Mock Recall lack of traceability to batches

Hi, I'm performing a mock recall. Currently, my guys fill out batch sheets. So I know what ingredient lot and how many pounds are put into each product. It is then packaged, and could be either shipped, or can be stored either in the freezer, or ships the next day. My problem is, once products hit the freezer, I don't know what batch they came from. Nothing on the bags tell me since they are all blank. The owner despises paperwork and doesn't want to implement any more of it to keep track of inventory. So when performing a mock recall, or a real recall for that matter, since I can't trace the specific lots in the freezer or anything shipped from the freezer, should I just recall every single product that contained the ingredient regardless of the lot number? My mass balance will be well above 100% since I'll be recalling extra products that probably didn't contain the recalled lot, but its the only way at the moment. (Product has a 14 day shelf life, so I can just recall everything shipped from 14 days back from the recall date?). Will this be a major non-conformance??

If the owner despises paperwork maybe you can suggest another line of business for him/her?  See link below on the ramifications of not having proper food safety and/or quality system in place.

https://www.foodsafe...07573f-40022219

Stewart Parnell of PCA probably regrets some of his action(s) or lack of action(s) including documentation and records.

Good morning Steven. I typically like to address the question, but this one caught my eye:

...I can't trace the specific lots in the freezer or anything shipped from the freezer,

How do you trace product that is in the freezer? If you say "I don't" and this is product that you sell as food, then yes, that will be a major and probably also an FDA 483 if the FDA were to inspect your facility.

Owner needs to come to terms with their issue first before you move forward.

Tell the owner you know a consultant that is currently dealing with (this is happening today) an owner that is on the cusp of total company loss due to not being with the program.

All he had to do was invest a couple of thousand dollars for an automatic tracking system - but no, did not because they never had a problem before.

Now they do - complete and total meltdown and it would have been so easy.

As a former SQF Auditor I would see your completely inadequate recall/trace program as a critical and not a major finding.

The catch is, you know about the problem, ownership knows there is an issue but they are not doing anything about it.

Their refusal is what gets people killed.

In the case of our client, his refusal to buy a tracking system has already resulted in a death... there is no excuse for this, none.

For me the frustration is this doesn't even need a computer (depending on the # of different skus), it just needs done

You could color code by product and then record just the month/day on the correct color sticker on a case and the batch record.  Or buy avery style labels, and print off actual batch #s onto them and stick em on the cases

Here in Canada, no recall program, no problem you've got 7 days (not business days mind you, 7 days) to fix it our we yank your license. Badaboombadabing

You're in a horrible spot, but you can go around the owner and correct this in the ways I've mentioned----its not perfect, but it's better than what you have now!

Unrelated to specific disaster being discussed but a further comment is that the exercise described  also falls short of the typical requirements of a complete mock recall.

Hi,

I'm performing a mock recall. Currently, my guys fill out batch sheets. So I know what ingredient lot and how many pounds are put into each product. It is then packaged, and could be either shipped, or can be stored either in the freezer, or ships the next day. 

 

My problem is, once products hit the freezer, I don't know what batch they came from. Nothing on the bags tell me since they are all blank. The owner despises paperwork and doesn't want to implement any more of it to keep track of inventory.

 

So when performing a mock recall, or a real recall for that matter, since I can't trace the specific lots in the freezer or anything shipped from the freezer, should I just recall every single product that contained the ingredient regardless of the lot number? My mass balance will be well above 100% since I'll be recalling extra products that probably didn't contain the recalled lot, but its the only way at the moment. (Product has a 14 day shelf life, so I can just recall everything shipped from 14 days back from the recall date?)

 

Will this be a major non-conformance??

As others have said, it would be more than a major non-conformance. It may be disastrous, if disaster occurs. How would you possibly perform an actual recall (much less a mock one), if you don't have supply-chain traceability? If you can't fix this by yourself, I think Ryan's suggestion is quite good. 

If the owner really will not implement change to ensure traceability they definitely should not be the owner of a food business. 

If I was in this position I would be: 

1) getting out of there 

2) calling the FDA myself 

Please be careful - I'm not entirely sure of your position however if you are completing a mock recall and you know about this situation - the QC of PCA got into some major trouble !!!! This has scared me since and I will have nothing to do with a business that isn't operating how it should be. (hence why i'm leaving my current role!)

'Mary Wilkerson, 41, a former quality control manager at the now-defunct peanut firm, drew a five-year prison term for her conviction on obstruction in the tragedy.'

I'm aware that ^ is dramatic thoughts. This is where my mind spirals to  :eek_yello: