Recoup (2.4.5 & 2.6.2.1) Traceability
Curious to hear anyone's thoughts/experience on this:
- We have a facility operating under SQF v9 Storage & Distribution and one of our teams is working on a project for recouping cans of beverage that regularly come damaged from the supplier. Specifically pulling and combining good cans from damaged flats to create a new 'full case' of the beverage to send to our own stores. These beverages are currently not lot-tracked in our WMS as they move in and out of our facility quickly enough to not require any formal date controlling.
That being said for 2.4.5:
2.4.5 Product Recoup
2.4.5.1 The responsibility and methods outlining how product is recouped shall be documented and implemented. The methods applied shall ensure:
i. Recouping operations are conducted by trained personnel; and
ii. Recouped product is traceable.
If we wanted to move forward with recouping these beverages would we need to start lot-tracking them and actually be able to fully trace them in our system, or because the cans are individually stamped with lot information would that be sufficient to say that the product is traceable because that information is available per can.
Essentially do we need to be able to say exactly where every can went, or would it be sufficient to (in the event of an issue requiring recall/withdrawal/trace) instruct all stores that could have received the recouped product to check their individual cans and take action as necessary?
A bit long winded question, but I couldn't really find what I was looking for in previously discussed topics.
Thanks in advance!
Are the flats you receive mixed lots? Are you mixing lots when you recoup them?
If the FDA comes on-site with a lot code, can you confidently tell them where you got it from and where it went? You will probably need to start tracking it regardless of how long it's in your warehouse.
We do something similar at one of my non-SQF sites, (cross dock for a customer) but we never mix lots and we still track it by date (the lot isn't on the outer case, just the date, so we check cans to make sure everything but the time stamp matches). We also don't own the product though, just in one door and onto a trailer and out the other door same or next day.
Learned a long time ago to track everything, EVERYTHING GETS TRACED.
Are the retail units the can, or only the case?
If the individual cans are retail units and contain the manufacturer's traceability info I wouldn't expect you to need to add anything. The difference is in how you count the inventory.
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Essentially do we need to be able to say exactly where every can went, or would it be sufficient to (in the event of an issue requiring recall/withdrawal/trace) instruct all stores that could have received the recouped product to check their individual cans and take action as necessary?
...
You need to know who you sold the product to regardless of what units are sold.
Plenty of products out there are sold in multi-packs where the individual units contain traceability info. That doesn't absolve a distributor of knowing who to notify if a recall occurs.
Are the retail units the can, or only the case?
If the individual cans are retail units and contain the manufacturer's traceability info I wouldn't expect you to need to add anything. The difference is in how you count the inventory.
You need to know who you sold the product to regardless of what units are sold.
Plenty of products out there are sold in multi-packs where the individual units contain traceability info. That doesn't absolve a distributor of knowing who to notify if a recall occurs.
Thanks! The retail unit are the cans and they contain the manufacturer's traceability info. All of our customers are our own retail stores, for which we have shipment records - we're just not currently lot-tracking those beverages through our WMS. We're largely trying to reduce waste of throwing away a whole flat/case of the beverages if just a couple cans are damaged, even though the beverage manufacturer has indicated that the level of damages we're seeing and claiming credit for (full flats) is acceptable.
Are the flats you receive mixed lots? Are you mixing lots when you recoup them?
If the FDA comes on-site with a lot code, can you confidently tell them where you got it from and where it went? You will probably need to start tracking it regardless of how long it's in your warehouse.
We do something similar at one of my non-SQF sites, (cross dock for a customer) but we never mix lots and we still track it by date (the lot isn't on the outer case, just the date, so we check cans to make sure everything but the time stamp matches). We also don't own the product though, just in one door and onto a trailer and out the other door same or next day.
We're typically getting few lots at a time since we order/receive whole truckloads into inventory, and while recouping cans into a 'new' full flat with mixed lots is unlikely, there are probably times where it would happen or be unavoidable. Though the traceability codes would still be on the individual cans.
If the FDA came on site with a lot code today we could definitely tell them where we got it from, and with a reasonable degree of confidence tell them where it went based on when it was received and how items are replenished in our warehouse.
Appreciate the feedback!