You may find yourself in an evaluation or verification audit being told about your traceability requirements and getting quite confused as to what you need to do, and why you need to do it. You are not alone.
I’m not saying I’m confused. I’m not saying the verifier is confused. Well, actually we are, but that’s not the point. What I am really referring to here is that MPI, the organisation making and / or interpreting the rules, are confused. Here’s how it goes.
One department of MPI reads the law and produces guidance on how we as food businesses need to operate. They are the guys you will speak to on the phone if you can ever get through and get to the right person. To cut a long story short, I generally agree with these guys and can usually get a decent answer out of them.
There is another department that will receive your Custom Food Control Plan after it has been evaluated and they have to register them. They essentially re-evaluate them. I don’t think this was ever the intention of this team, but this is how things have panned out. So you need to write your plan in a way that will please both this team, and your evaluator (and usually the evaluators boss as the work needs to be peer reviewed).
Are you following? Here is the tricky bit. There is a team that assesses the assessors. They go out to evaluations and check that the Evaluators are doing a good job. The big problem is that this team interprets the rules completely differently to the team at MPI that answers the phone.
MPI had no idea this was happening till I bought it to their attention. They have now had a meeting between the teams and my understanding is that not much has changed and the two sides have agreed to disagree for now.
I’m pushing this battle further and further as it relates to the interpretation of traceability. If traceability is based on risk assessment then the amount of work required will be based on the level of risk, which is often low. If every small business needs to comply to the highest level of 100% reconciliation of ingredients and finished goods, then we as an industry will need to be hiring a lot more people to cover these compliance requirements.
Have you read this article and scratched your head and realised you weren’t as confused as you should be? We fight hard for our clients to keep their compliance costs down, this issue regarding traceability is just one way in which we are doing it. In this case, it is a single person’s interpretation of the law that is creating huge amounts of work for some companies, and we think this is unacceptable.
