40 replies to this topic

[Charles Chew]

Hi Simon,

The blood just got thicker.

Government authority is taking action because the father of the child that is now in hospital happens to be a very "connected" person. Records need to be shown that we have an effective food safety plan in place and that our products are safe for consumption by the general public. CRISIS: we have 1 day to gather proof before govt. authority people comes around for inspection.

Customer Complain: : Hazard indicated by complainant is presence of chemical odor
Other known information : Batch No, Production Date, Pack Size and Product Type.
Potential Source : No clues due to non-specific hazards indicated.
Evaluation Area:
1) Check all CCPs control documents where chemical is being addressed in the HACCP Plan
- Indication of any deviation of CL
2) Check all areas where chemicals are used or applied i.e. Pest Control, Cleaning, Diesel Migration from burner or pipes, etc

Okay - we are done. Thank god, nothing has shown up which means we are "clean" and have not lost control of the entire monitoring system.

Verdict: Product may have been cross-contaminated by either customer directly or at point of sale or third party warehouse etc. BUT, all internal records ON THAT BATCH DATE have clearly shown FULL COMPLIANCE in all areas.

NO WORRIES!...........What do you think?

[Simon]

Okay - we are done. Thank god, nothing has shown up which means we are "clean" and have not lost control of the entire monitoring system.

Verdict: Product may have been cross-contaminated by either customer directly or at point of sale or third party warehouse etc. BUT, all internal records ON THAT BATCH DATE have clearly shown FULL COMPLIANCE in all areas.

NO WORRIES!...........What do you think?

Hmm...have you considered the contamination may have occurred at some point after leaving your factory but before reaching the point of sale / the consumer e.g. during the distribution process. If so we are far from clean.

http://www.saferpak....00&hl=transport

I think we've been here before.

Regards,
Simon

[Charles Chew]

Simon,

Yeah! I think we have been there before.

BUT it is relevant since we are dealing with frozen products:
1. Metal hazard (Blade remnants) - Unlikely to occur as it is protected by secondary packaging including tertiary with stretch wrap.

2. Chemicals - Unlikely, because out-sourced transport is not used. All trucks are dedicated.

This is where HACCP / assessment of risks is so dynamic. The report could be erntirely different had out-sourced transport been used where potential abuse or even sabotage may well be implicated.

Cheers
Charles Chew

[Charles Chew]

Certainly not the end of such an important aspect of a HACCP System. Can someone out there who has a deep knowledge on Pre-Product Recall decisions give us a hand here.

As mentioned somewhere in this topic, there is a need to identify potential loss of controls and look various points of the processes INCLUDING other verification exercises.

Perhaps, designing specific Pre-Product Recall Assessment Forms is a good idea. Could look at: (I am assuming that the potential recall may not be confined to a loss of control on a CCP), nevertheless,
1. CCP Non-conformance Report for a starter.
2. Overview on any deviations in Sanitation SOPs verification records.
3. Pest Control Management Review
4. Ingredients & packaging material non-conformances
5. Others

> A good HACCP Plan implementation follows the 12 principles starting from A - Z.
> A good Product Recall and Traceability Plan starts from Z - A.

Consider: Do you currently have a good communication path in your present recall plan?

Charles Chew

[Charles Chew]

Undertaking a hazard risk assessement (see exhibit 'A' case) to determine whether a potential risk to public health is at stake clearly achieves 3 major objectives:

1. Proof that a well documented haccp food safety plan is a measurable system and allows review to limit or avoid recurrence of similar causes.
2. Immediate adverse threat to public health can be determined within a practical response time.
3. Enable a preplanned methodology of product traceability and recovery.

Haccp is still the preferred food safety system which is why it is endorsed by WHO/CAC/FAO and is definitely coming into force under WTO international trade requirements by 1st January 2005.

Other additional requirements may be requested and often dictated by country or client specifics.

Charles Chew

[Charles Chew]

A hazard risk assessment on the food safety nature of a potentially affected product range / batch is likened to an internal food safety audit with particular specific to the potential cause(s) within the process environment.

Adding a new twist to this issue when nothing has been found to indicate any loss of control that may give rise to the indicated hazards in the process environment, could this be a case of product sabotage.

Well, what if exhibit 'A' appears to be more serious than I had expected and turned out to be a deliberate mess up by someone who happened to be a disgruntled former employee of the company. Wonder, what the company would have to do now when further investigation after Simon's dissatisfied reply indicated traces of arsenic being found.


Charles Chew

[Charles Chew]

A matter of interest - every product recall where "sabotage" is a potential suspect should involved the Police.

It would be a case of a recall subject to further investigations by both the Company and the Police.

There were many such cases of product recall due to this reason in the past and this can be very "ugly".

Charles Chew

[Charles Chew]

I am inhibited to move forward with this topic due to the slow and inappropriate responses coming for Simon on the OJF's case which I intend to use as a real life scenario.

Objectively, from the nature of the complaint, we should be discussing about traceability issue now but it is not to be just yet. I had expected a risk assessment to skew towards a product recall....

Lets wait on for a little while more....I am sure it is not the end of it

Charles Chew

[Charles Chew]

I know we are all waiting for Simon's next reply from the manufacture on exhibit A before we can move forward with this topic.

BUT the current situation does highlight the importance of a suitable "response time" whether in relation to a customer complaint or a decision on a potential product recall. Sadly, in Simon's case, it has only reached a customer complaint level nevertheless, I would expect the nature of this complaint to go beyond a hazard risk assessment towards a potential recall.

The customer/ QC department of the manufacturer of exhibit "A" obviously has a major problem with response time. By now, Simon would have lost his patience and as a customer, would probably never ever pick up products from this manufacturer in future.

On the other hand, had the product indeed posed an adverse health effect to the public consumers and a recall was never invoked, a lot of people could have taken ill or possibly worse.

So, what is your ideal response time in relation to the characteristics and expectations of your products. Would it be 3 hours or 1 day?

Charles Chew

Edited by charleschew, 24 June 2004 - 03:49 PM.

[just me]

Dear Charles,

Ummm...interesting topic, mind-blogging as well.

I vaguely remembered the case on Sara Lee's deli-meat in the late 1990s. 21 dead over a period of 4 months!!! ... Why 4 months??

On Exhibit A, I think that we are all technical people, we would want what is right to be carried out. But to our bosses, there are many other issues to consider, and more often than not money issue always win. In such a case, I think someone would be a scapegoat eventually...
I regret that the REAL world is not the Utopia that we sought.

On the second scenario, what about testing on retaining samples? Getting back some samples of the same batch from the market and test whether there is a same complaint on it?
The first response is to response to this issue, "assuring" the complainant that "we are doing something about it, and will let you know soon, but in the mean time, why not..."
Since it is indeed a VVIP involved here, I would say, the PR people would sought to "work it out" in some way, irregardless whether it is our fault.

What you do think?

Cheers,

Edited by just me, 29 May 2006 - 10:31 AM.

[Charles Chew]

Dear Wai Ling,

The business aspect of the organization is essentially left to the management to decide on the impact of not taking up the suggested proposal from the technical ppl. I guess in ISO 22000 thats where authority and responsibility comes into pla

On the second scenario, what about testing on retaining samples?

What if we do not retain production samples?

[just me]

Dear Charles,

The business aspect of the organization is essentially left to the management to decide on the impact of not taking up the suggested proposal from the technical ppl.

Yeah...that's why the management are the ones making big money. More $$$ means more responsibilities...

What if we do not retain production samples?

I think the next best bet would be tracing the batch, getting some samples back from the market or retailers and test on those samples to ascertain whether the source of the complaint came from the manufacturer. Shouldn't be too difficult IF the traceability program is indeed working.

By the way, happy "dumpling" day. Did you enjoyed any?

Cheers,

[Simon]

By the way, happy "dumpling" day. Did you enjoyed any?

I meant to ask what is dumpling day?

[just me]

I meant to ask what is dumpling day?

Dear Simon,

It's Chinese tradition. On every 5th day of the 5th month (Chinese calendar), the Chinese make and eat dumpling by the loads. It is actually glutinous rice wrapped in bamboo leaves and boiled, could be with savoury fillings or eaten sweet.

It's a tradition to honour a once honourable person in China, who went and kill himself by jumping into the river just because the Emperor told him to. Us Chinese have a saying: "If the Emperor ask me to die and I don't, it means betrayal".

So, to honour this guy, the people make the dumpling and throw it into the river, so that the fishes would eat the dumpling and not the dead guy's corpse.

Humoured?

It is like the Mid Autumn Festival, some calls it Mooncake festival, where we buy, give and eat mooncakes by the loads too. Ever heard of mooncakes? Serves people with sweet tooth.

Try it if you ever visit China, Singapore, Malaysia, Taiwan.

Cheers,

[Simon]

Try it if you ever visit China, Singapore, Malaysia, Taiwan.

I'd love to one day - thank's for the cultural lesson JM.

Regards,

Simon

[just me]

I'd love to one day - thank's for the cultural lesson JM.

Dear Simon,

Pleasure.

Cheers,