Last Update: 18 Aug 2022.

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5.2 Traceability and mass balance audits

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Quality Assured Pork / Traceability and mass balance

5.2.1 The charter participant shall carry out 4 mass balance and 8 traceability audits during the certification year. The schedule may consider the mass balance requirements specified within BRC GFS.

5.2.2 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.  See Appendix 1 of this module for a traceability audit form template.

5.2.3 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 license. 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. 

5.2.4 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. 

5.2.5 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’.

5.2.6 Documentary evidence containing a summary of each traceability and mass balance exercise shall be maintained to demonstrate that the requirements of the pork charter are being met.

5.2.7 Where a non-conformance is raised for traceability and mass balance exercises, records shall detail evidence of root cause analysis and corrective action. See Appendix 1 of this module for a traceability non conformance report form template.

5.2.8 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.

Guidance

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:

MonthScopeBasis
AprilBRC 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) 
MayBMPA backward trace to assured farmOn BMPA quality assured product 
JuneBMPA forward trace from raw material intake to finished product*On non-eligible product 
JulyBMPA forward mass balance from raw material intake to finished productOn BMPA quality assured product (incorporating a forward trace from raw material intake to finished product)
AugustBMPA backward trace to assured farm On BMPA quality assured product
SeptemberBMPA forward trace from raw material intake to finished product*On non-eligible product
OctoberBRC 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)
NovemberBMPA backwards trace to assured farmOn BMPA quality assured product
DecemberBMPA forward trace from raw material intake to finished product*On non-eligible product
JanuaryBMPA forward mass balance from raw material intake to finished productOn BMPA quality assured product (incorporating a forward trace from raw material intake to finished product)
FebruaryBMPA backward trace to assured farmOn BMPA quality assured product
MarchBMPA forward trace from raw material intake to finished product*On non-eligible product
*Note – sites that do not handle non-eligible material shall carry out the required mass balance and traceability exercises on BMPA quality assured products)

Evidence

In seeking compliance, objective evidence shall be aligned to the following sub clauses:

  • Clauses 5.2.1, 5.2.2 and 5.2.5 Review traceability and mass balance reports since the last audit. 
  • Clause 5.2.3 Rreview sampling plan. 
  • Clause 5.2.4 Verify independency and competency of the auditor undertaking the traceability and mass balance checks.
  • Clause 5.2.6 Where non-conformance has been raised by the independent auditor review evidence of root cause analysis, corrective action and monitoring.
  • Clause 5.2.7 Copy of risk assessment.