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Testing the product recall system "out of hours"

Mock Recall

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#1 Merikoferi

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Posted 08 January 2020 - 10:28 AM

Hello everyone,

I want to write a little bit about company, main activity is: Production of kernels packed in p/p, in plastic bags under vacuum or in big bags. Roasting of hazelnut kernels, chopping, milling and packing in plastic bags under vacuum (Production country - Georgia and the products are fully exported to Latvia, Germany, Greece, Poland, Spain and etc).

 

We just had BRC audit, and the auditor fixed non-conformance: "The company did not test the recall plan out of hours protocol" (3.11.2), nowhere is that written to do simulation test out of working hours, the only request is that system should work properly. 

And yes, we are doing simulation test once in the year.

 

what should i do? Can you help me on this issue??? (During simulation test we done traceability, send mail to the customer, told them that it is simulation and ask them to give us all information regarding receiving and actual situation)

 

thanks in advance

 



#2 pHruit

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Posted 08 January 2020 - 11:00 AM

Which clause did they write the noncoformance under - 3.11.2 or 3.11.3?

I've been through nearly 20 BRC audits and never seen an auditor request evidence of an out of hours test, but equally the standard does say in 3.11.2 that "the procedure shall be capable of being operated at any time", and 3.11.3 does state that the test must ensure "effective operation", one aspect of which is arguably that the out of hours requirement is fulfilled.

The specific use of the term "protocol" does perhaps give some leeway in terms of what they're expecting. Did the auditor explain in more detail at the time the NC was issued and discussed?
For example we do verify (and record) that all of the out of hours contact details for key staff are still correct as part of the test, and that the list of those in closest proximity to the site is still current. That could arguably be part of the "protocol" to which they're referring, and thus may provide a relatively easy fix.



#3 GMO

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Posted 08 January 2020 - 12:00 PM

Nowhere in the standard does it say it has to be done out of hours.  It does in retailer standards in the UK but not BRC.

 

This is from the interpretation guideline.

 

Tests of the withdrawal and recall procedures

The withdrawal and recall procedure must be tested at least annually. It should be emphasised that

traceability is only part of this procedure. The aims of testing the full procedure are to:

• demonstrate that the system works

• highlight any gaps and where the system requires improvement

• demonstrate how quickly the required information can be collated, and thereby corrective action taken,

such as materials being isolated and quarantined

• act as a training exercise for personnel to ensure that clear roles and responsibilities are undertaken in the

event of a real withdrawal situation.

The test of the recall and withdrawal procedure must include verification of the decision-making process,

traceability of raw materials through to finished product, verification of contacts, and timings of key activities.

Records must be kept of tests of the recall and withdrawal procedure and must include a review of the result

of the test and any action taken for improvement.

If the site has had an actual withdrawal or recall which fully tested its recall procedures, then this would be a

substitute for a recall test as long as records are maintained, an analysis of the effectiveness of the recall

procedure is carried out, and any areas for improvement are identified and acted upon.

 

That said, you have two options, appeal, or test it out of hours.  If you appeal, you risk annoying the auditor (sometimes justified), if you accept it will it improve your quality system?  Arguably yes.  So while I would have challenged this in the audit, afterwards is probably too late. 

 

It was a requirement of some UK retailer standards though last time I worked with them and there are a few options I did to comply.  Once I went in on a bank holiday, another time I started the scenario at 6am, another at 5pm.  It doesn't have to be 10pm to be "out of hours".



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#4 Merikoferi

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Posted 08 January 2020 - 12:13 PM

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Thanks for reply,

 

clause was 3.11.2.

Unfortunately Auditor did not discussed during audit process or closing meeting, he just give report and this non-conformance was there. And when we asked him, he briefly answered  that we should do recall out of our working hours. 

 

Everything  is described in the procedure, the customer can contact at any time, because there are several responsible persons for deviation or non-conforming product, in any real recall and product withdrawal everything is starting from the customer not from our side, because product delivered to them (and in this situation what kind of recall simulation should we do?)



#5 Merikoferi

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Posted 08 January 2020 - 12:24 PM

Your comment is understandable and I agree. Ok I will do simulation during non working hours, but since I am doing simulation the requirements be all time ready 24/7 is for me and not form my customer, whom during simulation i will send letter and he could not be available at all times.



#6 Hoosiersmoker

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Posted 16 January 2020 - 07:23 PM

Don't let an auditor cite and deduct for elements NOT in the code. They can be appealed and every auditor I've met has told me that is my right and they don't have issues with it, they just let the technical people deal with it. You hire them for a service, if they "cost" you a point in the process, they're not helping you. We had this issue with a previous audit where "all lighting" in a certain room was specified on the Glass and Brittle Plastic Register (so we didn't have to list the 40 fixtures each on their own line). He cited the lighting above one press as not specifically called out in the register. 4" fixtures like all the rest, containment like all the rest. He didn't mention it during the audit or exit meeting. We took pictures of the fixtures in question and submitted them with the register and the technical committee immediately restored the deducted point. That's how the system is set up. Also, you know there is no such provision, Maybe the auditor doesn't. You might be doing him a favor by pointing it out. If nothing else it will clarify it for future reference and there's no cost to appeal it so no reason not to and you might get a point back.



#7 GMO

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Posted 20 January 2020 - 12:17 PM

Don't let an auditor cite and deduct for elements NOT in the code. They can be appealed and every auditor I've met has told me that is my right and they don't have issues with it.

 

I'm not sure all CBs are the same, also I can't imagine an auditor where they are constantly being challenged is seen favorably.  It either indicates not understanding the standard or not explaining yourself well enough while you were on plant.  I've had an auditor get very angry when I said I'd appeal to something she was proposing to raise and then she didn't raise it.  I didn't mean it as a threat, just I thought she was misunderstanding the clause.



#8 Merikoferi

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Posted 20 January 2020 - 12:24 PM

GMO On Friday i send an Appeal to the CB, so, let's see how the things turn out :)

#9 GMO

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Posted 21 January 2020 - 01:43 PM

GMO On Friday i send an Appeal to the CB, so, let's see how the things turn out :)

 

Good luck!



#10 Hoosiersmoker

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Posted 21 January 2020 - 02:37 PM

Yes, Good Luck.







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