52 replies to this topic

[BM5]

 

 

BM5, the "we do regular traces" part seems like the whole thing. Do you find the speed comes mostly from the systems, or from the practice itself, that everyone knows their part because you run it often? Asking because a lot of 204 readiness spend over here is going into software, and I suspect drill frequency is the cheaper variable that gets less attention.

 

The speed comes from the practice and knowing how to resolve an issue having emergency contact phone numbers available etc., in the event that there's an anomaly. There's a multitude of factors. We don't run any sort of digital trace software such as Prophet / PR3, everything is done on paper BUT it's all scanned in to a "day folder" so it's very easy to find, you just need to know where to look. This is all included as part of our crisis management pack. We also run an annual crisis management test, usually on Christmas Eve or New Years Eve, coz I'm a bastard like that   , which also includes a trace, this includes fake documents and also invlolving our customers and suppliers, in on it to really test the senior management team, particularly when most of our raw material is coming in from Spain! 

 

Annually we'll conduct the following:

 

Red Tractor Mass Balance x3

Retaielr 1 Trace Test x3

Recall Test requiring (Mass Balance of 2 Raw Materials for Retailer 1) x1

Retailer 2 Supplier Traceability Challenge x1 (This is random and can happen at any time - happened twice in 2025, none in 2026 so far!)

Packaging Mass Balance x2

Raw Material Mass Balance x2 (For Each QA Shift Supervisor)

BRC - Product, Raw Material and Packaging x1 during BRCGS audit

 

I can't get my head round other than trying to protect profits and shareholders as to why recalls / withdrawals aren't carried out sooner, or that being able to trace product isn't particularly seen as a priority, it's madness!

[seanjones]

Most third party certifications, and many large retail customers, put the requirement at 2-4 hours, including the ones requiring mass balance on identity preserved materials.  The regulators are way behind the curve on this.

That reframes it better than I had it. If GFSI schemes and the big retail customers already require 2 to 4 hours with mass balance, then 204's 24-hour clock isn't raising anyone's bar. The new part is federal enforcement plus the format: KDEs delivered as a sortable spreadsheet on request. Certified operations have the speed. I wonder how many have ever produced that specific output.

 

Hi Sean,

 

Having read the article, my kindest thought was that it lacked substance.

 

Although I can see being kept up-to-date with legislation as being useful, good luck with getting $49 a month for that sort of content.

 

Kind regards,

 

Tony

Fair enough, and I appreciate you actually reading it. The weekly brief itself is free, for what it's worth. But your read on what this audience pays for versus reads for free is worth more than most of my analytics, so noted, genuinely.
 

[seanjones]

The speed comes from the practice and knowing how to resolve an issue having emergency contact phone numbers available etc., in the event that there's an anomaly. There's a multitude of factors. We don't run any sort of digital trace software such as Prophet / PR3, everything is done on paper BUT it's all scanned in to a "day folder" so it's very easy to find, you just need to know where to look. This is all included as part of our crisis management pack. We also run an annual crisis management test, usually on Christmas Eve or New Years Eve, coz I'm a bastard like that   , which also includes a trace, this includes fake documents and also invlolving our customers and suppliers, in on it to really test the senior management team, particularly when most of our raw material is coming in from Spain! 

 

Annually we'll conduct the following:

 

Red Tractor Mass Balance x3

Retaielr 1 Trace Test x3

Recall Test requiring (Mass Balance of 2 Raw Materials for Retailer 1) x1

Retailer 2 Supplier Traceability Challenge x1 (This is random and can happen at any time - happened twice in 2025, none in 2026 so far!)

Packaging Mass Balance x2

Raw Material Mass Balance x2 (For Each QA Shift Supervisor)

BRC - Product, Raw Material and Packaging x1 during BRCGS audit

 

I can't get my head round other than trying to protect profits and shareholders as to why recalls / withdrawals aren't carried out sooner, or that being able to trace product isn't particularly seen as a priority, it's madness!

The Christmas Eve test with fake documents is diabolical, and I mean that as a compliment. Running it when half the team is mentally checked out is exactly the condition a real one arrives in.

 

The detail I keep coming back to is that you're doing this on paper. Two hours, no trace software, because a scanned day folder plus thirteen or so exercises a year means everyone knows where to look and who to phone. Over here a lot of 204 readiness budget is going into platforms, and your setup is a strong argument that the spend is landing on the wrong variable.

 

One more if you don't mind: in all those tests, what's the closest one has come to failing, and what did it change?