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Rethinking our Recall Plan (moving to straight manual from manual/digital)

fsma recall documentation traceability

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Posted 30 January 2021 - 08:31 PM

Hi all,I wanted to run this by a few people because I came about the (possible?) solution in a very roundabout way.


Currently, we print recipes/CCP checks daily, enter in ingredient lot codes, track when that product was sent out, and then type those written lot codes/ ship dates into an excel database.


My reasoning was that would allow us to quickly do an audit of any ingredient batches we need to when we get our FSMA audit (the first for us, expecting soon). However, I was getting annoyed of how long it takes for us to digitally enter bake dates to each recipe, and began thinking of manual solutions.


We have a very short shelf life product ( we sell to customers as 24 hrs, though we know some hold on for longer), and a deep raw ingredient SKU but a moderate finished product/ parts SKU (around 30 items). 


I was thinking that; if all of our "live" recipe sheets are hung somewhere in the space, we could just write bake dates on each recipe as we go through it. That way, any product live on the floor is also live/visible document wise. If we want to conduct an audit, we could go literally look at each affected product to find if it has the audited lot code documented. THEN, and correct me if I'm wrong because it feels like the crazy part; we could move "finished" recipes to a holding file (5 days?) in case a customer really held on to something.... and then we could just manually file for 1 year.


Is that acceptable practice?


Does it need to be digitally filed? It feels crazy to not have a digital record, but if we have such a short shelf life, a visual audit of live recipes may actually be as fast for us as CtrlF through our product workbook. I guess my concern is if the audit is done backwards, suggesting we have an internal issue; but if we have all our CCPs monitored tightly and sanitation documented, then we are at very low risk (bakery); and we could still sort the records but it would take longer. 


This is all a bit mad since we were planning to move to an ERP preCovid which would help us w a lot of this, but since we are doing manually instead, wanted to try and write it out to see if it made sense. On the other hand, if you all have any elegant bakery recall systems which don't feature a 20K ERP or software program, I'm all ears!


Thanks all!

Edited by Charles.C, 01 February 2021 - 08:03 AM.



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Posted 01 February 2021 - 01:03 PM

I would be doing paper only, that's way too time consuming with very little to show for your efforts.


Correct me if I'm wrong, but baked good don't ship if the recipe or bake time/temp are off because they don't look like they should........which by default would prevent most of the issues from actually leaving before an issue was discovered


When I was in cannibis confections----we had an excel sheet for the batch (recipe) and the employees just had to add the weights and blending times etc. We had to verify the amount of distillate added (CCP) but other than that, paperwork was reviewed and then signed and filed---no electronic copy 



What do you hope to gain by going digital?

Please stop referring to me as Sir/sirs

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Posted 05 February 2021 - 10:48 PM


Thanks for the reply. We have been digital for the last year or so, but it's SO time consuming and double work. I was just mostly petrified that if FDA came to do mock recalls with us, that they would want to see an electronic record. I wasn't sure how far back they would want to be able to trace product/ingredient, and how long I would have to complete such a (again, mock) recall. 

Yes, baked goods, so our CCPs are largely taken care of by bake process; and then also allergens are a big worry. 


But we are switching to a much simpler manual tracing system this week; and so same idea as your plant; we will sign, hold, and then file away. 


Thanks for confirming my gut check!  

Also tagged with one or more of these keywords: fsma, recall, documentation, traceability

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