Do mock recalls need to be performed annually?
Do mock recalls need to be performed annually? And if so, is either raw material, packaging, or finished product mock recall enough?
Hi,
I think, it would be best to conduct a mock recall from raw to finished product annually. As from there you can see how fast your responses are to a situation and by monitoring your response time annually you can set a target response time (that you would be acceptable to maintain (?)).
For BRC and AIB - it has to be both. Ingredients (any) or from finished product. "Upstream and downstream."
Also required annually as a minimum by SQF Code (trace from raw material/supplier to customer is required):
2.6.2 Product Trace - Mandatory
i. Finished product is traceable to the customer (one up) and provides traceability through the process to the supplier and date of receipt of raw materials, food contact packaging and materials and other inputs (one back);
ii. Traceability is maintained where product is reworked; and
iii. The effectiveness of the product trace system shall be tested at least annually.
And by the IFS Food Standard:
4.18 Traceability (including GMOs and allergens)
4.18.1 Knock Out Clause
A traceability system shall be in place which enables the identification of product lots and their relation to batches of raw materials, packaging in direct contact with food, packaging intended or expected to be in direct contact with food.
The traceability system shall incorporate all relevant receiving processing and distribution records.
Traceability shall be ensured and documented until delivery to the customer.
4.18.2 Downstream traceability records (from production sites to the customers) shall be available.
5.9 Management of incidents, product withdrawal,product recall
5.9.4 The feasibility, effectiveness and timeliness of implementation of the withdrawal procedure shall be subject to regular internal testing, based on hazard analysis and assessment of associated risks but carried out at least once a year.
Regards,
Tony
If you pack for ASDA / Walmart, you have to do it twice a year!!
Don't forget, you need to do a mass balance too.
Caz x
We do 2 trace recalls a year (every 6 months) to meet government regulations and customer demands. This does not include trace recalls that are required by some auditors, so we end up doing 3 or 4 recall exercises annually. You should also try to do mock recalls on raw materials, packaging materials, ingredients and/or processing aids as well. You never know when one of your suppliers may end up having to issue a recall.
Consider a hypothetical situation with a problems with one of the raw materials and a packaging material. Trace it from receipt, through production and to the 1st external customer. One of our customers require a reconciliation to 99.5% to 100.5% of the discrepant material.
We aim to complete this trace within 2 hours in preparation for all the other steps of the mock recall. It is s also a good idea to have at least one of the mock recalls done outside of working hours.
If you ever have to do an actual recall, you may find that annual is not quite frequent enough. Actual recall can be quite different from the mock. We try to do them more frequently and with different groups of people as it can happen when not everyone on your team is there.
If you ever have to do an actual recall, you may find that annual is not quite frequent enough. Actual recall can be quite different from the mock. We try to do them more frequently and with different groups of people as it can happen when not everyone on your team is there.
That's an excellent point, Snookie. We do ours semiannually with finished product and primary packaging separate (so that would be four tests a year), and even then it's a stretch for "job memory". I would also like to add that it is a good practice to do a mock recall if your team changes ownership.