5 replies to this topic

[SueKaur]

Good day! Any advice on how to facilitate traceability? We are a coconut oil manufacturing organization wherein we do continuous milling (from copra), which goes to storage tanks. These oils will then be refined. It is not company practice to fully consume the contents of oil tanks before filling them with new product since it is costly (and would entail installing too many tanks). Would appreciate your inputs on how we could go about this issue. Thank you!

[SQFconsultant]

Familiar with similar operation in Costa Rica.

Question... at time of transfer from tank to refining step can you trace back to a certain tank or is everything mixed?

[SueKaur]

We have logs for the tanks where we get crude oil for refining although this is limited to the tank number and the time of intake. When we load our finished goods to tankers, we mix oils from different tanks so we can achieve the desired characteristics of our final product. 

 

So in case of a recall, given that our storage tanks never get emptied (unless for cleaning or repair) and our production is continuous, should we recall all released batches?

[TimG]

We also work with continuous batch. For traceability exercises when we factor incoming goods going into that lot, we pull the past 3 shipments of acid/base. Factoring in holding tank size and production schedule we get below 95% dilution (98% is typical) going back 3 truckloads of incoming acid/base (ingredients for our reaction) so we keep the incoming info in the trace exercise. We also note in our recall procedure that if a recall were to involve one of our 'ingredients' (acid/base=salt) that the scope of the actual recall would include calling back all lots created from those 3 incoming tankers (one full 10 day run) and possibly the next run as well (depending on cause for recall).

 

Not sure if that helps, but it might give you an idea of what you're looking for. Find the point where your dilution renders the hazards related to the incoming oil negligible. But keep in mind like Glen said, if you have several tanks, you will want to factor that in.

[SQFconsultant]

Ok, thanks - this is a similar situation with the Costa Rica facility.

 

They did have a recall and it was determined the best course of action was to recall all finished product and then go back to the tanks - 7 tanks were used in the mix. These tanks were sealed and testing was done on all 7.

 

The findings were that two of the tanks were tainted and contents of those two tanks were destroyed with the tanks actually being fully replaced.

 

Thus, course of action would appear to require the finished product recall and shut-down of tanks involved plus all piping, etc. and may require dumping lots of oil - in the Costa Rica facility the dump was somewhere in the neighborhood of 500,000 gallons.

[SueKaur]

Thank you very much, Glenn and Tim, for your inputs. We definitely want to avoid being in the same situation as the Costa Rica facility.

 

Do you have any advice on how we can improve our controls? Do you think our existing practice on product storage and dispatch (mixing from multiple tanks so we get the desired blend) can get us certified for FSMS?