Recall / Mock Recall Time Frame

Hello Again,

We are trying to complete our Mock Recall / Recall and Traceability Program.  There are time limits put on this process?

Some say 4 hours, some say 2 hours.  Exactly which part of the recall can be completed in this time frame?

Considering the press release, notification letter and return of product.  I'm assuming we just need to get down to what suppliers are responsible and what other product uses that material correct?

I've seen both 4 hours and 2 hours. 4 hours is usually acceptable, just make sure that none of your customers require it to be completed sooner than that (if one of them requires a 2 hour window then you must be able to demonstrate you can meet that timeline).

Obviously the return of product is not going to be completed in that time frame, but you need to be able to identify what customers received affected material within the designated time frame.

We're a paper converter making flexible food packaging. We conduct a traceability exercise twice per year and a full mock recall once per year. For the full mock recall I assembled the recall team together and went through a recall scenario raw material forward (we just received word from our supplier that a specific grade of paper was affected). I kept minutes of the exercise (noting start time and end time) including a draft of the press release, draft email notifying affected customers. While we were working on the press release and email details we had the responsible person carrying out the traceability exercise. We also had to identify and isolate potentially affected product in our warehouse as per our Material Hold procedure. We were able to complete the full exercise within the designated time frame. After the exercise the recall team signed the minutes and I filed the signed minutes along with the drafts noted above. This was acceptable with our SQF auditor.

Hope this helps!

HI PEACEQUEEN

Hypothetical: contaminated ink that was used.

Here at my facility (Flexography of food contact packaging) we have our goal established for traceability to "account for %100 within 4 hours". Units of production vary from customer to customer identified through billing (linear feet, linear yards, Impression, etc.) First the traceability of that ink to the print job or jobs, and then an accounting down to every production unit of the total from those prints. Several years back we got a minor nonconformance on a traceability exercise because while tracing the issue (fictitious incident identified in the print process as contaminated ink) we forgot to account for the loss of units of production that occur as waste. So the units that were later laminated and then slit and then shipped out were not %100 due to inaccurate records of setup waste and other production waste. So don't forget about that stuff either. Past that, the traceability of all that was shipped out and all that is possibly still in your warehouse down to the measured units of production. A full accounting

Different standards have different requirements for time-frames to conduct a 100% recall.

This is a mock recall, thus the exercise does not include actual notifications (just the steps that you would take) and does not include return of product (just the methods that you would use to do so.)

Most facilities that are still on paper and/or without an electronic recall program (such as SQF Sentinel for instance) can take upwards of 24 hours, most I've seen at 4-6 hours. Systems such as SQF Sentinel can get it down to mere minutes and seconds.

I honestly don't know what I would do without this network.  You have all helped me keep what little sanity I have left. LOL

One last question about recall and traceability.  My Mock recall example scenario is based on the customer we make boxes for contacting us regarding a health related issue.  Can't our suppliers of (paperboard, ink, coatings, adhesives) contact us due to a recall of their material as well?  We would therefore be tracing the FG the material was used in and be required to contact all customers affected...correct?

I don't think SQF code specifies, but on our own facility SOP we specify 2 hours (mostly due to one particular customer's requirements).

We are a paperboard food packaging manufacturer. Our Mock Recalls are usually completed within one hour (2017 was 43 min) using a checklist and electronic records. We have a live inventory system and our job cards have all raw materials on them including all of the quantities, traceability info and vendor and customer info. Our accounting system keeps all traceability info for each component per item. When we determine a recall scenario involving either a raw material defect or customer complaint, we find the job number then locate the job card and nearly all the information we need is on the card. One step forward, one step back accounting for 100% of all materials and products used to manufacture that item. it usually takes more time to scan or print the supporting doc's than anything else.

I honestly don't know what I would do without this network.  You have all helped me keep what little sanity I have left. LOL

 

One last question about recall and traceability.  My Mock recall example scenario is based on the customer we make boxes for contacting us regarding a health related issue.  Can't our suppliers of (paperboard, ink, coatings, adhesives) contact us due to a recall of their material as well?  We would therefore be tracing the FG the material was used in and be required to contact all customers affected...correct?

That's correct, and an equally likely scenario. Tracing the materials from the affected supplier would be your step back, contacting your customers affected would be your step forward.