TRACEABILITY

CONDUCTED BY (Name & Designation)

REASON FOR TRACE EXERCISE

REVERSE TRACE RESULT

FORWARD TRACE RESULT

EVIDENCE

NOTES / ACTIONS / DEADLINES / RESPONSIBLE OFFICER

It is a mandatory requirement all entrants to the Food Production Unit understand and abide by all of FERA LTD Policies & Procedures.

DOCUMENT NAME	3.3 Traceability
Document Reference Number	3.3
Document Sub-Sections	3.3.1a Food Traceability Procedure 3.3.2a All Raw Ingredients And Food Products Are Checked To Ensure Labelling Is Accurate And Applied As Part Of Housekeeping 3.3.2b Procedure And Steps To Facilitate Robust Food Traceability 3.3.2c Data Capture Forms To Ensure Documentation Of Traceable Information 3.3.2d Mass Balance Monitoring 3.3.3a Forward And Reverse Traceability Testing Procedure 3.3.3b Mock Traceability Exercises 3.3.3c Formal 'Real-World' Traceability Exercises
Issue Number	1.0
Issue Date:	05/01/2024
Last Reviewed Date	05/01/2024
Reviewed by	Board of Directors
Next Review Date	Annualised 05/01/2025 (Earlier if any significant changes made or required).
Responsible Officer(s)	Board of Directors
Distribution	Accessible and distributed to all staff Accessible via FERA intranet or available upon request.
Storage	Stored on the intranet.
Document Control	Uncontrolled Copy Unless Printed on Yellow Signed Paper or accessed on intranet.
Amendments with date of amendment.	Nil
Document Notes	Nil
Intranet Link	3.3 Map (Traceability) \| INTRANET I Fera
Authorised by	Adeel Iqbal

3.3.1a FOOD TRACEABILITY PROCEDURE

FERA Ltd has a proven ability to identify and trace all raw materials, including food contact packaging, from suppliers through all stages of production to the point of dispatch and, where appropriate, delivery to known customers and vice versa.

Tracebility Test Frequency

Traceability is tested each way at least annually and more frequently if there are known risks in the supply chain.

3.3.2a ALL RAW INGREDIENTS AND FOOD PRODUCTS ARE CHECKED TO ENSURE LABELLING IS ACCURATE AND APPLIED AS PART OF HOUSEKEEPING

We ensure all products including raw materials, interim products and completed products are fully labelled as part of housekeeping checks.

This is intended to ensure that we can fully trace all ingredients, food contact packaging, interim products and finished products, so that they can be easily identified in the case of a product withdrawal or recall.

We have robust digital systems in place to trace all raw materials, re‐work, semi‐processed products and food contact packaging, throughout all stages of production, processing and distribution.

All key information about each product is recorded to help with this process. This includes the product’s specification, batch code, location, quantity, suppliers and dispatch information.

Information Recorded to facilitate traceability

List of suppliers and materials supplied by them

List of customers and products bought by them

A system of clear labelling for food ingredients, re‐work, semi‐processed products and food contact packaging. Records capture detailsof all goods delivered such as product, supplier, batch code, best before date, quantity etc. by using a digital ‘Goods In’ form’ which serves as a database. This information can also be downloaded into a spreadsheet.

Dispatch records are kept including recording of finished product batch codes.

We have a standard batch code system which operates on all products and can be easily cross-referenced from source to purchaser.

3.3.2b PROCEDURE AND STEPS TO FACILIATE ROBUST FOOD TRACEABILITY

Procedure to faciliate traceability

Record batch codes on arrival

Make sure ingredient batch codes are clearly visible before putting away

Label ingredients once they are out of their original packaging

For ‘continuous’ processes, identify what constitutes a traceable ‘batch’ for potential quarantine or recall

Re‐work or semi‐processed products need to be clearly identified so they can be traced as well

Test systems regularly, and at least annually.

Keep records of the tests and if a system ‘didn’t work’ then take Corrective

Action and re‐test the system at a later date to see if the changes worked

By using this system we are able to, in the event of incidents, promptly inform customers of potential danger and can also internally place relevantbatches on ‘hold’until notified and quarantine such batches. This is to lower the risk of harm to consumers, damage to our business’s reputation and potential legal issues.

3.3.2c DATA CAPTURE FORMS TO ENSURE DOCUMENTATION OF TRACEABLE INFORMATION

By having a detailed ' GOODS IN' procedure, detailed 'PRODUCTION SHEETS' and detailed 'GOOD OUT OR DISPATCH' forms we are able to easily track the transition of materials forward and reverse.

Data Capture Forms	Links
GOODS IN FORM	1.6.3 Goods In Form \| INTRANET I Fera
PRODUCTION SHEETS	3.3.3(i): Production Sheets Overview \| INTRANET I Fera
GOODS OUT FORM	1.12.2 Goods Out & Dispatch Records \| INTRANET I Fera

3.3.2d MASS BALANCE MONITORING

We ensure that we are able to account for 100% of raw materials through to finished products, net of normal production yields.

Domains Addressed at Mass Balance
Traceability	To account for all raw materials forward and reverse as well as account for discarded, quarantined and contaminated products.
Food Fraud	To prevent adulteration, substitution and food fraud we ensure that we and our suppliers are able to prove that the designated ingredients purchased were sufficient to manufacture the quantity of finished productthat you sold.

3.3.3a FORWARD AND REVERSE TRACEABILITY TESTING PROCEDURE

A procedure is documented and tested for both forward and reverse traceability.

FORWARD TRACE TESTING
1	Start from a hypothetical warning from a supplier or source regarding a randomly selected raw material
2	Ascertain key information regarding product name, expiry and batch number
3	Search goods in records to see if product entered site
4	If affected material / product did not enter site, end of exercise
5	If affected material / product did enter site, search production records
6	Check to see how many items the product was used in and record
7	View batch numbers generated of those products in which the affected material was used
8	Check dispatch records – if batch numbers do not appear in the dispatch notes, this suggests affected materials has not been sent to the public domain and remains on site.
9	Search for all affected materials, quarantine and discard & assess for cross-contamination risk
10	If affected material appear on dispatch records, search all clients / customers / consumers that received the affected products and issue recalls.

REVERSE TRACE TESTING
1	Start from a hypothetical complaint regarding a random product from a client or consumer
2	Indicate a hypothetical fault with a component of the product
3	Trace that component back to source
4	Ascertain key information regarding product name, expiry and batch number
5	Access the dispatch records and use the batch number of the affected product to determine key information
6	Determine the batch number of the affected ingredient
7	Search production records to see where this batch of ingredient was used
8	Search the goods in sheet to see when, where and from which supplier the batch was obtained
9	Take corrective actions / inform supplier of issue

3.3.3b MOCK TRACEABILITY EXERCISES

Traceability is tested each way at least annually and more frequently if there are known risks in the supply chain.

DATE	CONDUCTED BY (Name & Designation)	REASON FOR TRACE EXERCISE	REVERSE TRACE RESULT	FORWARD TRACE RESULT	EVIDENCE	NOTES / ACTIONS / DEADLINES / RESPONSIBLE OFFICER
20 January 2024	Adeel Iqbal (Director)	Mock Test Exercise	PASS	PASS		Repeat within 1 year

3.3.3c FORMAL 'REAL-WORLD' TRACEABILITY EXERCISES