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Documentation of a Traceability Exercise


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#1 Plastic Ducky

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Posted 04 August 2020 - 08:26 PM

Hello all,

 

In a recent audit (NSF for Dietary Supplements) the auditor asked for us to show him a traceability exercise. We showed him a Mock Recall. He stated that the Mock Recall was not sufficient. I have read various threads on these forums discussing the inherent similarities in the two.

 

But my question is, I have written up dozens of Mock Recalls over the years. Will someone share with me their understanding of every thing that should be presented in the "write-up" of Traceability exercise?

 

I would assume; Finished Good Lot number and the total number of "eaches" produces, an invoice showing the shipment of all of that Finished Good Lot, a notation of the "eaches" in retain, the production record documenting the accuracy of "eaches" produced, same production record identifying the raw material lots associated with said production, BOL for all shipments related to the receipt of those raws.

 

What else? Truck inspection documents related to each receipt? What am I missing?

 

Sincerely,

 

Your grateful friend,

 

Plastic Ducky



#2 The Food Scientist

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Posted 04 August 2020 - 08:45 PM

Wait I thought a traceability exercise IS a mock recall? No?  :headhurts:  When auditors ask for that, we do a live mock recall right in front of them and they verify...

 

What you stated is already included in mock recalls. At least in mine  :shutup:


Edited by The Food Scientist, 04 August 2020 - 08:46 PM.

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#3 QA_Spices

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Posted 04 August 2020 - 08:55 PM

May be the auditor is just being picky (based on my experience with NSF auditors). As long as you are able to identify where your raw material came from, be able to describe how it was processed and where the finished product went you should be good. Some times auditors don't like that we use the same thing for a couple of clauses and this is the perfect scenario. I had the same issue on 2018, I got a major non conformance on my trace exercise because the auditor wanted a mass balance study which is not required by the code. I appealed it and got rid of the major non conformance. So again as you are able to identify where your raw material came from, be able to describe how it was processed and where the finished product went you are good.



#4 SQFconsultant

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Posted 05 August 2020 - 01:09 AM

Mock recall and traceability exercises are two different things.

 

Think tracing every single input and every single ingredient that goes into your finished product - every single item.

 

So, I have a bagel company that makes all sorts of bagels - Let's just focus on the cranberry orange bagels for this purpose.

 

This bagel has over 50 input items that include all the ingredients, all transport methods, breakdown of employees that were making them that day, what equipment was used, what were the pull points from the warehouse and refrigeration systems, any out of normal circumstances for that production taken from daily log, etc.

 

So, we think of a tracing exercise the same way we do a food defense challenge exercise, very much forensic with every single big and small detail noted.

 

Stuff like this can take days to do - thus a computer FSMS is really an asset and that is what we use to generate these exercises in minutes instead of days - I remember doing my first one and by the end of 3 days I was pulling the hair out.

 

Doing the tracing exercises will make doing recalls (if you ever have to do  a real one) and mock recalls a snap.


Kind regards,

 

Glenn Oster
 
 
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Do you really like doing it yourself? 

We can do it for you,

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#5 FoodSafetyAPP

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Posted 05 August 2020 - 08:08 AM

Hello. 

 

I love a traceability exercise, hate recall exercises. Also, when an auditor asks me a forward trace test and a backwards i die inside because to me it is the same thing. 

 

We are an egg packing site so fairly simple, but i'll list what we include in ours. (the amount of docs some require now has gone up over the last year - so this could be a bit excessive)

 

We have a form that lists the following:

- date / completed by

- time started / time finished 

- product 

- BB date of product

- date / time packed

- lane packed on

- producer PEN (probably irrelevant for you, this is the number from the farm that is stamped on the eggs)

- producer name (supplier name of the product)

- batch grading (or processing / packing date)

- start / finish time of processing batch

- batch quantitiy

- collection of product date (or delivery of supplies etc.)

- collection of product quantity (quantity received in that delivery)

- oldest date on that delivery

- the finished product packaging batch code (for us, the packaging comes on big pallets and each pallet has it's own ticket from the supplier, this has a batch code so we can trace the packaging)

- certificates of conformity from the suppliers (so any ingredients etc. used from external suppliers - their certificate numbers 

 

then we attach the evidence, such as:

- grading sheet (the machine we use for grading (processing) has a print off sheet for each batch

- original incoming tickets (any incoming product used, the ticket . delivery note etc. for that - they also tend to want the original and not a copy)

- supplier certificates (relating to the product)

- we include vehicle checks, delivery schedules, driver reports for that vehicle on the day of delivery

- an order form / delivery note showing the product going to the customer

- the original packaging label for the packaging used along with the delivery note of the packaging coming to us

 

You really could go on and on, they might want to see other checks completed such as temperature checks, changeover checks, weight checks, anything remotely related to that end product. 

 

I do this once a month - i think if you do one step forward AND one step backward it covers both forward and backward under the same trace. As i said we have a simple process to relatively easy for us. 



#6 olenazh

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Posted 05 August 2020 - 12:21 PM

Our traceability exercise also includes packaging materials (e.g. cups, lids, sealant film) and corresponding Receiving reports & BOLs/invoices, production records indicating their lots and quantities used. 



#7 TimG

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Posted 05 August 2020 - 02:52 PM

Interesting. I was instructed that there was a difference in a mock recall/trace exercise, but that difference was only in the Mock Recall including your trace exercise as well as proof you've verified all on file recall numbers were still up to date and accurate, preferably with a call to that #. So, for example, you'd sit with the customer contact list and mark off as you go "Hello, we have this name and number on file as our contact in case a recall of our product was initiated. I am just calling to verify this is still accurate." Basically the "Mock Recall" was top level and there to test you had your communication lines open in prep for an actual recall. I can't recall ever seeing the distinction I was taught in writing, however, and all of the above explanations sound equally plausible.

My suggestion would be to touch base with the auditor and get to the root of what they are looking for. Take a good hard look at the NSF code (my NSF auditor always references the code) and if you think it's too far above and beyond what their code requires, challenge it. 

Being in a facility that gets audited by SFSF, NSF, AIB, various USP bodies, by state auditors to several different types of state code, I've found their suggestions can easily contradict the requirements of another. 



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#8 bakeryscience

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Posted 05 August 2020 - 06:27 PM

I was under the impression that the difference is what TimG stated as well.



#9 liberator

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Posted 05 August 2020 - 10:25 PM

Traceability - can you find and account for everything that went into your finished product - ingredients, packaging etc?, specs, certification, coa etc and where it all went? Do the material inputs equal the total of product outputs - anything missing? Where did all of that finished product go in the supply chain, can you find it all?

 

Mock Recall - can you find and account all that finished product that was manufactured, from when it came off the line, to your warehouse, to third party warehouse, to customer warehouse to supermarket. Can you do this both forward and backwards? Does your system have the right contacts - can you challenge the system appropriately to find all the finished product?

 

An example

Traceability:,One of your material vendors advised you that they have found an issue with an ingredient supplied to you - can you trace and account where and what product that ingredient went into? (Mass balance)

 

Mock recall: You have identified what products this has gone into, can you trace all of the product so you can complete a recall(mock or real) and remove the product from the market? Mass balance to confirm all the manufactured product equals all of the product out there, in your system and the supply chain - can you find all of the product?

 

In reality, both are traceability, it's just the depth/detail required

 

Traceability - finding anything and everything that went into the product and where the finished product went and can be accounted for by mass balance.

 

Mock recall/recall - find the finished product though the manufacturing and supply chain and account for it all by mass balance.






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