implemented
• Ensure information is retained in a readily accessible format
These short guides are designed for companies involved in the enrolment program and aim to help you interpret the Standard, and design
robust systems and procedures that meet the requirements. Examples are given to explain the types of documents and procedures and
the level of detail typically required. However, you’ll need to consider the context relevant to your business. The implementation of the
Standard, and whether a resulting system is considered to be conforming or non-conforming by an auditor, is an objective judgement
which can only be based on the evidence collected and observations made during the audit.
Further details regarding the BRC Global Standard for Food Safety can be obtained from enquiries@brcglobalstandards.com
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Appendix 1: Example checklist for a traceability test
It’s good practice for you to have a checklist of documents to use during the traceability test so delays and omissions are avoided.
The example below is not an exhaustive list, as the exact documents will depend on the processes operated by your site.
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