11 replies to this topic

[Sankara narayanan]

During pre assessment , auditor was insisting on mock recall records. His observation was:

The effectiveness of recall program has not been verified through a mock recall or other form of system challenge.(7.10.4)

I tried in vain substantiating that our internal spec for our final product is 'nil microbes'.
Since we have prepared for the audit sans any consultant, we may have exposed some loopholes in our system. So, can anyone help me with suggestions for conducting a mock recall?

Sankara Narayanan

[jamesgibb]

I tried in vain substantiating that our internal spec for our final product is 'nil microbes'.

Sankara,

What about chemical or physical hazards?

The auditor is correct that this is a mandatory requirement of the standard however you do not have to conduct a "mock withdrawal" you need to verify the effectiveness of the withdrawal programme.

What I would expect to see is that you can verify that your recall process will work.

in place of a mock withdrawal how about conducting an audit of all contact details for all customers and attempting to contact some of them as a "customer satisfaction" exercise.

You have confirmed that you can contact the customers when needed and as long as your tracability system is effective as per 7.9 then you can demonstrate that you have effectively verified the withdrawal process

I Hope this helps

James

[Simon]

If you did want to conduct a mock product recall I found some very useful guidance and document templates here:

How to carry out a mock product recall

Regards,
Simon

[Phillip Huff]

Our HACCP program is through the Canadian Food Inspection Agency and requires a min. of 1 mock recall per year. Basically we select a single finished product and conduct a full document trace including all raw ingredient lot codes, packaging, etc. and we determine to the first point of distribution (ie. a warehouse) how may cases of the finished product that we can trace. In ISO (as well as new CFIA requirements) we have to trace down to the actual store where the product went to. Our efficiency score is based on the percentage of how may cases we traced (to the store) over the cases of product we made.

We are required to contact the stores themselves and have them trace how much product they have. Its basically like a full product recall without actually notfying the public.

ISO requires both a recall of a finished product, as well as a full recall of an incoming ingredient (pick one ingredient and trace all product where the specfic lot was used).

Its a lot of work but its the only way to really test if your recall procedures will work in the case of a true recall.

[Charles.C]

Dear All,

Nice explanation above.

I would make one comment if you are an exporter. The mock recall is somewhat simplified if you choose a product which has not yet reached it's destination port. Contrarily, if you have to start tracing items which have gone into a central warehouse and then are redistributed to many sub-locations, the situation can rapidly get quite complex. No douby auditors are aware of these subtleties.

The first result is that deficiencies in tracing are rapidly revealed. The second result is that the criteria for a recall and it's implementation are also highlighted. It is actually a very valuable requirement.

Rgds / Charles.C

[Simon]

Might seem like a stupid question, but does a mock recall always have to involve a customer?

[Charles.C]

Dear Simon,

I guess not, well not explicitly anyway, have a look at this actual example -

http://www.sproutnet.../Press/mock.htm

However I have seen people go the whole hog and involve the customers under the "making sure of all eventualities" philosophy.

Rgds / Charles.C

[Simon]

Dear Simon,

I guess not, well not explicitly anyway, have a look at this actual example -

http://www.sproutnet.../Press/mock.htm

However I have seen people go the whole hog and involve the customers under the "making sure of all eventualities" philosophy.

Rgds / Charles.C

Thanks for the link Charles, what did we do before the internet.

Regards,
Simon

[cazyncymru]

Thanks for the link Charles, what did we do before the internet.

Regards,
Simon

Each of our sites carry out a full traceability exercise and a full mock recall on an annual basis.

Sometimes we do involve the customer, sometimes not.

We do this to demonstrate to BRC that we can trace our products.


What did we do before the internet??? mmmm Work!!! lol

[okido]

Hi Sankara,

A recall on annual basis is required in most FSMS’s.
There is EU legislation for products that are to be used in food or food contact, these products should be traceable one step forward and one step backward.
I would not involve customers as a rule.
If you involve customers be sure that they fully understand that it is a mock recall that should be carried out.
I know incidents were good product was scrapped because of misunderstandings.
You can trace an ingredient, suppose a quality defect in a product or a machine part is missing for a mock recall.
Make a record of what steps you take, who did what when and how and verify this against the procedure that is already in place.

Remember to share good fortune with you friends, Okido

[yorkshire]

I would not involve customers as a rule.
If you involve customers be sure that they fully understand that it is a mock recall that should be carried out.
I know incidents were good product was scrapped because of misunderstandings.

Good point.

I would just add that it is useful to check the out of hours contact list to see that it is still valid.
During our mock recall we phone a couple of the Recall Team / Directors and also a couple of our suppliers emergency contacts.

[Esther]

Dear all

I agree Okido. In one of our mock recalls we involved the customer and I have to explain her ,for several times, what was this about, the reason why and she started asking if that is possible to happen ( a food safety problem with our product ) and bla, bla, bla.. I regretted having contacted her. I think there is not necessary to involved customers, it is not our mission to check their traceability system.

Now I am thinking about of "taking advantage of the Non conformities" on the product along the year. In order to carry our an investigation, you may have to go through your traceability system and your suppliers and/ or other clients. So this exercise can replace the mock recall.

I would like to know the opinion of ISO 22000, BRC or IFS auditors about this idea.

Sincerely
Esther