BRCGS Finished Goods Traceability

I am a tech PM working on implementing a manufacturing system at an olive oil processing facility. The system they are currently using was created in-house and we are moving them to Infor M3.

They are telling us that the level of traceability that the new system provides is not sufficient because it does not include finished good transfers from one tank to the next. There is no blending or additional inputs conducted during the transfer but they insist that it's required for BRC certification because of environmental factors. 

We would be forced to create a custom report to provide them with this detail but I don't know if it's actually a certification requirement or just the way they built the in-house system? Is there someone who can help me verify if this is actually a requirement? Happy to provide more details.

BRC is rarely that prescriptive - there is an overarching 'fundamental' requirement for the following:

 

The site shall be able to trace all raw material product lots (including primary packaging) from its suppliers through all stages of processing and dispatch to its customers and vice versa.

I think you'd struggle to argue that a storage tank was not part of the that fairly broad requirement. And in general I also think it's probably quite reasonable for the site to want this. Consider e.g. doing a routine inspection and finding that a seal has deteriorated on a tank connection and generated a load of potential foreign bodies - if the site cannot identify which batches have passed through that tank, their only other option is probably going to be to quarantine/withdraw/recall every single batch produced since the last clear inspection of that seal.

FWIW my experience of BRC audits in sites with liquid handling / storage tanks over the years has been that every single one has asked to see various records (e.g. cleaning, inspection, evidence of food grade status for seals etc) linked to the specific tank(s) used for the batch selected for the trace exercise, so I can very much understand why the site would want this from an audit perspective.

Greetings,

Post #2 is right, but if you take it up to their explanation, then there is no requirement that connects traceability to environmental "factors", even if they mean environmental monitoring.

As pHruit mentioned though tank transfers should also be traceable.

Regards!