7 replies to this topic

[vkul84]

Hello, we are unfortunately in the middle of a recall. We were notifed by our supplier that a product they sold us had a positive salmonella result (apparently they were notified by another customer of theirs). They had tested it when they recevied it and it tested negative and we recevied it based on their test results. It is a bit of a nightmare currently with CFIA and FDA involved, but luckily we only used the product once and made one lot of product with it so the recall has not been too diffcilut. 

 

What I need help with, is some advice on how to fill out the corrective and preventative actions for this. We have never had a recall of this type. Corrective actions would be the recall and disposal of all remaining material and etc I assume. But as for preventative actions I'm a bit stuck. Our supplier has been amazning about this and we want to keep using them (we are still waiting on their investigation results though). We usually do not test the material ourselves and rely on supplier testing (which has never been an issue at audits). 

 

Do we now need to implement some sort of testing for just this supplier? Our products are dried herbs and spices and we currently have a CCP in our HACCP plan that ALL incoming lots need a negative salmonella test. But I'm assuming I would need to implement something else considering this issue?

 

Any help or advice would be greatly appreciated. We are fairly new to SQF and I am learning as I go. Thank you.

[GMO]

I'd do some root cause analysis, if you're not sure how, there are free resources online or if you have recall insurance (which you probably do) sometimes there is money you can spend with external consultants to support around recall organisation and recovery.  They might be able to help here.

 

BUT... This is a tricky one.

 

So while your supplier did the test, and it tested negative, a test (IMO) cannot be a CCP.  I know that some other countries interpret HACCP differently, especially in Canada and the US but micro testing is almost always NOT a CCP because it's hard to prove a negative.  The CCP for Salmonella within your herbs and spices is presumably the heat treatment (or irradiation or whatever else they do) that the supplier's supplier does.  The testing is verification of that process, not a CCP in itself because that test is inherently fallible.  You can never test a sufficiently large amount to be 100% sure the batch is not contaminated.

 

So for me, it's the supplier to your supplier which is the really interesting part.  How do they control this and what failed here?

Then it's your supplier, what supplier assurance do they have?  How did that fail here?

 

When it gets to you, well, eek... I'm not sure there's much more that you can do apart from make sure that your direct supplier has good controls on their SQA and perhaps as a result of this you go through it together?

 

Thoughts from others?

[GMO]

Also - big virtual hugs.  No recall is ever a good place to be but nice to hear the good in all this that communication has been positive and everyone is doing the right thing.

[TimG]

I would first get very familiar with what my own Recall policy and Supplier Approval policy (and perhaps supplier scorecard/review policy) say. Make sure if you have guidelines on this already documented, you follow those. At the very least, I concur with the root cause analysis review (if your supplier is SQF they are probably doing this) and then a risk analysis that you (your company) would do based on that, discussed with key members of your team. 

[jfrey123]

Always rough to be subjected to a recall due to a supplier (or in this case a supplier's supplier).  As this recall wasn't due to your company's processing of the goods, a preventative action should be focused on supplier controls you have in place.  Do you have any such instructions in your SOP's for what to do with poor supplier performance?  I would request the supplier's investigation and CAPAs (they may want to do this over a meeting vs sharing physical copies), and likely increase verifications of the supplier's product for a period of time: place their material on hold and pull a composite sample from multiple cases to send in for verification testing for the next 3-6 months, charging them accordingly.

 

So many of us rely on COA's showing finished testing, and in this case it sounds like the supplier had their own testing that showed negative.  Just goes to show, to GMO's point, you cannot test your way into food safety because there's no guarantee your sample is reflective of the entire lot.

 

We did something similar to what I suggested when one of the major cheese makers had a national recall a couple of years ago.  Their executive QA team sat on a call with our executive QA team and went open book on their investigation and how it led to the issue.  Same thing with a major peanut butter supplier's recall a couple of years ago.  We still use both as suppliers, though even as big as my company is we aren't big enough to force those national brands to pay us for the increased testing...

[kconf]

If you are a processor and used the ingredient (with salm), did you get your final product tested before releasing? I don't know what your process is like or if there are controls.

 

If not a food processor - it depends on what your supplier sends you as their CAPA. You can tighten your supplier approval and ingredients risk assessment too if needed.

 

Good to know the whole recall is under control though. 

[Tony-C]

Hi vkul84,

 

My corrective action would also include a review verification procedures and move to positive release based on a negative Salmonella test.

 

As GMO has stated you need to carry out a Root Cause Analysis once you have the Investigation Results/Report from the Supplier.

 

I would also be looking at your Supplier Assurance Procedures (Approval and Monitoring) and Review the Food Safety Controls Implemented by the Approved Supplier including Process Controls and Sampling Methods and Frequencies for Salmonella.

 

I am also wondering what products you are making and if the herbs/spices can be put in at a step where they would undergo a treatment that would kill any Salmonella present?

 

Kind regards,

 

Tony

[SHQuality]

 Our products are dried herbs and spices and we currently have a CCP in our HACCP plan that ALL incoming lots need a negative salmonella test. But I'm assuming I would need to implement something else considering this issue?

If all your incoming products require a negative salmonella test, then how did this batch get approved for use? Did the supplier fail to perform a suitable sampling and testing for salmonella? Did your company itself fail to properly judge the COA?

 

If the supplier has done correct testing and their other customer found salmonella, you'd have to wonder if the contamination happened at their location rather than the supplier's. I agree that some root cause analysis is necessary here.