Module 3 Bacon & Gammon
7 Traceability and mass balance
Last Updated: 7 Jan 2022.
7.1 Labelling for traceability & mass balance
All pork raw material shall be identified as BMPA Quality Assured Pork or “BQAP” by labelling of the rack, chandelier or other transport medium.
Each batch of pork raw material to be used for the manufacture of any BMPA Quality Pork Charter products shall be marked or labelled with the following information as a minimum:
- Site identification code (health mark)
- Product description
- Traceability batch code
- Confirmation of assured status
- Country of birth, rearing and slaughter or statement of pigs’ origin
- Date of freezing (if frozen)
- Durability / process-by date
- Date of kill
Visual inspection of labelling of the transport medium, outer case and/or retail pack.
7.2 Traceability and mass balance audits
7.2.1 The Charter participant shall carry out 4 mass balance and 8 traceability audits during the certification year. The schedule mayconsider the mass balance requirements specified within BRC GFS.
7.2.2 All Charter participants shall ensure that they have a documented system and schedule for challenging traceability and mass balance of all assured pork raw material, work in progress material (WIP), rework and finished products and that these are clearly identified with assured status at each stage of the process from intake through to dispatch. The system shall facilitate both forward and backwards traceability and mass balance of both assured and non-eligible pork raw material by the conclusion of the Charter audit and that mass balance shall include any wastage and processing yield losses to account for the full batch to be completed within an accuracy of not less than 95% and not greater than 100% accountability. It shall include all forms of assured pork material used in the product i.e. rind, added back fat etc.
7.2.3 When completing traceability back to farm, 3 slap marks from 3 separate producers from the same kill date shall be checked against the pig producer’s animal movement licence. Verification of the slap mark or ear tag shall include the assured status of the farm, livestock vehicles and where applicable, assured collection centres using the relevant assurance checker.
7.2.4 The Charter participant shall have a sampling plan for the traceability and mass balance audits that include all the products approved by each module of the BMPA Quality Pork Charter and a minimum one product per month shall be challenged.
7.2.5 Traceability and mass balance audits shall be carried out by a competent, trained individual who is independent of the manufacturing operation. For further guidance, refer to the BMPA Quality Pork Charter rules appendix 3 ‘Competency and independence of internal/external auditors undertaking traceability and mass balance audits’ and appendix 4 ‘Traceability and mass balance guidance’.
7.2.6 Documentary evidence containing a summary of each traceability and mass balance exercise shall be maintained to demonstrate that the requirements of the Quality Pork Charter are being met.
7.2.7 Where a non-conformance is raised for traceability and mass balance exercises, records shall detail evidence of root cause analysis and corrective action.
7.2.8 Charter participants shall carry out a risk assessment at least once during each certification year to verify that the traceability systems and procedures are robust and effective for the identification and traceability of all pork materials.
Traceability checks are carried out to verify the assured supply chain and mass balance checks may be carried out on part of the process and may include non-eligible products. Product identification shall facilitate both backwards and forwards traceability i.e. from which batch did it originate and within which batch(s) was it used.
See below an example of a suggested schedule. The mass balance and traceability exercises carried out during a BRC GFS and BMPA Quality Pork Charter surveillance audit may count towards this requirement.
|April||BRC annual mass balance||On BMPA quality assured product (incorporating a backward trace to farm and a forward trace from raw material intake to finished product)|
|May||BMPA backward trace to raw material intake||On BMPA quality assured product|
|June||BMPA forward trace from raw material intake to finished product||*On non-eligible product|
|July||BMPA forward mass balance from raw material intake to finished product||On BMPA quality assured product (incorporating a forward trace from raw material intake to finished product)|
|August||BMPA backward trace to raw material intake||On BMPA quality assured product|
|September||BMPA forward trace from raw material intake to finished product||*On non-eligible product|
|October||BRC provenance mass balance||On BMPA quality assured product (incorporating a backward trace to farm and a forward trace from raw material intake to finished product)|
|November||BMPA backwards trace to raw material intake||On BMPA quality assured product|
|December||BMPA forward trace from raw material intake to finished product||*On non-eligible product|
|January||BMPA forward mass balance from raw material intake to finished product||On BMPA quality assured product (incorporating a forward trace from raw material intake to finished product)|
|February||BMPA backward trace to raw material intake||On BMPA quality assured product|
|March||BMPA forward trace from raw material intake to finished product||*On non-eligible product|
In seeking compliance, objective evidence shall be aligned to the following sub clauses:
- Clauses 7.2.1, 7.2.2, 7.2.3, 7.2.6 Review traceability and mass balance reports since the last audit.
- Clause 7.2.4 review sampling plan.
- Clause 7.2.5 verify independency and competency of the auditor undertaking the traceability and mass balance checks.
- Clause 7.2.7 Where non-conformance has been raised by the independent auditor review evidence of root cause analysis, corrective action and monitoring.
- Clause 7.2.8 Copy of risk assessment.