Appendix 3 Guidance for traceability & mass balance audits

1.1.1 Types of audits – There are three types of traceability audit, which may be carried out on either chilled or frozen product (where applicable).

• Forward trace of non-eligible product which may comprise primal, consumer packs, bulk packs or whole carcases
• Forward trace of assured product which may comprise primal and bulk packs 
• Backward trace of assured product which may comprise primal, consumer packs, bulk packs, or assured product e.g. the assured bacon and pork sausage used in pigs in blankets

1.1.2 Documentation – The auditor shall use appropriate documentation to record the traceability audit information in electronic format. 

The scope of a forward trace of non-eligible products audit covers All BMPA Quality Pork Charter modules

1.2.1 Objective – The objective of the forward traceability exercise shall be to verify that non-eligible raw material has been correctly processed and labelled in accordance with the BMPA Quality Pork Charter. Non-eligible raw material shall be defined as:

• Pork raw material from pigs that have not met the requirements of the BMPA Pig Welfare and Slaughter module (i.e. pigs that are not born and reared for their lifetime on an assured farm that is certified by Red Tractor, Quality Meat Scotland Pigs or an equivalent farm assurance scheme recognised by the BMPA) 
• Boars with a slaughter weight in excess of 110kg.
• Sows may only be used for the manufacture of comminuted meat preparations approved by the BMPA pork scheme e.g. sausage, providing that the pork complies with all aspects of the BQAP product quality standards with the exception of the P2 measurement. Any other use is not permitted within the BMPA pork scheme.
• Pork raw material processed under the Red Tractor or Quality Meat Scotland pork schemes

1.2.2 Selection of product – The auditor shall be responsible for the selection of the product. Product selected for the trace exercise shall be from a previous production date to allow the product to have been processed through to dispatch. The consignment shall be confined to a discrete batch. This shall be interpreted as single pallet, dolav or batch size aligned to the site’s traceability system, aligned to the current audit observations or previous site history. 

The auditor shall have the discretion to select a larger quantity of product for the trace exercise. The charterparticipant shall be required to present all traceability information and weight calculations aligned to the traceability exercise for review. It is important that the information recorded can be cross referenced to the corresponding trace documentation presented by the site. 

There is no requirement to copy sensitive commercial information unless the information is required to support non-conformance. Any copying of sensitive commercial information shall be agreed by the charter participant.

The scope of the backward trace on BMPA quality assured products audit covers the following modules:

• BMPA Quality Assured Pork 
• BMPA Quality Assured Bacon and Gammon
• BMPA Quality Assured Ham and Cooked Pork
• BMPA Quality Assured Pork Sausage

1.3.1 Objective – The objective of the backward trace shall be to verify that incoming assured pork raw material/pork meat products is sourced from a participant of the BMPA Quality Pork Charter, and that the supplier holds a valid BMPA Quality Pork Charter certificate of conformity. It shall be sufficient for the assured backward trace to be verified to the point of intake at the site.  There is no requirement for the backward trace to be verified back to farm. However, to maintain traceability, all pork carcases and raw material shall be accompanied by clearly marked delivery documentation which confirms its assured status and country of birth, rearing and slaughter or statement of pig’s origin. 

Where pigs are born, reared and slaughtered in one country, a single statement of origin shall be sufficient for the traceability declaration. For co-located abattoirs with cutting and packing facilities, the objective of the backward trace shall be to verify that pork raw material is derived from pigs, which have been certified by Red Tractor, Quality Meat Scotland-Pigs or an equivalent farm assurance scheme recognized by the BMPA. 

1.3.2 Selection of product – The auditor shall request to see a copy of the participants’ current BMPA Quality Pork Charter certificate of conformity. Only products that are listed on the BMPA Quality Pork Charter certificate of conformity shall be deemed to be approved. The auditor shall be responsible for the selection of the product for the backward trace. The sample shall comprise a single sample of finished product. Finished product at some sites may be product that is to be despatched to another site for further processing/final packing.

For BQAP, dependent on the scope of the site’s processes the auditor shall choose a use-by date, date of packing or kill date. From the corresponding kill sheet, the auditor shall randomly select three different pig suppliers and verify the status of the haulier, collection centre, country of birth and farm assurance. Where pigs are born, reared and slaughtered in one country, a single statement of origin shall be sufficient for the traceability declaration. The animal movement document shall be included in the backward trace.

Product selected for the trace shall be taken from a different production date and not from product manufactured on the day of the audit unless the surveillance audit is unannounced.  The auditor shall request that all relevant trace information is presented for review. It is important that the information recorded can be cross referenced to the corresponding trace documentation presented by the site. 

There is no requirement to copy sensitive commercial information unless the information is required to support non-conformance. Any copying of sensitive commercial information shall be agreed by the scheme participant. 

A forward mass balance audit shall be undertaken on assured product. A mass balance or quantity check is generally defined as a reconciliation of the amount of incoming raw material against the quantity of finished product taking into account process waste and rework. The finished product shall be aligned to the scope of activities of the pork module under audit. Finished product shall have a different interpretation for an abattoir/cutting plant operation as opposed to a site that that undertakes finished packing of processed product e.g. BMPA quality Assured Ham and Cooked Pork, Bacon or Sausage. 

The scope of mass balance audits covers All BMPA pork modules (including external cold stores)

1.4.1 Objective & frequency – The overarching objective of a mass balance exercise shall be for the site to demonstrate through their traceability systems, procedures and control of operations that the quantity of assured finished product does not exceed the quantity of received assured pork material. The frequency of the mass balance audits shall be aligned to the requirements of the pork module.

1.4.2 Principles of mass balance – It is recognised that manufacturing operations differ; therefore, charter participant may have developed systems for undertaking mass balance specific to the type of operation. The following principles are therefore for guidance only:

Prior to instigating a mass balance challenge the auditor shall take into consideration the complexity of the operations of the site and a reasonable and acceptable volume of product to be challenged. 

• Select a batch or consignment of assured product
• Identify the quantity of assured product supplied with that batch code
• Identify all the final products in which the assured material was used
• Use production records e.g., production planning records, butchery records, recipes, weigh out records to calculate the quantities used
• Account for any known waste, yields reports, residuals or rework
• Calculate the quantity of any unused material held in storage
• Reconcile the quantity delivered against the amounts used including any residual stock unused
• The target for the reconciliation of weight shall fall within the range of 95 to 100%.

1.4.3 Recommended time for reconciliation of data – It is expected that a mass balance challenge shall be completed by the conclusion of the day’s audit.  Where a site is unable to complete the mass balance challenge within the recommended time, a non-conformance shall be raised.

1.4.4 Recording calculations and data – All calculations relating to the mass balance challenge shall be prepared in electronic format by the site and presented for review to the auditor.  The report shall be included as an appendix to the mass balance audit report. See example below, mass balance may be done by both weight and count or a combination of both.

1.4.5 Examination of financial records – The BMPA Quality Pork Charter rules stipulate that a charter participant shall make readily available on request to the auditor, financial records of the company that shall be deemed appropriate where issues have occurred and specifically related to the purchase of pork material. 

The rationale to undertake an examination of the financial records shall be to verify the quantity of pork material purchased against quantity of finished product.  Where an examination of the financial records is undertaken, the auditor shall prepare a short summary report.  In compiling the summary report, the auditor shall make every effort not to compromise the scheme participant’s confidentiality.

1.4.6 Mass balance as part of internal risk assessment – The expectation concerning the annual risk assessment of the participant’s traceability system and procedures is to evaluate the robustness of both product identification, forward and backward traceability and mass balance at each step of the process from intake through to dispatch, and the consequence and corrective actions to be taken if the capability to identify and trace product is lost. (A process flow diagram would ensure that each touch point for traceability is assessed). It should also include a review of the trace and mass balance audits carried out in the previous 12 months, providing evidence of whether the system is effective or not. Evaluation of any non-conformances previously raised, root cause analysis, and corrective actions taken, should take place. This review should highlight any long-term developing trends and thus provide early opportunity for intervention.