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CCP Not being performed - Recall?

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awallace

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Posted 29 January 2021 - 12:06 AM

I just found out one of my production lines has not been doing the CCP of x-ray for the past few weeks. They were supposed to use another machine, but apparently have not been doing that, and the person doing the monitoring did not notify our quality department or anyone! We are putting all of the product on hold, and having an emergency HACCP meeting, but do we now have to recall all the product made on that equipment? This is going to be a lot of products, so I'm wondering what our options are. I'm worried about the customers, as well as what we need to demonstrate to our SQF auditor when they see we are missing records for a month. I usually check the records monthly during our walkthrough audits, which is why it has been so long. Our product is mostly powders / beverage mixes that you would drink directly out of the package. Thanks!



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Posted 29 January 2021 - 01:00 AM

I just found out one of my production lines has not been doing the CCP of x-ray for the past few weeks. They were supposed to use another machine, but apparently have not been doing that, and the person doing the monitoring did not notify our quality department or anyone!

 

We are putting all of the product on hold, and having an emergency HACCP meeting, but do we now have to recall all the product made on that equipment? This is going to be a lot of products, so I'm wondering what our options are. 

 

I'm worried about the customers, as well as what we need to demonstrate to our SQF auditor when they see we are missing records for a month. I usually check the records monthly during our walkthrough audits, which is why it has been so long. 

 

Our product is mostly powders / beverage mixes that you would drink directly out of the package. 

 

Thanks!

 

Hi awallace,

 

Various aspects, eg Process CCP consequences, haccp documentation consequences, etc

History may also play a part.

 

^^^(red) - The easy answer is Yes. Assuming this is possible ?. US Regulatory aspects ?

 

^^^(blue). May depend on how SQF rates defects, eg Major, Critical etc.

 

There are several similar threads here with often extended discussions, eg - 

 

https://www.ifsqn.co...ring-operation/

https://www.ifsqn.co...this-a-failure/


Kind Regards,

 

Charles.C


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Setanta

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Posted 29 January 2021 - 12:53 PM

I just found out one of my production lines has not been doing the CCP of x-ray for the past few weeks. They were supposed to use another machine, but apparently have not been doing that, and the person doing the monitoring did not notify our quality department or anyone!

 

We are putting all of the product on hold, and having an emergency HACCP meeting, but do we now have to recall all the product made on that equipment? This is going to be a lot of products, so I'm wondering what our options are. 

 

I'm worried about the customers, as well as what we need to demonstrate to our SQF auditor when they see we are missing records for a month. I usually check the records monthly during our walkthrough audits, which is why it has been so long. 

 

Our product is mostly powders / beverage mixes that you would drink directly out of the package. 

 

Thanks!

 

 

I think first you need to ID all of the questionable product. Do you still have physical control of the all of the product? I would track all of the product at risk down, segregate it, and get it back to your site. Can you re-run it through a working x-ray to test it and see if it is good?


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Scampi

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Posted 29 January 2021 - 01:12 PM

My answer is yes. The company has an obligation to its customers to follow procedures determined NECASSARY to produce wholesome product, they failed. The plan determined a CCP was required, ergo recall or withdrawl needs to happen as deviation procedures were not followed either

 

If you don't recall this, the company may not see why procedures need followed and this WILL happen again

 

As an aside, why is CCP paperwork not being reviewed more often? This should have been caught week 1 not "the past few weeks"???

 

You're entire HACCP system needs reassessment to see where else the program is failing, I can guarantee this isn't the only spot


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SQFconsultant

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Posted 29 January 2021 - 02:02 PM

I just found out one of my production lines has not been doing the CCP of x-ray for the past few weeks. They were supposed to use another machine, but apparently have not been doing that, and the person doing the monitoring did not notify our quality department or anyone!

 

We are putting all of the product on hold, and having an emergency HACCP meeting, but do we now have to recall all the product made on that equipment? This is going to be a lot of products, so I'm wondering what our options are. 

 

I'm worried about the customers, as well as what we need to demonstrate to our SQF auditor when they see we are missing records for a month. I usually check the records monthly during our walkthrough audits, which is why it has been so long. 

 

Our product is mostly powders / beverage mixes that you would drink directly out of the package. 

 

Thanks!

 

two things - on the recall: YES

on how an Auditor will view this gap - this will be written up as a major finding, as long as you document the process from the time you found the error to how you closed it out, how you informed customers, etc.  Otherwise i would expect a critical without that satisfaction.


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Posted 29 January 2021 - 03:54 PM

This is definitely a recall situation.

An adequate corrective action is to adjust the frequency of verification of these CCP Monitoring records to a more suitable time frame (i.e. weekly, the next day). Monthly is not frequent enough.


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cgarcia1

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Posted 29 January 2021 - 05:26 PM

I just found out one of my production lines has not been doing the CCP of x-ray for the past few weeks. They were supposed to use another machine, but apparently have not been doing that, and the person doing the monitoring did not notify our quality department or anyone!

 

We are putting all of the product on hold, and having an emergency HACCP meeting, but do we now have to recall all the product made on that equipment? This is going to be a lot of products, so I'm wondering what our options are. 

 

I'm worried about the customers, as well as what we need to demonstrate to our SQF auditor when they see we are missing records for a month. I usually check the records monthly during our walkthrough audits, which is why it has been so long. 

 

Our product is mostly powders / beverage mixes that you would drink directly out of the package. 

 

Thanks!

 

From working in a USDA plant, that would turn into a recall of the product. The person who is supposed to monitoring the production should be held responsible for that error. If there is no consequences there would be no change, this is speaking from experience. I had to do a days worth of production since the metal detector was not being used. Ever since then, there has been no issue. Also, HACCP records should be reviewed way more often than once a month, I review daily for USDA. 



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awallace

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Posted 29 January 2021 - 05:32 PM

Thank you all for your quick responses! I suspected we would need to follow through with a recall of the products. Unfortunately, product did make it out the door. 

 

We will be making some serious revisions to our monitoring processes - it will officially be daily going forward. 



Scampi

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Posted 29 January 2021 - 05:45 PM

Best of luck to you through this

 

Use this as a learning opportunity within the company!


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