How to conduct a Mock Recall for an Agents and Brokers BRC audit?

Looking for advice on how to conduct a Mock Recall for an A&B BRC audit?

Have you experience with "normal" BRC (food) or similar?

I'd treat your A&B recall test pretty much exactly the same as that. Obviously your traceability element will be slightly different as you'll presumably not need to follow it back through manufacturing records, and for the stock reconciliation element it might not be your own warehouse - you may therefore need to ask any subcontracted warehouse(s) to do a physical stock check to verify quantities and/or dispatch records for you for the batch(es) in question.

I think the interpretation guide gives reasonable notes on the expected areas that should be covered by the test exercise.
It falls under the same clause (3.11) in Issue 8 of the Food standard, in case you also wanted to search around the forum/google for existing information on that, as it is a more widely adopted standard so there tends to be a bit more out there.

Otherwise if there are specific points you're struggling with then please advise which, and I'm sure you'll get some more detailed input :)

I have just done one and it is relatively straightforward compared to the other Standards. There will be variations depending upon the nature of your business, eg if the products are your own label or are generic brands.

First of all, you should have a Product Recall Procedure and if it is correct, it is that which you should follow don't make it up as you go along.

You need a starting point to create a scenario. I don't know what products you sell but choose a product and make up a defect that would normally justify a recall - for instance an undeclared allergen in a food product or a failed migration test if you sell packaging materials.

It is common to use a complaint that you have received to identify a product and its batch code.

Remember, a recall test is not just traceability, it tests management decisions and communications so you should start by having the appropriate senior manager making the decision to do a recall. 

Your procedure should have identified who in your team is responsible for the different tasks needed - person A to forward trace which customers have received that product and batch code, person B to go back to the supplier for production data etc. The latter is important because the defect may also have occurred in other batch codes/products made at the same time.

It is good practice to do all communications, internal and external, by email so that you have the date/time of the communications documented. If phone calls are made, record the times and people spoken to. 

As an Agent/Broker, you will not have your own warehouse but will probably use a sub-contracted warehouse and distributor. They will need to quarantine any remaining stock (and provide you with evidence that it has been done) and also that your supplier has quarantined any remaining stock that they may still have.

Correlate the quantities of products made by the supplier and dispatched to your warehouse with the quantity dispatched by your warehouse to your customers or still in stock and calculate the mass balance.

When you have identified your customers, make sure that you list out their contact details.

If the product is a generic branded one, you should ensure that the brand owner's contact details are also recorded.

Make sure that you state in your records that you would have informed the certification body if this had been a real recall, or any other agencies - FSA, labs, police, media etc.

You have 4 hours to complete the test or 24 hours if you have to obtain information from outside the company.

Write up the test in a timeline and review the effectiveness of the key components - mass balance percentage, communication problems etc.

One thing to bear in mind is that it is a test of the effectiveness of your procedure. If it doesn't work 100% correctly that is not a problem provided you have put in place a plan to eliminate the errors.If it is a total catastrophe, you will need to repeat the exercise after you have corrected the failings.

(After the test make sure you tell your supplier and distributor to take the products out of quarantine!)

Might note that "mock" recall, per se, is nowhere mentioned in BRC9. 4 hours is mentioned for "Traceability". (A&B no idea)

JFI here is a "straight" BRC worked example -

https://www.ifsqn.co...ort/#entry47832

(also note time comment in Post 9)

(The concise template form in Post 12 also looks quite useful)

Hi Charles,

Mock Recall is merely a difference in terminology, we used to call it a mock recall many years ago but now most people call it a test.

BRCGS Global Standard for Agents and Brokers Issue 3 clause 3.11.3 requires:

The product incident management procedures (including those for recall and withdrawal) shall be tested at least annually, in a way that ensures their effective operation. Results of the test shall be retained and shall include timings of key activities. The results of the test and of any actual recall shall be used to review the procedure and implement improvements as necessary.

Guidance offer by BRCGS:

The tests of the procedures must include verification of the decision-making process, traceability of products through the process from manufacturer to customer, verification of contacts and timings of key activities.

BRCGS Global Standard for Food Safety Issue 9 has the same requirements and refers to test as well.

With regards to the 4 hours requirement, BRCGS Global Standard for Agents and Brokers Issue 3 Clause 3.7.2 states:

The traceability test shall include the reconciliation of quantities of product traded by the company for the chosen batch or product lot. Traceability should be achievable within 4 hours (24 hours when information is required from external parties).

Kind regards,

Tony