40 replies to this topic

[Charles Chew]

There has been so many issues raised on traceability in this forum BUT are we missing out on the REAL ISSUE with regards to the all important preliminary evaluation of information prior to invoking our TRACEABILITY PLAN.

We know the importance of protecting consumers from hazardous products BUT a wrong decision to invoke a Product Recovery Exercise would certainly be a very expensive and unjustified affair for the manufacturer.

With the exception of a recall instigated by the government, a Traceability Plan is not complete if we do not have a thorough Hazard Risks Assessment Format including the methodologies to justify such an exercise.

Stock Reconciliation, Product Recovery Register, Product Disposal Register, Recall Register etc are all documents relating to the application of the Traceability Plan.

What and where are the information for assessments to support this action? How do we engage an independent assessment for such an action?

Please let us have the usual comments and contributions from the forum.

Cheers
Charles Chew

[Charles Chew]

Dear All,

A Traceability Plan is only HALF as good if we cannot determine a good reason why we should go for such an action.

We all know that if a control deviation of a CCP can lead to a harmful product hazardous to consumers, a decision to trace for product recovery (specific batch)is essential. BUT what about non-CCPs issues which may lead to similar threats to consumers...........like pesticide contaminations from Pest Control Program, chemical residue from cleaning detergent, etc.

Again, a decision to trace for product recovery if NOT justified, is a bad decision that can be very expensive.

Any comments?

Charles Chew

[Simon]

Hi Charles,

If deviation from a none CCP hazard is deemed to be serious enough to warrant the instigation of a product recall, then you have to question whether the HACCP team have done their job correctly in the first place.

If deemed a CCP the decision 'to recall' or 'not to recall' would be documented as a corrective action in the HACCP plan. Risk already assessed.

Am I making sense - it's very late.

Regards,
Simon

[Charles Chew]

(If deemed a CCP the decision 'to recall' or 'not to recall' would be documented as a corrective action in the HACCP plan. Risk already assessed.)

Hi Simon,

Whilst CCPs are subject to scrutiny and specific control mechanisms, other elements may not be so although the usual periodic and continuos monitoring programs are put in place, you just cannot have a perfect system.....and there can never be

Regardless of category and nature of risks, once a product is deemed (by assessment) hazardous to consumers' health, a product withdrawal is invoked. THIS IS THE CORE ISSUE.

[Simon]

Good Morning Charles, What time is it where you are?

Yes, OK I agree that a breakdown of a factory wide or prerequisite procedure may also warrant the instigation of a product recall.

I also agree with you that the decision whether to recall or not to recall is a critical one and could prove very costly to the business if an incorrect decision is made. With this in mind what investigations do you believe should take place and what is the decision making process for example in the case of a loss of a blade or sharps item?

Regards,
Simon

[Charles Chew]

Hi Simon,

I need to expand on the subject from where I left off.

Agree that whatever the decision made, it has to be documented for Correction Actions BUT not necessarily that the risk assessment has been done CORRECTLY.

The core issue here is whether we have got it right in our risk assessment method i.e. What to look for, Where and How.

Traceability is really a big issue and a big area.

The approach that we use focus on: Information retrieved from the "Hazard / Risk Assessment Information Form" ref: Specific Batch No / Production Date etc
a. CCPs documentation - analytical observation for any recorded deviations.
b. GMPs - Analytical assessment on all record keeping documentations for non-conformances
c. SSOPs - Analytical assessment on all SSOPs documentations for non-conformances
d. Pest Control Records- The only area handled by external party. Observation for chemical cross contaminants
e. Interventions on any unforeseen hazards during this date or period.
f. Others

Simon, we pursue an analytical process on these documentations with a specific objective of looking out for specific contributions or links to the identified hazard leading to the recall progam being invoked.

The objective should not be any different for Food HACCP or BRC. Not forgetting that we may need to address to the court of law one day that the organization has an effective food safety system to endorse that its food is safe for consumption......but not necessarily the other guy!

Cheers
Charles Chew

[Charles Chew]

Hi Simon,

My local time is 2.30 pm.

I had a recent discussion with a friend who had a batch of meat products (like FOUR forty-footers containers load) being recalled and products disposed as a result of remnants of blades being found in a meal.

As this hazard was informed by the trade, there was no need to consider a risk assessment - product recovery was instantaneous. However, the company took great pain to review how this event had occurred and finally put in place a loose tool assessment program on top of their loose tool plan. (Never use breakable blades but fixed utility knives instead)

However, if a loose item recording program was in place, a missing sharp object would have triggered a crisis management activity in the production department and the respective personnel(s) provided with blades or sharp items would be questioned and hopefully, item retrieved.

I really feel the forum has much to gain if all participate in this wide scope - one that is really going to be in the forefront of all food safety systems.

CharlesChew

[Simon]

Let's assume that the crisis management activity did not find the missing blade. And our investigations and records could only narrow the missing blade down to a full shift and the entire manufacturing process, because the operator involved had been working on a variety of jobs / batches during the shift. The £500,000 of finished product is now in transit to several of our customers.

Recall?

Regards,
Simon

[Charles Chew]

Simon,

Great question.

Assumptions:
a. Blades are issued out to operators within the confine of the production facility.
b. Unable to find missing blade AND the suspect products are now in transit to the customers.

Action:
a. Category - definitely a Goods-in-Transit Level Recall. Because products are still in transit to customers, there is no immediate threat of harm.
b. Convene the Recall Committe to map out the recovery immediately as per Traceability Plan. (not exhaustive)

Post Recovery Action:
a. Consider reworking of products - where no grinding process is involved. This is a decision for the Recall Committee to recommend to Management. Where suitable, reworking of products may be done by a powerful and appropriate metal detector.
b. Dispose off recovered products - where grinding is involved for obvious reason.
c. Other actions but not exhaustive.

Is recall justified?

Charles Chew

[Simon]

Charles when making a list (a., b., c. etc.) in a post use "." instead of ")" because b with a ")" following turns into B)

Hope this makes sense.

Simon

[Charles Chew]

Simon,

Got you and thanks.

You probably realise by now that I am not that IT savvy but sufficient to get through.

Same time, I think it is a good idea for saferpakers to throw in their reasons WHY this situation should or should not be calssified as a recall. Provides a wider scope of knowledge for all.

Regards
Charles Chew

[Simon]

It's John F. Shittelgroover here President of Nevereverrecall Fine Foods Inc. (Your big boss).

Listen Charles, I just got wind of this problem and I have to tell you straight that you are going to have to forget all about this HACCP recall nonsense. There's no way I'm sanctioning 0.5m worth of recall because there 'might' be a poxy piece of metal in one of the pieces. Understand Charles, it's not just the cost of the scrap, we would have to reproduce product and we don't have the production capacity. We would lose customers for sure and jobs would definitely be on the line - not least of which mine! And I'm not losing my condo in Florida over this.

We are going to have to tidy up the records and suck it and see. We found the blade…understand Charles.

Best
J F Shittelgroover.

[Franco]

It's John F. Shittelgroover here President of Nevereverrecall Fine Foods Inc. (Your big boss). 
We found the blade…understand Charles.

It goes without saying that in my present position I would ask for recall, but the decision is not mine, hence I voted 'not sure' because I'm really not sure about what I would do if I were the Big Boss.

You know things may change if you see them from a different viewpoint.

If you start a war you know there will be wounded and dead people in both parties.

But you also know that benefits could be much more than losses and wars have been going on ever since.

Let's suppose things go the other way round.

The product is safe.

We simply want to gain advantage hence we launch a PR with no technical reason.

We organize appropriately, we choose the right batch, let' say 1000 pieces in three retailers' warehouses and a public campaign with a very well designed marketing message on newspapers.

Will the Fifth Power inform all the community that our company is committed to quality and consumer's safety ?

Is this a Machiavellian idea ?

What would Mr. Shittelgroover think of this idea ?

[Simon]

Franco,

I thought this issue had been put to bed with my note to Charles.

Look Franco if I thought there was any mileage in using this as a PR tool we'd be on to it. If it was a hazard with the potential to kill someone then sure we'd be interested at headquarters and we might well instigate a small highly targeted and well promoted recall - but come on it's only a freekin blade.

Best

John F. Shitelgroover

[rheath]

Simon,

I have not voted in this example as I would say 'not my call'.

Base it on the facts & de personalise the situation

You’ve told Mr Shittlegroover blade is missing, refer to the procedures (that he has endorsed).

If he wishes to make a call then that’s his right to do so BUT its against what procedures say.

More significantly - I have NOT found the blade (this I would be prepared to lose my job over - better that than prison)..

Regards

Rich

[Charles Chew]

Dear Guys,

The issue of traceability on product recovery is not about a PR exercise nor running away from responsibilties.

Clearly, it is about consumer safety and responsibility to the public. Mr. Shittelgroover is obviously more concerned about his Condo Apartment in Florida than the number of people who are going to be critically ill. Sadly, social responisibility is obviously not a primary concern in his mind.

And, for those who run away from responsibilities in making a poll call, we would just have to review your position as an active HACCP Member in this "company".

Common guys, its not just a freekin blade.............its a freekin hazard that may just kill.

But having said all that I like Franco's idea of gaining some mileage out the recall exercise. It shows guts, responsibility and hell of a lot of PR points.

Charles Chew

[Simon]

You'll be glad to know that Mr Shittelgroover's been retired to his condo in Florida

I will miss him as he allowed me to play devils advocate for a while on a hypothetical but nonetheless very serious issue. It's a can of worms and although we would all like to think that in this situation our head honcho would operate with ethical judgement, make the recall call and take the loss, rather than leave the outcome completely to lady luck. Let's just hope that none of us are ever faced with this decision for real.

Doesn't it highlight the importance of a watertight food safety system that minimises hazards and an accurate and effective traceability system that allows for rapid and accurate recall in the event of such a problem. Makes the head honchos decision much easier when you have tight systems that minimise lo££es.

People did laugh at them but hats off to Coca Cola for the recent Dasani water recall:

http://news.bbc.co.u...ess/3550063.stm

Regards,
Simon

[Charles.C]

Dear Simon,
Not sure exactly relevant but 2 cents
The discussion has revolved around operational practicalities, moral/ethical, financial issues and where the buck stops.
Can of worms is right. Pandora's box also. Cost effective - hmmm.
How does one, small, found knife blade rate compared to, say, one bag of food (ready to eat) found to have salmonella?
A while back in another forum you were discussing risk assessment, I have seen proposals for CCP's based on an assessment of the likely numbers of injuries and their associated degrees of severity (ie worst case scenarios). Maybe ugly ethically speaking but at least the options are out in the open for all to see. As usual in HACCP, the problem of quantitation is highly (totally?) subjective.
I confess I don't know the answers but I suggest such complexities illustrate the limitations of HACCP. It is an amazing tool but can only be relied on within a defined framework which the hazard analysis frequently sidesteps. It is dangerous (and unfair) to expect miracles.
Traceability - that's another story.

Regards
Charles.C (non-Chew)

[rheath]

Dear Guys,

The issue of traceability on product recovery is not about a PR exercise nor running away from responsibilties.

Clearly, it is about consumer safety and responsibility to the public. Mr. Shittelgroover is obviously more concerned about his Condo Apartment in Florida than the number of people who are going to be critically ill. Sadly, social responisibility is obviously not a primary concern in his mind.

And, for those who run away from responsibilities in making a poll call, we would just have to review your position as an active HACCP Member in this "company".

Common guys, its not just a freekin blade.............its a freekin hazard that may just kill.

But having said all that I like Franco's idea of gaining some mileage out the recall exercise. It shows guts, responsibility and hell of a lot of PR points.

Charles Chew

Charles,

You've completely missed the point of what I was saying in my post. I am not a quality inspector, not a food safety controller - I am a undefined manager.

All of the calls made in my business are made by the line managers - this is the only way you can have a truly effective system - me as 1 person cannot effectively control what happens in our operation.

As soon as I override a line managers decision then my battle is lost - I have to make the calls for evermore. My job is about putting systems in place & giving people the appropriate training & information to make the correct informed choices.

Obviously where I am involved I can give my professional advice and in my organisation I am happy to say that there are no shittlegroovers.

This has been achieved through effective systems, checks and balances as such I do not need to make any calls as it is NOT my call..

Hope this clarifies my position

[Franco]

You've told Mr Shittlegroover blade is missing, refer to the procedures (that he has endorsed).

Hi Richard,

may I see the procedure please ? :D

Seriously now and approaching the issue as a System Thinker, I don't think there should be a procedure telling what Mr. Shittlegroover should do or not.

That procedure would declare the death of Management Responsibility

[Charles Chew]

Dear Richard,

Management must be committed to a food safety system (often a criteria), to having an effective plan.

Therefore, a commitment to make that "difficult" decision rests on the shoulders of Senior Management or Owner whether wise or unwise. As an undefined Manager, you may choose to abstain in recommending the course of action to take BUT the rsponsibility to MAKE that decision is not for line managers to make but often, the Top Boss.

However, did you realise that your post-product recovery role as a system and training provider is equally important compared to the decision that the boss has to make. Let us hear the preventative measures that you are going to propose in ensuring that this event does NOT occur again.

Can't take any more shittlegroover!

Charles

[rheath]

- I am a undefined  manager.

How ironical -

The word I typed here was 'systems', which I attempted to highlight in bold which was subsequently adjusted to undefined

I agree the shittlegroover argument is going nowhere.. Charles I think the written word is not doing either of us any good here as we seemingly getting wires crossed.

The point I am trying to make - albeit not very well is that if you’re line managers are empowered, knowledgeable & follow the system then all should be fine & dandy i.e. the knife would not be in a position to cause contamination in the first place.

Even if an incident did happen then immediate notification would have meant an internal sort takes place, which is far less expensive than a full recall (again appropriate action would be taken by the line manager to do this in our organisation).

In the shittle groover argument the point I was making is that in this hypothetical argument, the controls have failed (possibly) & at this point it is NOT MY CALL but the Senior Managers. Which is exactly the same statement that you have put in your last post.

“Therefore, a commitment to make that "difficult" decision rests on the shoulders of Senior Management”.

Within all this process, I certainly would NOT “abstain in recommending the course of action”.

Regards

Richard

[Charles Chew]

Dear Richard,

Agree above all - its Management's Call.

Regards
Charles Chew

[Charles Chew]

Hi,

How in the world did the products tainted with pieces of blade managed to pass through the metal detector anyway?

Maybe it is not possible for us to proof scientifically but analytical assessment is an important tool in HACCP. As this step (metal detector) is a CCP, a major non-conformance has occured and the loss of control has allowed potentially harmful products to the carried to the market place.

Fortunately, with recovery possible in transit, all is safe pending further aprorpiate action. Issue is simple: we knew the loss of control, where it happened and what caused the deviation of CL.

Question: What if the products had entered commerce and a customer called to INFORM that the product has some chemical odor in it and her son having consumed the product is now in the hospital for observation.

The product batch number is known, type and size including all other relevant information. Meanwhile, government authority has just got wind of this issue.

CAUSE OF HAZARD: Unknown BUT definitely NOT a CCP step.
RESPONSE TIME: ASAP
ACTION: Any suggestions

Food for thoughts.

Charles Chew

[Simon]