I am trying to interpret clause:
3.9.1: Identification of raw materials, including primary and any other relevant packaging, processing aids, intermediate/semi-processed product, part-used materials, finished products and materials pending investigation shall be adequate to ensure traceability.
The interpretation guide says, "The traceability system needs to include primary packaging (in direct contact with food), other relevant packaging materials (such as printed outer packaging) and processing aids..."
The part I'm stuck on is "other relevant packaging." What is considered relevant packaging? If I have a box that is lined with a poly bag and the product goes in the bag, is the box relevant packaging? We cook some products in sleeves. These sleeves are crimped with metal clips. The clips do not come in contact with product. Are these clips relevant packaging? We use some pre-printed consumer boxes. Are these considered relevant packaging?
As far as processing aids go, we use liquid nitrogen to freeze product. We have bulk tanks for this and obtain certificates of food grade suitability. However, we cannot lot track the liquid nitrogen. If a risk assessment is completed and I show there are no recalls for food safety issues surrounding liquid nitrogen, is that enough to not lot track this?
Any help interpreting this clause would be helpful.