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How the product recall and withdrawal procedure should be tested?


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#1 Betty8

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Posted 28 February 2011 - 01:32 PM

Hi.

Can anybody give we idea how the product recall and withdrawal procedure should be tested ? Is it not the same what traceability exercise? Ok I can imagine possible reason for recall and what then. It's gathering information like batch numbers, raw materials identification, customers info etc. generally all what we do for traceability anyway. So what's the difference between testing recall and traceability exercise. How you testing recall procedure?



#2 Zeeshan

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Posted 01 March 2011 - 05:42 AM

Hi.

Can anybody give we idea how the product recall and withdrawal procedure should be tested ? Is it not the same what traceability exercise? Ok I can imagine possible reason for recall and what then. It's gathering information like batch numbers, raw materials identification, customers info etc. generally all what we do for traceability anyway. So what's the difference between testing recall and traceability exercise. How you testing recall procedure?



Not an expert but I'll try to explain what I understood after getting some information on the subject.

The objective of testing recall/withdrawal procedure is to test/estimate the capability of the organization as a whole how much time it would use and how much area of distribution it may cover in case of actual emergency situation of recall.

This drill also enhance the confidence-level in the designated withdrawal/recall team of the organization and also in the Top/Senior Management to face any actual emergency situation.

Looking at the differences between recall and traceability exercises:
- The significant outputs of testing recall are (1)-possibly retrievable QUANTITY and (2)-maximum TIME consumed in tracing that quantity.
- The out put of backward traceability exercise is is testing the capability of organization in getting correct information about supplier/producer/manufacturer of a particular or selected raw material(s).
- The output of forward traceability exercise is testing the capability of organization in getting correct information about customer(s)/consumer(s) of particular end product(s).

Hence you can say that if TIME and QUANTITY factors are made integral parts of FORWARD TRACEABILITY exercise then it will become a recall/withdrawal drill.

Hope it would help.

Regards:
M.Zeeshan.

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#3 Betty8

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Posted 01 March 2011 - 09:03 AM

Thank you for replay.

Identification of all customers was always part of my forward traceability exercise. So if I'll include timescale in my report, should it be enough to cover recall/withdrawal testing?






#4 GMO

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Posted 01 March 2011 - 10:39 AM

Also ensure all the product is accounted for and that contact details are available but I think apart from that, yes.



#5 Dr Ajay Shah

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Posted 02 March 2011 - 05:39 AM

Hi Betty 8,

You can get the Food Industry Recall Protocol document which you can modify to your needs. The information supplied can be very useful and it is from an Australian website:

http://www.foodstand...ocol6thedition/

When conducting a Mock Recall it is important to create a scenraio and follow through from where you source the raw materials right through to where you send it to so that you can trace all this. It is important to have a time line with everything so that when you convene a recall committee everybody should know what their tasks are. All major contacts should be on the recall procedure so that one knows how to follow through properly.

There are companies that speacialise and train personnel in conducting a Recall such as RQA. The details are avilable from the following website and hope this helps:

http://www.rqa-inc.com/crisismgmt.html

I hope all the above assists you.

Regards

Ajay Shah


Edited by Dr Ajay Shah, 02 March 2011 - 05:41 AM.

Dr Ajay Shah.,
BSc (Hons), MSc, PhD, PGCE(FE)
Managing Director & Principal Consultant
AAS Food Technology Pty Ltd
www.aasfood.com


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#6 Zeeshan

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Posted 02 March 2011 - 05:58 AM

Thank you for replay.

Identification of all customers was always part of my forward traceability exercise. So if I'll include timescale in my report, should it be enough to cover recall/withdrawal testing?


Apparently it looks that its OK. For a more clear understanding, IMO you should also review following source, especially section 2,8,9,10.

http://www.fda.gov/S...e/ucm129259.htm

Whatever information could be collected and how much time is consumed to collect applicable information are, I think, the basis of withdrawal/recall test.

Regards:
M.Zeeshan

#7 Foodworker

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Posted 02 March 2011 - 09:57 AM

Traceability and Product Recall are different but intrinsically linked. It is possible to test Traceability without Product Recall but rarely the other way round.

Traceability is the method that you use to identify where materials have been used and dispatched. It is essentially a mathematical process.

Product Recall is the procedures and practices that you have to identify a problem, investigate it to ascertain the level of seriousness and take appropriate action. The Product Recall Procedure will have guidance as to the type of incident which may require product to be recalled, management decision making protocols, specific individual roles, communication methods and contacts etc.

Therfore, testing traceability looks at the method of accounting for material movements.

Product Recall testing looks at the quality of decision making, the availabilty of people in a crisis, their ability to perform their allotted tasks and the effectiveness of customer and other notifications.

Testing of Product Recall should be carried out to evaluate your ability to deal with a crisis where product safety/legality is involved. It is because these crises don't happen often that regular testing is needed so that you are not finding your way in a life or death situation (literally in some instances)

Always test your Product Recall using a challenging scenario. Don't do it just because a Standard says you have to. You will know the weak spots in your in your systems. Choose scenarios which test these weak spots.



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#8 Charles.C

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Posted 02 March 2011 - 05:01 PM

Dear Betty,

I realise it's a bit late now but you really should do a search here for "mock recall". Yr question is very popular since it is a basic requirement for most (all?) FSMS systems. There are many threads existing here with practical details.

Rgds / Charles.C


Kind Regards,

 

Charles.C


#9 Madam A. D-tor

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Posted 07 March 2011 - 09:19 AM

Thank you for replay.

Identification of all customers was always part of my forward traceability exercise. So if I'll include timescale in my report, should it be enough to cover recall/withdrawal testing?



Therfore, testing traceability looks at the method of accounting for material movements.

Product Recall testing looks at the quality of decision making, the availabilty of people in a crisis, their ability to perform their allotted tasks and the effectiveness of customer and other notifications.

Testing of Product Recall should be carried out to evaluate your ability to deal with a crisis where product safety/legality is involved. It is because these crises don't happen often that regular testing is needed so that you are not finding your way in a life or death situation (literally in some instances)

Always test your Product Recall using a challenging scenario. Don't do it just because a Standard says you have to. You will know the weak spots in your in your systems. Choose scenarios which test these weak spots.





Dear Betty,

As an auditor I like to see in a recall test that you have followed your recall procedure and that this procedure is applicable, I would like to see that the recall team knows what to do of know how to interpreted the procedure (and where to find it). Also I would like to see that the recall team is trained by doing these exercises.

IMOI it is exactly what foodworker said.
Sometimes very useful and odd corrective actions came out good conducted mock recalls. E.g. a company where I have worked found out that a conference phone was needed in the conference room. A company I have audited found out that sales men started to call there own customers with own made stories, before the decision for recall was actually made by the management.

A recall test/ mock recall is like a fire exercise. You probably never need in in real life, but you want to make sure everybody knows what to do in case of fire. It is the same with recall exercises. It is hard to do a good one and even harder to get the management involved. But the senior management is mostly the decision taker in recalls/withdrawals and therefore should be included.

Regarding the report. I prefer to see a timing for each process step in stead of timing for the whole recall exercise. E.g. incident reported on 16:05 h, recall team gathered on 17:34 h, traceability information available on 17:37 h, information about hazard impact 20:30 h etc. You can find the bottle neck in your recall process and establish corrective actions on these.

I hope this is helpful.


Kind Regards,

Madam A. D-tor

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#10 Simon

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Posted 18 March 2011 - 06:16 PM

Hi Betty, are you clear on the requirements now?

Regards,
Simon


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