Traceability Procedure

Maintain a continuous link from supplier to customer

The traceability system connects incoming raw-material and primary-packaging identifiers with internal batch, mix or process identifiers, finished-product batch or lot and date codes, and dispatch records showing which finished-product batches or lots were supplied to each customer.

Defined traceability points cover goods receipt, storage and issue to production, batching, mixing and processing, packing and labelling, and dispatch, as applicable. The procedure accommodates both computerised and paper-based systems, provided the required linkages are created and maintained through controlled transactions or records.

This structure supports backward traceability from finished product to all constituent raw materials and packaging, and forward traceability from raw materials and packaging to finished products and customer dispatch.

Preserve identity through processing, splitting and rework

Unique batch, lot or production identifiers are assigned, recorded and transferred between stages so material identity remains preserved or appropriately linked when materials are split, combined, reworked or further processed.

For intermediate and work-in-progress materials, the procedure requires traceability records to maintain the relationship between input identifiers, processing or batching activities and the output materials generated at each relevant stage. Where material or product is decanted, split, part-used, re-packed or otherwise removed from its original packaging, identification must preserve the original lot or batch linkage and associated status.

Rework is treated explicitly: where reworking takes place, the traceability record must link the reworked material to its source batch or batches, the point at which the rework was generated and the finished-product batch or batches into which it was incorporated.

Link receipt and dispatch records to the complete product history

Raw materials, including primary and secondary packaging, remain traceable from receipt through to their use in intermediate and finished products. Receipt records identify the supplier and delivery details, quantities, batch or lot codes and the point at which materials enter production.

At the finished-product end of the chain, records identify the finished-product batch or lot, quantity, production date and associated processing information. Dispatch records then link finished-product identifiers to customer deliveries, with applicable information including quantity dispatched, customer identification, dispatch date and delivery or transport-document references.

The resulting record chain is designed for timely retrieval when traceability information is needed, including for traceability verification and to support incident, withdrawal or recall activities governed by the separate incident-management procedure.

Meet the four-hour traceability requirement

The procedure requires the internal traceability system to determine product history accurately within four hours of initiation using records created during normal operations. It also requires the system to meet the legal traceability requirements of the country of sale or intended use.

The four-hour requirement applies not only to routine capability but also to planned traceability testing, giving technical and quality teams a defined performance criterion against which retrieval and linkage can be evaluated.

Verify traceability in both directions and reconcile quantities

System effectiveness is verified through planned traceability tests at a predetermined frequency, at least annually. The tests cover the range of product groups manufactured at the site and demonstrate traceability in both directions: from finished product back to raw materials, including primary packaging, and from raw materials forward to finished products and dispatch.

Testing includes a quantity check or mass balance for food raw materials and finished products, together with printed packaging and labels carrying food-safety and legal information. Each exercise also includes a documented summary of the records and documents referenced and clearly shows the links used to establish traceability through receipt, processing and dispatch.

Technical or quality management evaluates test outcomes against the traceability objectives. Where deficiencies or failures are identified, they are recorded and addressed to restore the effectiveness of the traceability system.

Keep traceability effective through controlled change

Traceability arrangements are reviewed and maintained when changes to products, processes, materials or systems may affect traceability. Changes that do affect the system are implemented in a controlled manner so continuity of product history and data integrity are maintained.

The procedure also requires traceability identification and records to remain sufficient for part-used materials, work in progress and materials or product pending investigation, so their status and links to relevant batches and processing stages remain clear and retrievable.

Allocate ownership across management and operations

Senior management is responsible for providing the resources needed to establish, implement and maintain the traceability system and for reviewing its effectiveness as part of wider FSQMS oversight.

Technical or quality management establishes and maintains the internal system, defines traceability points, record linkages and data-integrity controls, plans and evaluates traceability tests, and follows up identified deficiencies. Production and operations management implements the requirements within operational processes and supports testing, while employees follow the requirements relevant to their roles, complete required records accurately and report issues that could compromise traceability integrity or effectiveness.

Connect traceability with records and incident response

The procedure defines the traceability mechanism while preserving clear boundaries with related controls. Record completion, control and retention are governed by the Record Completion & Maintenance Procedure, and incident management, product withdrawal and recall execution are governed by the separate Incident Management, Product Withdrawal & Recall Procedure.

Within those boundaries, the Traceability Procedure provides the product-history and distribution information that must be accurate, reliable and retrievable when verification, investigation or response activities require it.