6 replies to this topic

[daveh11]

It is a requirement of ISO22000 to ensure the batch traceability of Raw materials used with the manufacturing process, so in the event of an issue, say at a suppliers, we can then identify what batches of our finished product contained the effected batch of raw material.

 

However, what would be the expectations where the finished product contained food safe, recycled / reclaimed materials? the same traceability, back to the original raw materials or even supplier cannot possibly exist once in the Recycled stage of a process..

 

The recycling process cannot identify the specific batch details for the raw materials used, so the end user of the recycled product would not be able to maintain the link back to the initial, virgin source either.

 

What would we need to do, as a user of the recycled material, to satisfy the requirements of the standard in terms of recording the batch details where it includes the use of recycled materials?

Would we just need to record that a particular batch of finished product contained "re-cycled" material, and perhaps the date it was processed or would it need to go back to a specific source / identification?

 

Any advice would be gratefully received.

 

David

[GMO]

Do you mean reworked batches?  Most sites I've worked at where rework existed now accept there has to be some kind of clean break.  How often that clean break is depends upon cost of wasting the rework for a batch or, say, cost of full withdrawal of everything.

The only exception I had to that was making sourdough bread.  Sourdough for those who don't know involves making a sour starter culture from flour and water which then gets colonised by natural yeasts and lactobacilli.  You take some out for each batch to make a wet dough which is eventually made into bread then add more flour and water to the starter for it to continue to feed and grow.  Basically that starter theoretically contains flour from day 1 onwards and so, therefore, do all your breads.  What I did was to calculate the % of each "generation" of sour starter and how many generations it would take before you would be reasonably confident it was <1% of the total content.  Unfortunately with the life of fresh bread that didn't help us massively and if there was a huge contamination incident we'd not only have to recall but destroy our starter so my mindless ramblings might not have been much help.

[Tracey Richardson]

Recycled material is traceable. You should know exactly what went into the recycled material. You  know what went into the batch. The added recycled material must be added at a percentage so it can be accounted for. The recycled batch should have its own identifier so that it can be traced and you must record the amounts that went into new batches. The new batches that are made will have an indicator that they have the unique identified recycle material in them. The recycled batches have their own records and if out of spec, they are marked as remill/recycle. I have done many trial traces and it works awesome. Hope this helps.

[daveh11]

HI - Many thanks for the feedback on this topic.

 

We know we placed a known quantity of recycled material into a batch of finished product and when this was used - however what we cannot identify, is the original finished product or raw material batch details used in the recycled material. 

 

The reason for this is the process produces waste (We produce Paper), paper is produced in large "Jumbo" reels, which are then trimmed to the required widths the customers require, this more often than not results in "off cuts" from the jumbo reel,  these are stored, and when there is sufficient quantity, are then put back through the system. The off cuts will be from many, many different batches of finished product, all jumbled up so they can be reprocessed effectively.

 

By its very nature, the off cuts are likely to contain product which is likely to have already been re-cycled many times over so tracking the original raw materials is virtually impossible.

 

This must be a similar scenario for Bulk recycling plants for glass, card, paper etc., which is then sold back to industry as food safe post-consumer waste - the raw material audit trail must be lost as soon as the virgin product enters the recycle chain. Yes, once recycled, a new batch ID could be allocated, but it would not allow the identification of the original batches of raw material used, so there must be some formal method of managing this scenario one would assume.

 

Hope this explains our issue a little clearer.

 

Once again many thanks for the continued assistance with this issue,

[Charles.C]

Hi daveh,

 

Have a look at this thread which expands on Post 2 -

 

http://www.ifsqn.com...taining-rework/

 

Not my direct experience but Googling suggests that this approach is widely implemented (= only way out ?).

[daveh11]

HI All.

 

Once again many thanks for the feedback on this topic, the option to have a cut-off point does look to be the only suitable option available to us, and when the process "restarts" with 100% virgin materials, we can then control the traceability more effectively, however this will require us to "assume" the presence of all raw material batches processed between the restart and cut off periods in all finished product produced during the same period.

 

But at least its a definable period.

 

If anyone has any information as to how recycling plants control this aspect i would be most interested - Adopting the principles of being able to trace one stage up & down the process is i suppose achieved by the end user of the recycled material, as I’m sure they can indicate the delivery note, invoice etc., but would not achieve the goal of being able to determine the specific batches of the product used to produce the said batch of recycled product, so cannot achieve the overall aim of the traceability by being able to determine traceability throughout the supply chain - hope this makes sense.

[Tracey Richardson]

Trace the recycle material by hours. You should know what batches were made in those hours and a what went into them. The recycled paper will like consist of several batches, so just use cutoff times and treat them as "New Recycled Batches" that are added to the virgin batches at a certain percentage.