Traded Products Traceability Procedure

Maintain batch or lot identity from receipt to supply

Traded products are incorporated into the site traceability system established under the Traceability Procedure. Within that framework, the procedure requires product identification to remain linked to receipt and dispatch information, with batch or lot identity preserved against the applicable supplier, receipt record and recipient.

The document distinguishes between information held internally and information that may need to be obtained from a supplier or other external party. Where the identity of the last manufacturer, packer or place of last significant change is held internally, it must remain linked to the applicable batch or lot. Where it is not held internally, the retained batch or lot and supplier information must be sufficient to obtain the required upstream information when traceability is exercised.

That distinction is important for traded products because the company may not hold the full upstream manufacturing or movement history at the point of receipt. The procedure therefore defines the link that must be preserved internally, while giving Technical / Quality Management responsibility for determining whether the available or externally obtained information is sufficient to demonstrate the required upstream traceability.

Show where each supplied quantity went

Forward traceability is developed through dispatch and customer records that preserve a batch- or lot-specific link to the recipient of each quantity of traded product supplied by the company.

Where a batch or lot is divided between more than one recipient, the retained identification and dispatch information must remain sufficient to determine which quantity was supplied to each recipient. This keeps the downstream trace specific to the affected quantity rather than treating the batch or lot as a single undivided movement after receipt.

Test upstream, downstream and movement traceability

The procedure requires traded-product traceability testing in addition to traceability testing for raw materials and products manufactured by the site. Completion of one type of traceability test does not replace the other, so traded products receive their own annual test within the site traceability programme.

The selected traded-product batch or lot is traced back to the last manufacturer or, for a primary agricultural product, to the packer or place of last significant change. It is also traced forward to the recipient or recipients supplied by the company. Where information needed for the backward trace or complete movement history is not held internally, the procedure provides for the required information to be obtained from suppliers or other relevant external parties.

The test also covers product movement from manufacturer to receipt by the company, including intermediate movements and places of storage where these form part of the supply route. By including movement history as well as upstream and downstream identity, the procedure tests more than the presence of a supplier name or customer dispatch record.

Reconcile quantities and evaluate completion time

Quantity reconciliation is a defined part of the traded-product traceability test. The quantity received for the selected batch or lot is reconciled against quantities supplied to recipients and any quantity remaining under company control. Technical / Quality Management evaluates any unexplained difference before accepting the reconciliation as satisfactory.

The procedure also sets different completion-time expectations depending on where the required information is held. Where all information needed to complete the test is available internally, the required traceability should be achievable within four hours. Where completion depends on information that is not available internally and must be obtained from an external party, the required traceability should be achievable within one day.

This preserves a practical distinction between internal retrieval capability and externally dependent traceability. The one-day allowance applies only where completion of the test depends on information that is not available internally.

Define responsibility for traceability control and judgement

Responsibility is allocated across the functions that maintain, use and evaluate traded-product traceability information. Senior Management provides the resources and organisational support needed to maintain and test the system and to obtain traceability information from internal and external sources when required.

Technical / Quality Management establishes and maintains the traded-product traceability controls, evaluates annual test results, determines whether internal or externally obtained information demonstrates the required upstream link, assesses unexplained reconciliation differences and initiates corrective and preventive action where the traceability system fails to demonstrate the required elements.

Production / Operations Management implements the requirements within receipt, storage and dispatch activities, maintaining the link between batch or lot identification and the applicable supplier, receipt and recipient information while product is under company control. Employees are required to follow the traceability requirements relevant to their roles, maintain identification and traceability information assigned to their activities and report any loss of traceability or issue that may prevent a traded-product batch or lot from being traced as required.

Control traceability failures through the correct FSQMS interfaces

The procedure does not recreate the site’s non-conforming product or corrective-action processes, but it clearly defines when those interfaces are used. Where traceability cannot be demonstrated for a traded-product batch or lot under company control, the affected product is identified and controlled as non-conforming product in accordance with the Non-Conforming Product Control Procedure.

Where the inability to demonstrate traceability results from a failure or weakness in the traceability system, or where a traded-product traceability test does not demonstrate the required elements, Technical / Quality Management initiates corrective and preventive action in accordance with the Corrective & Preventive Action Procedure.

Records generated through the procedure may include traded-product batch or lot traceability records, supplier and receipt information, dispatch and customer traceability records, externally obtained traceability information, product movement and intermediate storage information, quantity reconciliation records and traded-product traceability test evaluation records. Those records provide the evidence base for reviewing whether the required upstream links, downstream links, movement history, reconciliation and completion-time expectations have been demonstrated.