Can we use Mock Recall information for a Traceability Exercise
If I perform a Mock recall exercise can I use the same info for my traceability exercise?
or will I need to do a separate exercise?
We are currently doing 8 exercise per year. 4 mock recall and 4 traceability.
If you utilizing the same traceability format for mock recalls as you are general traceability, then performing a mock recall is also testing your trace system at the same time. Unless you are auditing the traceability system on the floor or needing to perform mass balance exercises. In prior and current roles we would use a mock recall as a test to not only pull back the product, use our recall system, and then trace product 1 up and 1 back. if you are archiving high 90 percentage of recovery during your trace then placing that into the mock recall process, I would consider this sufficient to meet both requirements. I have independently audited the traceability system to review any breakdowns in recording information on the floor with staff and paper/electronic systems. This is different in your auditing the trace program as a whole, which could be a corrective action from a mock recall if you couldn't trace all your product within reason. Hope this gibberish makes sense.
Hi Norma,
You do not need to do your traceability and recall tests 4 times a year each, I would reduce that to a couple of times a year unless you are picking up issues.
Also, the traceability test can be done as part of the recall test providing you are conducting a full traceability in your recall test (for example, from supplier/raw materials to finished packaging & customer not just tracing finished packaging to customer).
So, if your audits, systems and previous tests are showing no issues with recall or traceability then I would reduce your number of tests from 8 in total to 2 recall tests per year but ensure that you include full traceability in the recall tests.
Relevant BRCGS Global Standard for Packaging Materials Issue 6 requirements and guidance are outlined below:
3.11.4
The traceability procedure and system shall be tested at a predetermined frequency, at least annually, ….
3.13.7
The product withdrawal procedure shall be tested, at least annually, …..
3.13.7 Interpretation
The test of the withdrawal procedure must include verification of the decision-making process, traceability of raw materials through to finished product, verification of contact details and timings of key activities.
Kind regards,
Tony