Product Recall and Traceability
I'm starting to get a bit confused on the issue of Product Recall vs. Traceability.
Prior to BRC certification, we had considered a mock recall to be a trace of finished product to customers.
Isn't this also one aspect of traceability? If done as a traceability test does it also serve as the mock recall?
And how many conditions of traceability must be tested? ie: raw material forward, finished good backward and forward, packaging material forward.
We received a C grade and so will be re-audited within 6 months. Want to make sure to be prepared, as an A or B is well within reach!
Hi everyone!
I'm starting to get a bit confused on the issue of Product Recall vs. Traceability.
Prior to BRC certification, we had considered a mock recall to be a trace of finished product to customers.
Isn't this also one aspect of traceability? If done as a traceability test does it also serve as the mock recall?
And how many conditions of traceability must be tested? ie: raw material forward, finished good backward and forward, packaging material forward.
We received a C grade and so will be re-audited within 6 months. Want to make sure to be prepared, as an A or B is well within reach!
A mock recall is in essence, a traceability exercise. However, the mock recall should be used to test your entire recall program. This means notifying the members of the recall team, having them make the decision whether or not a recall is warranted, etc.
You should also use the opportunity to ensure that contact information for suppliers, customers, regulatory agencies etc. are verified.
We do two mock recalls and two traceability exercises each year which covers your second question. We do one raw material forward, one packaging material forward, one finished good backwards and one raw material backwards.
Marshall
A mock recall is in essence, a traceability exercise. However, the mock recall should be used to test your entire recall program. This means notifying the members of the recall team, having them make the decision whether or not a recall is warranted, etc.
You should also use the opportunity to ensure that contact information for suppliers, customers, regulatory agencies etc. are verified.
We do two mock recalls and two traceability exercises each year which covers your second question. We do one raw material forward, one packaging material forward, one finished good backwards and one raw material backwards.
Marshall
Yes what Marshall says is correct although traceability is an aspect of recall, the Mock recall is a test of your recall procedure and it is important to record the timings from the complaint coming in until the product is back on your imaginary truck. The first recall I did caused consternation as I got one of our overseas sales people to rraise the complaint, they have to be offay with the procedure also. They had never heard of such a thing, and didn't know what I was talking about, however it all went well and a few weeks later we had a real recall, and the team were spot on getting it sorted.
The traceability I do involves Mass balance, and works backwards from the traceability code, and goes right back to raw material.
Creat a report of the mock recall, the auditors like to have a front page that they can look at and see that the thing has been done correctly, and they don't have to fossick through reams of paper
Hope this helps
A mock recall is in essence, a traceability exercise. However, the mock recall should be used to test your entire recall program. This means notifying the members of the recall team, having them make the decision whether or not a recall is warranted, etc.
You should also use the opportunity to ensure that contact information for suppliers, customers, regulatory agencies etc. are verified.
We do two mock recalls and two traceability exercises each year which covers your second question. We do one raw material forward, one packaging material forward, one finished good backwards and one raw material backwards.
Marshall
One raw material backwards....Could you elaborate? We have a pretty simple process here, but it seems it starts with raw materials, so how do you go backwards?
One raw material backwards....Could you elaborate? We have a pretty simple process here, but it seems it starts with raw materials, so how do you go backwards?
The easiest of the four, you determine date material received, quantity received, transporter and trailer identification information. This would normally be done at the behest of a supplier if they were conducting a recall/traceability. The information would satisfy their requirement to trace one step forward.
It also gives you an idea if the receiving department is properly inputting all the required data when receiving materials.
Marshall
I don't hv the exact BRC requirement but this example text below may help. The simplicity of compliance will depend maybe on where you are in the supply chain, what you are doing, and what records you maintain.
traceability of foods and foodborne hazards - T2395.pdf 643.76KB 1002 downloads3. Legislation and standardization at EU- and international level
Legislation
Since the beginning of 2005 a system has been required from food processors for identifying the origin of raw materials and the destination of final products i.e. one step forward and one step backward in the production chain. This was stated in EU regulation 178/2002, which includes the following clear requirements for traceability:
1. The traceability of food, feed, food-producing animals, and any other substance intended to be, or expected to be, incorporated into a food or feed shall be established at all stages of production, processing and distribution.
2. Food and feed business operators shall be able to identify any person from whom they have been supplied with a food, a feed, a food-producing animal, or any substance intended to be, or expected to be, incorporated into a food or feed.
To this end, such operators shall have in place systems and procedures which allow for this information to be made available to the competent authorities on demand.
3. Food and feed business operators shall have in place systems and procedures to identify the other businesses to which their products have been supplied. This information shall be made available to the competent authorities on demand.
4. Food or feed which is placed on the market or is likely to be placed on the market in the Community shall be adequately labelled or identified to facilitate its traceability, through relevant documentation or information in accordance with the relevant requirements of more specific provisions
The ultimate relevance might be, eg "Who sent the batch to us with this defect material in it and where did all the bits end up?" Followed usually by "How much was there" ? and finally "What's it going to cost us ??
The available depth of the answer relies on access to records of course. The above text seems to hv limited the responsibility to 1 step.
Rgds / Charles.C
PS Some standards seem to be more demanding, eg
Other applications required by IFS
• Batch traceability in both directions
... backward to the source of each raw material up to the supplier
... forward into the market for eventual call back campaigns
IFS some notes 2007.pdf 225.93KB 678 downloads
PPS - There are several threads here on this topic if you search a bit for "Traceability" or "mock recall" (including from memory some examples of actual implementation of the requirements)
Hi everyone!
I'm starting to get a bit confused on the issue of Product Recall vs. Traceability.
Prior to BRC certification, we had considered a mock recall to be a trace of finished product to customers.
Isn't this also one aspect of traceability? If done as a traceability test does it also serve as the mock recall?
And how many conditions of traceability must be tested? ie: raw material forward, finished good backward and forward, packaging material forward.
We received a C grade and so will be re-audited within 6 months. Want to make sure to be prepared, as an A or B is well within reach!
Traceability is covered under clause 3.9: The traceability system should be tested to ensure you can track from raw materials (including packaging) to finished products and vice versa including quantity/mass balance check. It should be achievable within 4 hours, tested at a predetermined frequency but at least annually.
Clause 3.11 covers Management of Incidents, Product Withdrawal and Product Recall. The key requirements to be included in the procedure are:
- Identification of key personnel in the recall team
- Guidelines whether a product needs to be recalled
- An up to date list of key contacts: recall team, suppliers, customers, local authority, certification body & emergency services
- Communication plan
- External agencies providing advice
- Logistics plan: traceability, recovery, disposal and stock reconciliation
Clause 3.11.3 refers to testing the procedures: The procedures should be tested in a way that ensures their effective operation and timing of key activities.
So a recall test will require you to check all these procedures are in place and correct, not just that your traceability system is working.
Hope this helps explain the difference.
Regards,
Tony
The way I try to get it across is to explain that Traceability is the 'mathematical part' and Product Recall is the 'management part'.
Traceability is achieved by whatever system of identification and recording that you have - anything from a basic handwritten log to a sophisticated Management Information System. The concept of forwards as well as backwards traceability sometimes needs a bit of further explanation, particularly if you have come from an ISO9000 background.
Product Recall is who does what, when and how.
Traceability is an intrinsic part of Product Recall and it makes sense to combine the tests.
Tony C has covered pretty much everything (even though I'm sure that he didn't really mean that the test should be carried out at a minimum of an hourly frequency!)
No I certainly didn't, minimum annually
Just out of curiosity, how did you get on with your Certification Body with respect to the audit duration and not coming back on site to close off the non conformities?
Good Evening SaltSafety,
Just out of curiosity, how did you get on with your Certification Body with respect to the audit duration and not coming back on site to close off the non conformities?
The Certification Body explained to us that the requirement for returning to the site to confirm corrective actions, while a requirement in Europe, is not generally enforced in the US due to the huge distance that is often required for an auditor to travel for re-visits. We sent extensive proof, including documents and many pictures and they found it acceptable and granted us certification.
As for the duration, I recieved a customer survey from them following them following the audit and commented on why I thought the duration should be shortened. I like working with this company and don't want to create a bad relationship, so I'm hoping they will see that 4 days is excessive.
There is a guide on Food Industry Recall Protocol from the Food Standards Australia New Zealand website which you can adopt and modify to suit your country and regulatory requirements:
It is available at the following website:
http://www.foodstand...r1819.cfm<br />
I hope it is useful to you.
cheers
Yes what Marshall says is correct although traceability is an aspect of recall, the Mock recall is a test of your recall procedure and it is important to record the timings from the complaint coming in until the product is back on your imaginary truck. The first recall I did caused consternation as I got one of our overseas sales people to rraise the complaint, they have to be offay with the procedure also. They had never heard of such a thing, and didn't know what I was talking about, however it all went well and a few weeks later we had a real recall, and the team were spot on getting it sorted.
The traceability I do involves Mass balance, and works backwards from the traceability code, and goes right back to raw material.
Creat a report of the mock recall, the auditors like to have a front page that they can look at and see that the thing has been done correctly, and they don't have to fossick through reams of paper
Hope this helps
*Ingredient forward
*Packed Lot Back
*Back Trace forward
*Pack lot to Customer
*Customer Back to Ingredient
*Pack Lot to Distributor
I got some how confused with these many recall exercises,
Any help is appreciated.
Thanks
Would yo please advice me in the meaning of these terms in a recall:
*Ingredient forward
*Packed Lot Back
*Back Trace forward
*Pack lot to Customer
*Customer Back to Ingredient
*Pack Lot to Distributor
I got some how confused with these many recall exercises,
Any help is appreciated.
Thanks
Hi Amb
Ingredient forward - From Raw Material Product Lot (Batch) forward through the process
Packed Lot Back - Finished Product Lot (Batch) back to Raw Material Product Lot (Batch)
Back Trace forward - Contradicting term, not a phrase that means anything to me and not referred to in BRC
Pack lot to Customer - Lot or Product Batch sent to customer
Customer Back to Ingredient - From Finished Product Lot (Batch) sent to customer back to Raw Material Product Lot (Batch)
Pack Lot to Distributor - From Finished Product Lot (Batch) sent to distributor back to Raw Material Product Lot (Batch)
Simply put you need to have a system that can trace from raw materials to finished products (& onwards to customers) and vice versa.
Regards,
Tony
Thank you, I appreciate your input.
amb