24 replies to this topic

[susan99]

Hello,

 

This is our first year for an unannounced SQF audit. I have been informed we will be instructed to perform a mock recall while the auditor is on sight. My first questions is... is this true and my second question is... If so, will the auditor choose the item to be recalled or will we? Thanks for any help you can provide!

[scoot915]

Hello

 

I have only experienced 2 GMP audits so I am not sure about SQF.

 

Although the standard stated I would be asked to do a mock recall, for the first one I was not asked to it, but was questioned on our tracking & recall plans/policies.

 

During the second audit I was hoping for good luck again but was asked to do the mock recall.

The auditor picked the item to be recalled, in my case it was a ingredient used in some of our products.

 

Wanted to also mention I do remember the first item the auditor chose was for some reason odd.

I explained to her why the item was odd, she agreed and chose something else.

Apologies for bad memory - was a nervous wreck that day.

 

SQF audit is much more involved than GMP so I would expect they will ask you to perform the mock recall.

 

Hope that helps

[SQFconsultant]

A. Who informed you of this requirement to do one on the spot?

B. If legitimate it is normally the auditor that makes the pick.

C. As a former SQF Auditor the only time I ever asked someone to do a mock on the spot was when a review of the mock recalls raised some red flags.

Gee whiz, it's enough of a nerve racking day already and then they tell you you should expect this... what and why!

[susan99]

Thank you for that input! Our former SQF Practitioner was told this by a previous auditor. Preparing for the audit is a nerve racking process to be sure. I feel like I'm trying to herd kittens most days just ensuring everyone is prepared for the audit, let alone equipment, building, and processes are in order as well.

[Setanta]

IMEX, SQF does make you do a mock recall during the audit if your customers (like Costco) require it. For us, the auditor narrowed it down to some thing we'd run in the last few weeks.

[GrumpyJimmy]

Hello,

 

This is our first year for an unannounced SQF audit. I have been informed we will be instructed to perform a mock recall while the auditor is on sight. My first questions is... is this true and my second question is... If so, will the auditor choose the item to be recalled or will we? Thanks for any help you can provide!

Hi susan99

 

In my experience it has only come up when there was a concern raised about the site not being able to satisfy a recall scenario or has experienced a major issue when dealing with a retailer.

 

To answer the question of who chooses?, The auditor would choose this and if like a BRC audit will give you a time limit to complete it. Its always good to only have pictures or product examples in the meeting room the audit is taking place in of products you know you can robustly do traceabilities on. Remove examples of dodgy or old products where information has been archived somemwhere and will take ages to find it and taking up valuable time, Not that i would do this honest!

 

DW

[tadelong]

My auditor always makes us do one. I had trouble once.

[cerving]

We have had to do a mock recall during every SQF audit we've had.  The auditor always let us pick the item, though they generally give us a date and tell us to pick an item ran on that date.  We've never had an issue, but mock recalls have always been something we've excelled at.

[DN_QAMGR]

I've always done a mock recall during the audit. (3rd Party Customer & BRC & SQF)

 

I believe it is apart of the standard to do it for the audit. 

 

I recommend you review the standard.

[MMC79]

We have had 4 SQF Audits and for all have been asked to do a mock recall with auditor choosing product to recall

[Charles.C]

I've always done a mock recall during the audit. (3rd Party Customer & BRC & SQF)

 

I believe it is apart of the standard to do it for the audit. 

 

I recommend you review the standard.

 

Hi DNQ,

 

I could only find this ?

 

2.6.3.4  Records of all product withdrawals, recalls and mock recalls shall be maintained.

 

and guidance -

 

The recall and withdrawal procedure shall be reviewed initially at the desk audit and compliance to this
requirement by observation, interviews with recall committee, and review of actual/mock recall records at
each facility audit.  The SQF auditor shall review the annual test of the recall and withdrawal system, and
corrective actions taken as a result of the test.

etc etc

 

I suppose "observation" could be interpreted as requiring an on-the-spot demo but strictly speaking the guidance material is not auditable anyway.

[DN_QAMGR]

Hi DNQ,

 

I could only find this ?

 

and guidance -

 

Hi Charles, (aren't you the expert or are you testing me, j/k).

 

I haven't performed a SQF audit in years, but have been monitoring the SQF Code to keep on top of it. 

 

I believe the code they are looking for is: 

 

2.6.2 Auditing Guidance

• The product trace procedure shall be reviewed initially at the desk audit and compliance to this requirement by observation, interviews with operational staff, and review of records at each facility audit.
• The facility audit shall include a review of trace back on rework (where applicable) and the auditor may need to verify traceability requirements.
• Evidence may include:
  • There is a product trace procedure that documents all applicable materials, work-in-progress, and finished products;
  • The product trace system is effectively implemented;
  • The product trace system is one up, one back;
  • Finished product can be traced back to material suppliers;
  • Rework is traceable back to materials and work-in-progress;
  • The product trace system has been tested annually.

My interpretation of this statement: "auditor may need to verify traceability requirements" is that the auditor can initiate a mock recall to verify the procedures, process & steps of the recall program.

 

thanks,

DN

[Charles.C]

Hi DNQ,

 

From the Code -

 

2.6.2.1  The responsibility and methods used to trace product shall be documented and implemented to ensure:
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.
2.6.2.2  Records of raw and packaging material receipt and use, and product dispatch and destination shall be
maintained.

 

 

I rest my case. Twice.

[Jus'me]

We have gone through four SQF audits thus far presently and with each one we have had to conduct a mock recall while the auditor was present.  Usually they would offer two or three items from the documents they reviewed and allowed us to choose one of these to do the M-R on.  If you have a good program in place and have your staff prepared prior, letting them know that a M-R will be conducted, you should be fine.  They re not trying to trip you up, just want to ensure you can conduct a recall properly.  Relax, it is a small part of the audit.  If you have already conducted a mock recall and made any corrections or bolstered any weak areas, you should be fine when the auditor has you do the trace.

[pooled]

In my experience, during BRC audits, we always had to perform a mock recall. Recently I have been involved in SQF, last year was our initial audit & we performed a mock recall. This year we did not have to.

[Charles.C]

Hi All,

 

I should have added a caveat in my previous post that i will not be in the least surprised if SQF auditors are reported to implement interpretations of text in the SQF Code which, IMHO, are (auditee) challengeable. (or other GFSI-recognised standards for that matter).

 

IMEX the classic audit repartee (assuming well-prepared) is  - Show me where the Standard requires this ? (See below for a BRC "variant" which does comply with this "Rule" but such afai can see is not used in the SQF standard)

 

After all, you are the one paying for this auditorial priviledge.

 

@pooled, actually there is no specific mention of "mock" recall in the BRC7 Standard. You may be thinking of Traceability. Although IMO not deducable from the numbered text BRC7 contains  -

 

●● Opening meeting
●● Production facility inspection
●● Document review
●● Traceability challenge
●● Review of production facility inspection
●● Final review of findings by auditor
●● Closing meeting – review audit findings and confirm any non-conformities

 

 

BRC7 also has -

The product recall and withdrawal procedures shall be tested, at least annually, in a way that ensures
their effective operation. Results of the test shall be retained and shall include timings of key activities.
The results of the test and of any actual recall shall be used to review the procedure and implement
improvements as necessary.

(3.11.3)

afai can see, no specific requirement to perform a challenge for the above in an audit unless it is "understood" to be a 100% certain consequence of the phrase  "The procedure shall be capable of being operated at any time"(3.11.2). No idea if BRC can be that "subtle".

 

If auditors validate/notify auditees of their interpretation of such issues in advance (sufficient to enable auditee verification) of the audit, it's maybe fair enough. Otherwise, IMO, it becomes "fair game".

[Dan McCarthy]

My auditor always makes us do one. I had trouble once.

Is it a Major if you miss the timeline? 

[tadelong]

I got a minor. IMEx auditors don't give out majors unless it's an egregious mistake.

[adelk2202]

I have always had to perform a mock recall during my SQF audits. Usually, the auditor lets us pick the item from a date they specify but I think they can pick it if they want. Hopefully your auditor is nice and lets you pick. Good luck!

[bakeryscience]

I know this is an old thread, but hopefully someone can still answer this. How do auditors verify that all product was traced properly? 

[Scampi]

Auditor requested a traceability exercise while on site (we use really good software so it only takes 3 minutes to run the exercise)

[scoot915]

Auditor requested a traceability exercise while on site (we use really good software so it only takes 3 minutes to run the exercise)

Would you like to share what software you use?

Thanks

[Scampi]

It's called iTrace, all of our ingredients, packaging etc are given a lot at receipt by the system (with scannable codes) and the system has our recipes built in, so it automatically knows what you've used when you enter a FG lot

 

For trace ability, it automatically gives you all raw inputs when running a search of an FG, and works backward on ingredients (ask for all the flour from lot 123 and it spits out where it went, who it shipped to an how much is left in inventory)

 

 

http://www.can-trac.ca/

[scoot915]

Will check it out 

Thank you

[OrRedFood]

Hi Charles, (aren't you the expert or are you testing me, j/k).

 

I haven't performed a SQF audit in years, but have been monitoring the SQF Code to keep on top of it. 

 

I believe the code they are looking for is: 

 

2.6.2 Auditing Guidance

• The product trace procedure shall be reviewed initially at the desk audit and compliance to this requirement by observation, interviews with operational staff, and review of records at each facility audit.
• The facility audit shall include a review of trace back on rework (where applicable) and the auditor may need to verify traceability requirements.
• Evidence may include:
  • There is a product trace procedure that documents all applicable materials, work-in-progress, and finished products;
  • The product trace system is effectively implemented;
  • The product trace system is one up, one back;
  • Finished product can be traced back to material suppliers;
  • Rework is traceable back to materials and work-in-progress;
  • The product trace system has been tested annually.

My interpretation of this statement: "auditor may need to verify traceability requirements" is that the auditor can initiate a mock recall to verify the procedures, process & steps of the recall program.

 

thanks,

DN

Hi - I'm looking at this old thread for advice on a customer who is performing a mock recall.  They want all of our raw ingredient specifications, COAs, and organic certificates for org. items, in 2 hours.  I don't think this is standard in to share with a customer.  Any thoughts? Thanks in advance!