Fluid Dairy Recall Challenges

I am looking for some suggestions and input on a recall system for Fluid Dairy products. Currently when or if there is reason to recall or withdrawal a product we complete a blanket recall system. This ensure we have notified all customers that have received but also some that may have not received that specific lot code. I am trying to come up with a way that we can narrow this down to better specify what codes each customers receive. We are an older facility and do not have a scanning system, our product is packaged into milk crates and there is no identifier. The only thing that I can come up with is having the shipping employee manually write the code dates on the bills and providing a copy to file. If there was a withdrawal or recall we could manually sort through to find what customer received what lot. This also poses challenges. I am hoping that there are other dairy's that have similar challenges and can provide insight into what systems they are using and suggestion on if it is possible to improve this system. Thank you!!! :) 

 

You don't identify any of the lot information in any way currently?   If you can't change that, you'll have to stay doing what you're doing.

 

You could try having the shipper record some information, but you'd need to monitor that closely and shipping would have to have a way of knowing one lot from another

 

are you following CFIA requirments?

Subsections 92(1) and (2): Labelling information that must be provided with the food

• If the traceability requirements apply to you, you make sure that a label is applied, attached, or accompanies the food when you provide it to another person. The label must include the following information:
  • the common name
  • the name and principal place of business of the person by or for whom the food was manufactured, prepared, produced, stored, packaged or labelled

  • the lot code if it is a consumer prepackaged food.

    Note:

    • At retail, if you package food into consumer prepackages, the label may include either a lot code or unique identifier.
    • For food, other than consumer prepackaged food, the label may include either a lot code or unique identifier.

The OP is complying with the CFIA requirements because all of that information is on the individual container label.  I'm assuming this because of my experience in dairy and yeah a bit of it packing into milk crates which is a nightmare for a few reasons...including traceability.

 

Ultimately, you need to think about how the lots can be recorded and traced from loading to shipping and distribution.  If you can't identify a way to isolate this then you need to do a blanket market recall with all customers for that given product / item.

 

I do wonder...have you done a traceability exercise?  Can you at least identify where the product / item / lot all possible locations?  How does your mass balance shake out?

 

I'd press upper management to provide some type of system to do traceability.  If they have no stomach for the cost and are OK with doing a mass recall then that's fine and that's on them, but you need to be able to prove you can trace to all possible customers.  If you ever have a recall is your management team and executives OK with not getting the full information from your customers?  Are you going to assume any quantity not captured is out at the individual retail customer and a potential complaint / liability?